Emergency towing procedures should be vessel-specific

Several years ago, the International Maritime Organization (IMO) introduced an amendment to the International Convention for the Safety of Life at Sea (SOLAS) regarding emergency towing arrangements.

The original legislation required tankers of 20,000 tons deadweight and greater to be fitted with emergency towing arrangements at each end of the ship.  MSC.256 (84) revised SOLAS Chapter II-1/3-4 by expanding the requirement for documented procedures to all ships of 500 gross tons and greater.

In short, ships and yachts “shall be provided with vessel-specific emergency towing procedures.  Such procedures shall be carried aboard the yacht for use in emergency situations and shall be based on existing arrangements and equipment available on board the yacht.”  For regulatory purposes, commercial yachts are considered cargo ships.

The deadline for compliance with the emergency towing procedures began a phase-in period on Jan. 1, 2010.  Since that date, all passenger ships in operation and new passenger and cargo ships delivered after that date must have emergency towing procedures in place. For cargo ships built before Jan. 1, 2010, they were required to be in compliance no later than Jan. 1, 2012.

An important item to note is that the existing construction and configuration  of the yacht shall be used to develop the procedures. In contrast to the original regulation, it required the installation of a specific emergency towing arrangement. The procedures should be considered as part of the emergency preparedness required by paragraph 8 of part A of the International Safety Management Code.

These yacht-specific procedures can be created by any qualified party, but preferably one experienced in towing operations. In developing these, it must be remembered that the nature of an emergency does not allow time for deliberation.  And not all yachts will have the same deck equipment, so there will be limits to possible towing procedures. Because of these factors, the intention is to predetermine what can be accomplished, and provide this information to the yacht’s crew.

The owner, through the captain, should ensure that the yacht is inspected and its capability to be towed under emergency situations is evaluated. Both equipment on board and available procedures should be reviewed. The ability of the yacht to be towed from bow and stern should be included. Items to be considered are the line handling procedures; layout, structural adequacy and safe working loads of connection points (fairleads, chocks, winches, bitts, bollards); anchor chains, shackles, stoppers, tools, and line throwing apparatus. The radio equipment should be identified in order to enable communication between deck crew, bridge, and the towing/salvage ship.

Following the evaluation, procedures should be developed for inclusion in the Emergency Towing Booklet. The IMO-issued guidelines recommend certain topics be included, such as:

• A quick-reference decision matrix that summarizes options under various emergency scenarios, such as weather (mild, severe), availability of shipboard power (propulsion, on-deck power), imminent danger of grounding, etc.
• Organization of deck crew (personnel distribution, equipment distribution, including radios, safety equipment, etc.)
• Organization of tasks (what needs to be done, how it should be done, what is needed for each task, etc.)
• Diagrams for assembling and rigging bridles, tow lines, etc., showing possible emergency towing arrangements for both fore and aft. Rigged lines should be lead such that they avoid sharp corners, edges and other points of stress concentration.
• Power shortages and dead ship situations, which must be taken into account, especially for the heaving across of heavy towing lines.
• A communications plan for contacting the salvage/towing ship.

All of these need to be documented in a clear, concise, and ready-to-use format (booklet, plan, poster, etc.)  This Emergency Towing Booklet should include yacht-specific data, including the yacht’s name, call sign, IMO number, anchor details (shackle, connection details, weight, type, etc.), cable and chain details (lengths, connection details, proof load, etc.), height of mooring deck(s) above base, draft range, and displacement range.  Comprehensive diagrams and sketches of the assembly and rigging, towing equipment, strong point locations, and safe working loads.

A copy should be kept at hand by the owners and/or shoreside management in order to facilitate the transfer of information to the towage company. A copy should be kept in a common electronic file format, which will allow faster distribution to concerned parties.

The IMO requires that a minimum of three (3) copies should be kept on board and located on the bridge, the forecastle space, and the ship’s office.

While the SOLAS amendment does not state that a formal approval is required, it will be at the discretion of the yacht’s flag of registry if a copy must be submitted for review.  

While most existing commercial yachts already comply, it is the formerly private yachts transitioning to commercial that must ensure new compliance.

Capt. Jake DesVergers currently serves as Chief Surveyor for the International Yacht Bureau (IYB), a recognized organization that provides flag-state inspection services to private and commercial yachts on behalf of several flag-state administrations.  A deck officer graduate of the US Merchant Marine Academy at Kings Point, he previously sailed as Master on merchant ships, acted as Designated Person for a shipping company, and served as regional manager for an international classification society.  Contact him at 954-596-2728 or www.yachtbureau.org.