Task Order: USAED GS-10F-0242L 

Deliverable Number: 6 

Report Number: 469-05 

Uninspected Towing Vessel 

Industry Analysis Project 

Final Report 

Sponsored by: 

United States Coast Guard 

2100 Second Street, SW 

Washington, DC 20593-0001 

Issued August 2006 

Prepared by ABSG Consulting Inc. 
ii 
iii 

EXECUTIVE SUMMARY 

This project was sponsored by the United States Coast Guard (Coast Guard) to support the 

ongoing development of a proposed regulation to require the inspection of towing vessels. It was 

intended to assist the Coast Guard with making regulations that reflect the risks of the towing 

industry, both those faced by towing vessels and crews and those posed by towing vessels to 

other maritime infrastructure (e.g., bridges, locks). 

The project consisted of a number of activities, which are documented in this report, including: 

(1) analysis of towing industry vessel population and characteristics (e.g., age, size, service), (2) 

visits to selected towing companies to discuss industry issues and concerns, (3) risk evaluation of 

towing vessel accident history, (4) analysis of economic impacts of towing vessel inspections, 

and (5) development of recommendations for Coast Guard consideration as the proposed 

regulation is developed 

During this project there was no publicly available draft of a proposed towing vessel inspection 

regulation. Therefore, this report does not provide an evaluation of the potential risk-reduction 

impact of such a new regulation, nor does it provide a complete regulatory cost analysis. 

However, the information in this report is intended to help the Coast Guard make decisions about 

potential regulatory options and will help support a more comprehensive regulatory impact 

analysis when required. 

Results of the work are presented in this report and are highlighted below: 

Industry Analysis and Characterization − There are numerous difficulties in trying to use the 

Marine Information for Safety and Law Enforcement vessel registry to examine the number of 

towing vessels in the industry and the characteristics of those vessels (e.g., age, length, 

horsepower, service). 

Comparison with and use of U.S. Army Corps of Engineers data sources can contribute to 

better understanding of the portion of the towing industry involved in waterborne 

commerce, but lack of data and conflicting data still present problems − Based on the 

reviews performed in this effort, the project staff estimated that there are 5,100 to 5,200 towing 

vessels that are likely to be covered by a towing vessel inspection regulation. (This estimate does 

not include approximately 1,200 towing assistance vessels and an unknown number of small 

workboats supporting marine-related construction.) 

Risk Evaluation of Towing Vessel Accident History (1994-2003) − The project implemented a 

Coast Guard risk evaluation approach that allows the evaluation of the historical risk profile of 

the towing vessel industry, including safety, economic, and environmental impacts. Although 

there are only a limited number of large consequence events (only 12 events out of more than 

3,600 examined were assigned to the Coast Guard severe or major severity categories), those 

events presented more than 75% of the consequences over that time period. Many of the same 

causes that in very specific circumstances cause major losses occur much more frequently with 

only minor, if any, consequences. This indicates that although major events are what the Coast 

Guard wants to prevent, it requires focusing on the underlying contributing factors for all 

accidents - and the majority of the data comes from minor events. 
iv 

Analysis of Economic Impacts of Towing Vessel Inspections − Evaluation by the Coast Guard 

of the economic impact of a towing vessel inspection regulation that involves a specific 

requirement to implement a towing company safety management system (SMS) will be difficult. 

This project examined costs for both potential equipment requirements and the development, 

implementation, and maintenance of an SMS. To structure the cost evaluation, the project used 

equipment and SMS recommendations made by the Towing Safety Advisory Committee (TSAC) 

Work Group (WG) on Vessel Inspection (in its report dated 9/29/05). 

The potential costs of equipment addition are relatively easy to evaluate, and some of the towing 

industry personnel consulted indicated that many towing vessels already included most of that 

equipment. Because of that, the actual cost impact of a requirement similar to the TSAC WG 

would be small for those vessels. However, that same conclusion may not apply to the large 

number of vessels that belong to companies that are not active in TSAC WG and/or members of 

American Waterways Operators. A comprehensive regulatory impact will need to address that 

issue. 

