5. Operation

5.1 Towing Safety

5.1.1 Regulatory Reference

5.1.1.1 The following regulations contain requirements that are applicable to some of the risks associated with tugs and tows:

  • Safe Working Practices Regulations
  • Maritime Occupational Health and Safety Regulations (see 5.1.1.2)

5.1.1.2 Vessels with employees that are covered by federal health and safety legislation will fall under Part 2 of the Canada Labour Code (Section 123) and the Maritime Occupational Health and Safety Regulations. Most vessels that operate only within the limits of a province will have employees that are covered by that province’s health and safety legislation.

5.1.2 Additional Guidance

5.1.2.1 A review of the recent safety record of the towing industry indicates that the greatest risks to tug personnel are associated with movements between tug and tow, e.g. between tug and barge or between tug and log boom, and the most serious accidents occur when crew fall directly from the tow. Such occurrences are impossible to prevent by regulation, and require a safety culture aboard the tug, with an emphasis on crew awareness of the risks associated with moving onto the tow from the relative safety of the tug itself.

5.1.2.2 However there are risks inherent with every aspect of towing or ship assist. Owners must be familiar with these risks and promote safety through good design, sound construction, careful maintenance, and the implementation and enforcement of safe working practices, including in particular:

  • Operations around rotating and reciprocating machinery
  • Operations with electrical equipment
  • Operations handling fuel and oils
  • Use of major deck equipment, towlines and mooring lines
  • The appropriate matching of the tug itself to the tow and the conditions and locale in which the tow will take place

5.2 Pollution Prevention

5.2.1 Regulatory Requirements

5.2.1.1 The following regulations and standards apply to the pollution prevention aboard all tugs:

  • Vessel Pollution and Dangerous Chemicals Regulations
    • Part 1 for general requirements
    • Part 2 for specific requirements:
      • Division 1 for oil
      • Division 2 for noxious liquid substances and dangerous chemicals
      • Division 3 for marine pollutants
      • Division 4 for sewage
      • Division 5 for garbage
      • Division 6 for air pollution
      • Division 7 for pollutant substances
      • Division 8 for anti-fouling systems
    • Part 3 for pollutant discharge reporting
  • Ballast Water Control and Management Regulations, for all vessels that are designed or constructed to carry ballast water:
    • Sections 4 and 5 for ballast water management
    • Sections 6 and 7 for ballast water exchange
    • Sections 8 and 9 for ballast water treatment and exchange standards
    • Section 10 for sediment disposal
    • Sections 11 and 12 for ballast water management plan

5.2.1.2 The following regulations and standards apply specifically to the operation and maintenance of pollution prevention equipment:

  • Vessel Pollution and Dangerous Chemicals Regulations, Part 2
  • Ballast Water Control and Management Regulations

5.2.1.3 Particular attention should be paid to sewage discharges in designated sewage areas, as listed in Schedule 2 of the Vessel Pollution and Dangerous Chemical Regulations. For requirements, refer to section 96 of the Vessel Pollution and Dangerous Chemical Regulations.

5.3 Crewing

5.3.1 Regulatory Requirements

5.3.1.1 The crewing requirements for all Canadian vessels are provided in the following sections of the Marine Personnel Regulations Part 2:

  • Training and Familiarization – Section 205 and 206
  • Minimum Complement – Sections 207 to 210
  • Safe Manning Requirements – Section 211
  • Masters and Deck Officers – Section 212
  • Deck Watch – Sections 213 to 216
  • Engineers – Section 217 to 222
  • Engineering Watch – Sections 223 to 225
  • Dual Capacity – Section 226
  • Cooks – Section 227
  • Radio Watch – Section 264 to 267 (where a ship station is required by the Ship Station (Radio) Regulations, 1999)
  • Medical Examination of Seafarers – Division 8

5.3.1.2 The maritime labour standards for Canadian vessels are provided in the Part 3 of the Marine Personnel Regulations.

5.3.2 Additional Guidance

5.3.2.1 It should be noted that there may be some union agreements across Canada which may require crew complement to exceed those of the regulations.

5.4 Safe Operating Procedures

5.4.1 The Canada Shipping Act 2001, section 106, requires the authorized representative of a tug to develop procedures for the safe operation of the vessel and for dealing with emergencies, and to ensure that the crew receives safety training. The authorized representative is also required under the Marine Personnel Regulations, section 206, to provide the vessel master with written instructions to ensure that each member of the vessel complement is familiar with the shipboard equipment operational instructions specific to the vessel and can effectively perform their duties related to safety and pollution prevention.

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