This is an important yet frequently misunderstood subject for masters, mates and pilots of towing vessels, but I’ll try to make this as simple and pain-free as possible. Before I get into the specifics of the regulations, the following requirement must be gone over and understood. To serve as a pilot on towing vessels in navigation within designated pilotage waters and towing inspected tank barges authorized by their Certificate of Inspection (COI) to proceed beyond the Boundary Line, or operating on the Great Lakes, you must meet one of the following standards:
Hold a license or endorsement as first class pilot for the particular pilotage route you are navigating on, as per 46 CFR § 10.701. Those holding these endorsements are sometimes referred to as federal pilots, in that their pilotage is granted by federal authority (the Coast Guard).
Meet the requirements spelled out in 46 CFR § 15.812 to “serve as pilot”, which is normally referred to as “acting as pilot”. Any towing vessel officer meeting these requirements may “act as pilot.” That is what the vast majority of us do and, on a practical level, we’re de facto federal pilots when we do so.
If you’re moving a tank barge or barges totaling over 10,000 GRT you must have a first class pilot at the con at all times while underway in pilotage waters. The tug’s master or mate may serve in this capacity if they’re properly endorsed to do so. A tank barge or barges totaling 10,000 GRT or less can, alternatively, be under the control of a master or mate qualified to “act as pilot.” Pilotage waters, and the specific pilotage routes within them, are designated by the local Coast Guard Officer in Charge, Marine Inspection (OCMI) for that sector or zone, and they’ll furnish you with a detailed list of them upon request.
Keep in mind that this applies to any and all inspected tank barges authorized by their COI to proceed beyond the boundary line (referred to as coastwise seagoing) whenever they’re underway in designated pilotage waters or navigable waters of the United States that aren’t designated as pilotage waters, as well as those operating on the Great Lakes. Tank barges authorized by their COI for Inland routes only (Lakes, Bays & Sounds/Rivers), other than those operating on the Great Lakes, have no pilotage requirement at all, regardless of size. Strange, huh?
To “act as pilot” when handling tank barges the regulations require that you be at least 21 years of age, and have a minimum of 12 round trips as an observer over that particular pilotage route, of which at least 3 (25%) must have been made during the hours of darkness if you want authority to make night transits on that route. Finally, as per 46 CFR § 15.812(b)(3)(iv), you must also have at least 6 months of service (presumably measured in 8-hour days, although it doesn’t specify) in the deck department of towing vessels engaged in towing operations. That translates into 8 calendar months in a 2-watch system on an equal time schedule, and sure blows a big hole right through the new 30-day Wonder program! Coast Guard “policy” (not to be confused with actual federal law or regulations) requires that at least 2/3 (8) of the round trips be made with a barge in tow, however any OCMI has the authority to further reduce or completely eliminate this requirement if they feel it is “appropriate.” Yes, you read that right. I can’t imagine how any OCMI could possibly deem it to be “appropriate” without being guilty of dereliction of duty, but they have that option. The remaining 1/3 (4) of the round trips can be made on a vessel of “reasonable size”, although this is not specifically defined except to say that an outboard motorboat is not a vessel of reasonable size. Well, that sure is a big relief. But are we to assume that a slightly larger inboard motorboat would be okay? This policy also allows for the substitution of trips with dry-cargo barges to meet the barge-in-tow requirement. But it doesn’t stipulate what percentage (if any) of the round trips must be with a loaded barge (dry-cargo or tank), thereby making this poor policy. Not only should every trip be with a barge, at least half of them should be with a loaded barge. How else can someone legitimately learn all the specific local knowledge they’ll need to safely navigate and maneuver tank barges (both loaded and light) along a pilotage route? This whole “policy” could use an overhaul.
Don’t forget the annual physical examination! As per 46 CFR § 10.709, it’s a requirement for all first class pilots and your authority becomes invalid without it. You’ve got until the first day of the month following the 1-year anniversary of your last physical. Just in case you think that this doesn’t apply to you because you “act as pilot” and don’t have a first class pilot’s license or endorsement, think again. 46 CFR § 15.812(b)(3)(iii) specifically states that individuals may serve as pilot on a tank barge provided that he or she “Has a current physical examination in accordance with 46 CFR § 10.709.” However, because 46 CFR § 10.709(a) reads “this section applies only to an individual who pilots a vessel of 1,600 gross tons and over” it creates a possibly unintended loophole, thereby exempting tank barges less than 1,600 GRT. So for them you technically don’t need an annual physical, just the usual 5-year license renewal physical exam.
I’ll take this opportunity to point out that virtually all towing vessel officers routinely refer to their authority to “act as pilot” as “recency.” This is technically incorrect and, more importantly, confuses another very important aspect of pilotage as well. The slang term recency, when correctly used, refers solely to whether or not you’ve made a round trip over a given route within 5 years of your last round trip on that route, thereby keeping your authority to “act as pilot” active or valid. Hence the term recency! The Coast Guard officially refers to this in the regulations as “currency of knowledge.” As per 46 CFR § 10.713(a), Requirements for maintaining current knowledge of waters to be navigated, “if a first class pilot has not served over a particular route within the past 60 months, that person’s license or endorsement is invalid for that route, and remains invalid until the individual has made one re-familiarization round trip over that route.” Translation: you don’t have to start over from scratch if you go past the 5-year limit on a given pilotage route, you just need a refresher round trip as an observer to reactivate your authority for another 5 years. Please keep in mind that this means someone else on the boat must have both the required pilotage and recency, or else you must retain the services of someone who does. Basically, once you’ve acquired your dozen round trips, you have pilotage for life. You can’t really lose it, as it just becomes inactive if you don’t have recency.
The Coast Guard’s NVIC #8-94, Issues Regarding Federal Pilotage, is required reading for all mariners, so get to it!
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