The results of the examination of the economic impact of requiring that an SMS be provided for 

all towing vessel suggest a wide range of costs for SMS development and implementation. The 

range not only is affected by the size and towing activities of the companies, but also reflects the 

starting point for the specific company and the level of detail the company management chooses 

to include in its SMS implementation. This variation in cost is consistent with what has been 

experienced in other regulatory imposition of performance-based SMSs. 

Observations from Discussions with Selected Towing Companies − Project personnel and 

Coast Guard representatives met individually with a small number of towing companies to 

review example SMSs and identify issues of concern to the towing industry. Issues that were 

raised by the towing company personnel are provided in Section 2.2 of this report and address 

potential economic impacts of towing vessel inspection, including direct costs (e.g., for 

equipment, documentation, inspections), business impacts (e.g., down time required to 

accommodate Coast Guard inspections or mandated drydock inspections.), and other regulatory 

implementation issues. 

Recommendations for Coast Guard Consideration − The project team developed a number of 

recommendations for consideration by the Coast Guard. These recommendations are: 

1. Consider excluding workboats and towing assistance vessels from the proposed 

regulations for inspection of towing vessels. (See Section 6.2.1)

2. Ensure that large horsepower towing vessels (i.e., greater than 5,000 horsepower) receive 

the regulatory attention they deserve based on historical accident experience examined in 

risk terms. (See Sections 6.1 and 6.2.2)

3. Consider providing effective training when the final rule for the towing vessel inspection 

regulation is released and then providing periodic training for Coast Guard inspectors and 

third-party personnel who will be involved in towing vessel inspections, in order to help 

ensure consistency in regulatory review and enforcement. (See Section 6.2.3)

4. Consider encouraging small business outreach/assistance programs by industry 

organizations or by the Coast Guard to assist small towing companies in SMS 

development and implementation, both for compliance purposes and to help them achieve 

real human factors improvements. (See Section 6.2.4)
v 

5. Consider offering alternative inspection approaches (i.e., that do not require a company 

safety management system) for companies that prefer being subject to a more prescriptive 

inspection regime. (See Section 6.2.5)

Each of these recommendations is described in more detail in the sections of the report 

referenced here. However, they will need to be examined further by the Coast Guard as a more 

specific regulatory proposal is developed. 
vi 
vii 

TABLE OF CONTENTS 

Section Page

EXECUTIVE SUMMARY ....................................................................................................... iii 

LIST OF TABLES ..................................................................................................................... ix

LIST OF FIGURES ................................................................................................................... xi

LIST OF ACRONYMS ............................................................................................................. xiii 

1. INTRODUCTION................................................................................................................. 1-1 

1.1 Uninspected Towing Vessel (UTV) Regulatory Project .......................................... 1-1 

1.2 Objectives and Tasks for this Industry Analysis Project.......................................... 1-4 

1.3 Definitions ................................................................................................................ 1-4 

1.4 Report Organization ................................................................................................. 1-7 

2. RESULTS OF SPECIFIC PROJECT TASKS .................................................................. 2-1 

 2.1 Estimation of Towing Industry Vessel Population................................................... 2-1 

 2.2 Performance of Visits to Towing Companies in Various Ports................................ 2-4 

3. ANALYSIS OF TOWING INDUSTRY VESSEL CHARACTERISTICS ..................... 3-1 

3.1 MISLE Vessel Registry............................................................................................ 3-1 

 3.2 USACE WTLUS Vessel Registry ............................................................................ 3-6 

 3.3 MISLE to WTLUS Comparison............................................................................... 3-9 

 3.4 Industry Trending Analysis ...................................................................................... 3-12 

4. TOWING VESSEL ACCIDENT HISTORY AND RISK EVALUATION..................... 4-1 

4.1 Previous Examinations of Towing Vessel Accident History ................................... 4-1 

 4.2 UTV Industry Analysis Project Risk Evaluation...................................................... 4-3 

 4.3 UTV Historical Risk Profile..................................................................................... 4-4 

5. ANALYSIS OF ECONOMIC IMPACTS OF TOWING VESSEL INSPECTION........ 5-1 

6. PROJECT CONCLUSIONS AND RECOMMENDATIONS .......................................... 6-1 

6.1 Conclusions .............................................................................................................. 6-1 

6.2 Recommendations .................................................................................................... 6-2 

7. REFERENCES...................................................................................................................... 7-1 

Appendix A Preliminary Unit Cost Assessment of an Inspection Regime for the 

 Uninspected Towing Vessel Industry ........................................................... A-1 
viii 
ix 

LIST OF TABLES 

Table Page

2.1 Towing Company Visits by Project Personnel................................................................ 2-5 

3.1 Categories for Vessel Characteristics.............................................................................. 3-2 

4.1 Consequence Matrix........................................................................................................ 4-5 

4.2 Number of Vessel Casualty Incidents per Severity Category for Impacts on People ..... 4-6 

4.3 Number of Vessel Casualty Incidents per Severity Category for Economic Impacts..... 4-6 

4.4 Number of Vessel Casualty Incidents per Severity Category for Impacts on 

 the Environment .............................................................................................................. 4-6 

4.5 Count of Incidents by Year and RIN Range.................................................................... 4-7 

4.6 Causal Factors/Subfactor Categories............................................................................... 4-13 

4.7 Vessel Service Categories ............................................................................................... 4-13 

4.8 Vessel Operation Categories ........................................................................................... 4-13

4.9 Injury Severity Counts (July 2005 to June 2006)............................................................ 4-24 
x 
xi 

LIST OF FIGURES 

Figure Page

2.1 Estimates of Number of Active Towing Vessels ............................................................ 2-2 

2.2 Towing Vessel Companies by Fleet Size (Based on WTLUS 2003).............................. 2-4 

3.1 Length Over Deck (ft) Categorization (MISLE Data)..................................................... 3-3 

3.2 Gross Registered Tons (GRT) Categorization (MISLE Data) ........................................ 3-3 

3.3 Age Categorization (MISLE Data).................................................................................. 3-4 

3.4 Horsepower Categorization (MISLE Data)..................................................................... 3-4 

3.5 Waters Categorization (MISLE Data) ............................................................................. 3-5 

3.6 Construction Material − Hull (MISLE Data) .................................................................. 3-5 

3.7 Length Over Deck (ft) Categorization (WTLUS Data)................................................... 3-7 

3.8 Net Tonnage Categorization (WTLUS Data).................................................................. 3-7 

3.9 Age Categorization (WTLUS Data)................................................................................ 3-8 

3.10 Horsepower Categorization (WTLUS Data) ................................................................... 3-8 

3.11 Length Over Deck (ft) Categorization (“Active” MISLE Vessels vs. WTLUS 

Vessels vs. “Active” MISLE with Distributed Unknowns) ............................................ 3-10 

3.12 Net Tonnage Categorization (“Active” MISLE Vessels vs. WTLUS 

Vessels vs. “Active” MISLE with Distributed Unknowns) ............................................ 3-10 

3.13 Age Categorization (“Active” MISLE Vessels vs. WTLUS 

Vessels vs. “Active” MISLE with Distributed Unknowns) ............................................ 3-11 

3.14 Horsepower Categorization (“Active” MISLE Vessels vs. WTLUS 

Vessels vs. “Active” MISLE with Distributed Unknowns) ............................................ 3-11 

3.15 Length Over Deck (ft) Trending Analysis (1997 – 2004)............................................... 3-13 

3.16 Gross Tonnage Trending Analysis (1997 – 2004)........................................................... 3-13 

3.17 Age Trending Analysis (1997 – 2004) ............................................................................ 3-14 

3.18 Horsepower Trending Analysis (1997 – 2004) ............................................................... 3-14 

4.1 Basic Elements of Risk Measures ................................................................................... 4-4 

4.2 Number of Vessel Casualty Incidents Related to Towing Vessels per Year 

 (1994 – 2003) .................................................................................................................. 4-8 

4.3 Risk by Age Categories (RIN/Exposure Year)................................................................ 4-9 

4.4 Risk by Horsepower Categories (RIN/Exposure Year)................................................... 4-10 

4.5 Risk by Length Categories (RIN/Exposure Year)........................................................... 4-10 

4.6 Risk by Net Tonnage Categories (RIN/Exposure Year) ................................................. 4-11 

4.7 Geographic Distribution of High Consequence Incidents............................................... 4-15 

4.8 Percent of Incidents by Causal Factors ........................................................................... 4-16 

4.9 Percent of Human Factor Incidents by Subfactors .......................................................... 4-16 

4.10 Percent of Equipment Failure Incidents by Subfactors ................................................... 4-17 

4.11 Percent of Incidents by Operation ................................................................................... 4-17 

4.12 Percent of Incidents by Service ....................................................................................... 4-18 

4.13 Percent of Human Factor Incidents by Operation ........................................................... 4-18 

4.14 Percent of Equipment Failure Incidents by Operation .................................................... 4-19 

4.15 Percent of Human Factor Incidents by Service ............................................................... 4-19 

4.16 Percent of Equipment Failure Incidents by Service ........................................................ 4-20 
xii 

LIST OF FIGURES (cont’d) 

Figure Page

4.17 Injury vs. Fatality Trending Analysis (1994 – 2004) ...................................................... 4-21 

4.18 Fatalities by Accident Category (90 Fatalities) (1994 – 2004) ....................................... 4-22 

4.19 Injuries by Accident Category (2,534 Injuries) (1994 – 2004) ....................................... 4-22 

4.20 Contact Fatalities by Accident Type (80 Fatalities) (1994 – 2004) ................................ 4-22 

4.21 Contact Injuries by Accident Type (1,935 Injuries) (1994 – 2004) ................................ 4-23 

4.22 Noncontact Fatalities by Accident Type (8 Fatalities) (1994 – 2004) ............................ 4-23 

4.23 Noncontact Injuries by Accident Type (69 Injuries) (1994 – 2004) ............................... 4-23 

4.24 Overexertion Injuries by Accident Type (481 Injuries) (1994 – 2004)........................... 4-24 

4.25 Nonvessel Casualty Risk by Age Categories (RIN/Exposure Year) (1994 – 2004) ....... 4-25 

4.26 Nonvessel Casualty Risk by Horsepower Categories (RIN/Exposure Year) 

 (1994 – 2004) .................................................................................................................. 4-26 

4.27 Nonvessel Casualty Risk by Length Categories (RIN/Exposure Year) (1994 – 2004)... 4-26 

4.28 Nonvessel Casualty Risk by Net Tonnage Categories (RIN/Exposure Year) 

 (1994 – 2004) .................................................................................................................. 4-27 
xiii 

LIST OF ACRONYMS 

AWO American Waterways Operators 

COTP Captain of the Port 

FRP Fiber reinforced plastic 

GRT Gross registered tons 

hp Horsepower 

ICW Intracoastal waterway

ISM International Safety Management 

ISO International Standards Organization

ITV Inspected towing vessel 

MISLE Marine Information for Safety and Law Enforcement 

NFPA National Fire Protection Association 

RCP Responsible Carrier Program 

RIN Risk index number 

RWG Report of the Working Group 

SMS Safety management system 

SOLAS Safety of Life at Sea Convention 

TSAC Towing Safety Advisory Committee 

USACE United States Army Corps of Engineers 

UTV Uninspected towing vessel 

WCUS Waterborne Commerce of the United States 

WTLUS Waterborne Transportation Lines of the United States 
xiv 
1-1 

1. INTRODUCTION 

1.1 UNINSPECTED TOWING VESSEL (UTV) REGULATORY PROJECT 

In the U.S. Coast Guard and Maritime Transportation Act of 2004 (Pub. L. 108-293), Congress 

added towing vessels to the list of vessels subject to inspections and authorized the United States 

Coast Guard (Coast Guard) to consider establishing a safety management system appropriate for 

towing vessels. 

The specific language in the Act related to towing vessel inspection is as follows : 

SEC. 415. INSPECTION OF TOWING VESSELS. 

(a) VESSELS SUBJECT TO INSPECTION.--Section 3301 of title 46, United States Code, is 

amended by adding at the end the following: 

 (15) towing vessels. 

(b) SAFETY MANAGEMENT SYSTEM.--Section 3306 of chapter 33 of title 46, United 

States Code, is amended by adding at the end the following: 

 (j) The Secretary may establish by regulation a safety management system appropriate 

for the characteristics, methods of operation, and nature of service of towing vessels. 

To implement adding towing vessels to the list of inspected vessels, the Coast Guard has to develop 

the specific regulations under which towing vessels will be inspected. It is important to note that 

"uninspected vessel" is not equivalent to "unregulated vessel." Although towing vessels under 300 

gross tons, operating inside the boundary line (as defined in 46 CFR 7), are currently uninspected, 

there are numerous regulations that apply to them, including measures for: 

• Manning requirements and crew licensing 

• Fire protection and fire suppression 

• Lifesaving equipment 

• Pollution prevention 

• Navigation rules 

Although the Coast Guard is not required to periodically examine uninspected towing vessels for 

compliance with these regulations, compliance is expected and enforcement actions are taken if 

noncompliance is recognized (e.g., in a post-accident investigation). 

Additional input was provided to the Coast Guard regulatory development by Congress in the 

conference report on the act (U.S. Congress, 2004), which states: 

Section 415. Inspection of Towing Vessels 

The House bill does not contain a comparable provision. 
1-2 

The Senate amendment does not contain a comparable provision. 

The Conference substitute adds towing vessels, as defined in section 2101 of title 46, United 

States Code, as a class of vessels that are subject to safety inspections under chapter 33 of 

that title. Section 3306 of title 46 details the items that are to be regulated under the 

chapter to secure the safety of individuals and property on board the vessel. This includes 

design, construction, alteration and repair of the superstructures, hulls, fittings, equipment 

appliances, propulsion equipment, machinery, lifesaving equipment, firefighting equipment, 

and vessel stores and other supplies of a dangerous nature. 

The Coast Guard may prescribe different standards for towing vessels than for other types 

of inspected vessels. Similarly, the Coast Guard can prescribe different standards for the 

various types of towing vessels based on size, horsepower, type of operation, area of 

operation. For example, the Coast Guard can prescribe different standards with regard to 

propulsion machinery and hulls for a towing vessel pushing barges down the Mississippi 

River than for vessels that provide towing assistance for recreational vessels. 

New section 3306(j) of title 46, United States Code, authorizes the Secretary of the 

department in which the Coast Guard is operating to establish by regulation a safety 

management system appropriate for the characteristics, methods of operation, and nature 

of service of towing vessels. Safety management systems allow the Coast Guard to oversee 

the maintenance and repair of vessel equipment and ship systems subject to inspection 

through an approved safety management plan that includes maintenance schedules and 

system tests. The Coast Guard may enforce the plan through audits of the vessel’s logs and 

vessel operator’s records rather than having to directly oversee the repair or maintenance 

work conducted on a particular piece of equipment or ship system. 

This action by Congress resulted from many influences, among them: 

• Publicity regarding towing vessels and associated barges being involved in several large 

consequence events (e.g., pollution events, bridge strikes, fatal accidents) over the 

previous decade 

• Input by maritime labor organizations regarding their view of the working conditions 

aboard towing vessels and the overall safety of the towing vessel crews 

• Input from the towing industry that an inspection regime primarily based on onboard 

inspection by Coast Guard assets was not the only way that an effective vessel 

inspection program could be organized 

• The desire by the towing industry to consolidate its regulatory involvement with the 

Coast Guard, rather than having to deal with the Coast Guard on some issues and the 

Occupational Safety and Health Administration (OSHA) on others 

Note: Federal law requires OSHA not to take steps to regulate an industry or activity where the 

industry/activity's hazards are adequately addressed by the regulations of another federal agency 
1-3 

(OSHA, 1996). This has traditionally meant that OSHA did not generally involve itself in 

regulating conditions on vessels formally inspected by the Coast Guard, but could choose to do so 

on uninspected vessels. 

In response to this congressional mandate, the Coast Guard provided two notices in the Federal 

Register to announce public meetings and to ask for public and industry input (Fed Reg, 2004 and 

Fed Reg, 2005). The public meetings were held in four locations around the country in January 

and February 2005. The notices requested input regarding the following questions: 

(1) Towing vessels of a certain size (300 or more gross register tons) are already 

inspected vessels and are subject to a variety of existing requirements. Should the 

Coast Guard use any of these existing standards (or standards for other types of 

inspected vessels) for incorporation into the new regulations regarding the 

inspection of towing vessels? If so, which regulations or standards should be 

incorporated into these new regulations? 

(2) Title 46, United States Code, specifies the items covered with regard to inspected 

vessels including lifesaving, firefighting, hull, propulsion equipment, machinery and 

vessel equipment. However, the legislation that added towing vessels to the list of 

inspected vessels, authorized that the Coast Guard may prescribe different 

standards for towing vessels than for other types of inspected vessels. What, if any, 

different standards should be considered with regard to inspected towing vessel 

requirements from other inspected vessels? 

(3) Towing vessels vary widely in terms of size, horsepower, areas of operation, and 

type of operation. Under what circumstances, if any, should a towing vessel be 

exempt from the requirements as an inspected vessel? 

(4) Should existing towing vessels be given time to implement requirements, be 

‘‘grandfathered’’ altogether from them, or should this practice vary from 

requirement to requirement? 

(5) Should existing towing vessels be treated differently from towing vessels yet to be 

built? 

(6) The same act that requires inspection of towing vessels authorizes the Coast Guard 

to develop a safety management system appropriate for the towing vessels. If such a 

system is developed, should its use be required for all inspected towing vessels? 

(7) Examples of existing safety management systems include the international safety 

management (ISM) code and the American Waterways Operators Responsible 

Carrier Program. If a safety management system is used, what elements should be 

included in such a system? 

Responses to those questions and other input from the public and industry have been collected in 

the docket for this proposed regulatory action (i.e., Docket USCG–2004–19977) and are being 

considered by the Coast Guard in its regulatory development. 
1-4 

1.2 OBJECTIVES AND TASKS FOR THIS INDUSTRY ANALYSIS PROJECT 

The objective of this project is to provide technical support services required to aid the Coast Guard 

in developing regulations governing the inspection of towing vessels. Its technical tasks (and the 

chapter of this report that provides information from those tasks) are as follows: 

• Characterization/Categorization of the UTV Industry 

• Accident History Data Gathering for the Inspected and Uninspected Towing Vessels 

• Risk Analysis of Towing Vessel Accident History 

• Economic Impacts Analysis Associated with Inspection Requirements 

• Preparation of a UTV Industry Analysis Report 

The ABSG Consulting Inc. (ABS Consulting) team included personnel from ABS Consulting and 

Abt Associates (the economics analysis subcontractor for this effort). They worked closely with 

the Coast Guard regulatory development team during this effort. This resulted in several changes 

in the original focus of the project, including: 

1. Modification of proposed project approaches that required detailed, defined regulatory 

alternatives – Those alternatives were not yet developed to allow the project to be as 

specific in this analysis as originally proposed. This issue was discussed with the Coast 

Guard project team and the project effort was revised as necessary. 

2. Elimination of the analysis of the risks associated with potential illegal activities 

involving towing vessels (e.g., drug smuggling, customs violations, transporting of illegal 

aliens) – The Coast Guard project team did not believe that the inspection regulation 

development and implementation were expected to address the reduction of potential 

illegal activities involving towing vessels; therefore, such an analysis was not necessary. 

3. Increased effort applied to the economic analysis – The resources saved by deleting the 

illegal activities analysis discussed above were applied to increased collection of 

economic impact data. However, that data collection was limited in detail because of 

change 1 noted above. 

These changes in project focus were (1) discussed in meetings or conference calls with the Coast 

Guard regulatory development team and (2) documented in the original project management plan 

(dated 11-29-05) or in the monthly reports submitted to the Coast Guard as required under the 

contract. 

1.3 DEFINITIONS 

The most important definitions for this project are for towing vessels and various types of towing 

vessels or service, including definitions from various Coast Guard regulations: 
1-5 

Towing vessel is a commercial vessel engaged in, or intending to engage in, pulling, 

pushing, or hauling alongside, or any combination of pulling, pushing, or hauling alongside. 

(46 CFR 27, Fire Protection; 33 CFR 164.70, Navigation Safety Regulations) 

Towing vessel is any commercial vessel engaged in towing another vessel astern, 

alongside, or by pushing ahead. (33 CFR 161.2, Vessel Traffic Management) 

Fleeting or assist towing vessel is any commercial vessel engaged in towing astern, 

alongside, or pushing ahead, used solely (1) within a limited geographic area, such as a 

particular barge fleeting area or commercial facility, and (2) for restricted service, such as 

making up or breaking up larger tows (33 CFR 157.03, Rules for the Protection of the 

Marine Environment Relating to Tank Vessels Carrying Oil in Bulk). 

Additional definitions provided below have been extracted from 46 CFR 10.103 Part 10 — 

Licensing Of Maritime Personnel, Subpart A—General, § 10.103. 

Assistance towing means towing a disabled vessel for consideration. 

Disabled vessel is a vessel that needs assistance, whether docked, moored, anchored, 

aground, adrift, or under way, but does not mean a barge or any other vessel not regularly 

operated under its own power. 

Harbor assist is the use of a towing vessel during maneuvers to dock, undock, moor, or 

unmoor a vessel, or to escort a vessel with limited maneuverability. Note: Also called 

"ship assist" in some cases. 

Inland waters are the navigable waters of the United States shoreward of the Boundary 

Lines as described in 46 CFR part 7, excluding the Great Lakes and, for towing vessels, 

excluding the Western Rivers. For establishing credit for sea service, the waters of the 

Inside Passage, between Puget Sound and Cape Spencer, Alaska, are inland waters. 

Near coastal means ocean waters not more than 200 miles offshore. 

Oceans are the waters seaward of the Boundary Lines as described in 46 CFR part 7. For 

the purposes of establishing sea service credit, the waters of the Inside Passage, between 

Puget Sound and Cape Spencer, Alaska, are not considered oceans. 

Rivers are any river, canal, or other similar body of water designated by the Officer in 

Charge, Marine Inspection. 

Western Rivers are the Mississippi River, its tributaries, South Pass, and Southwest Pass, 

to the navigational demarcation lines dividing the high seas from harbors, rivers, and other 

inland waters of the United States, and the Port Allen-Morgan City Alternate Route, and 

that part of the Atchafalaya River above its junction with the Port Allen-Morgan City 

Alternate Route, including the Old River and the Red River, and those waters specified in 

33 CFR 89.25. 
1-6 

Additional definitions from 46 CFR 27, the regulation defining fire protection requirements for 

towing vessels include: 

Accommodation includes any: 

(1) Messroom 

(2) Lounge 

(3) Sitting area 

(4) Recreation room 

(5) Quarters 

(6) Toilet space 

(7) Shower room 

(8) Galley 

(9) Berthing facility 

(10) Clothing-changing room 

Engine room is the enclosed area where any main-propulsion engine is located. It 

comprises all deck levels within that area. 

Fixed fire-extinguishing system is: 

(1) A carbon-dioxide system that satisfies 46 CFR subpart 76.15 and is approved by 

the Commandant; 

(2) A manually operated clean-agent system that satisfies the National Fire Protection 

Association (NFPA) Standard 2001 (incorporated by reference in Sec. 27.102) and 

is approved by the Commandant; or 

(3) A manually operated water-mist system that satisfies NFPA Standard 750 

(incorporated by reference in Sec. 27.102) and is approved by the Commandant. 

Fleeting-area is a separate location where individual barges are moored or assembled to 

make a tow. The barges are not in transport, but are temporarily marshaled, waiting for 

pickup by different vessels that will transport them to various destinations. A fleeting-area 

is a limited geographic area. 

Harbor-assist means docking and undocking ships. 

Limited geographic area is a local area of operation, usually within a single harbor or port. 

The local Captain of the Port (COTP) determines the definition of local geographic areas 

for each zone. 

Operating station is the principal steering station on the vessel from which the vessel is 

normally navigated. 
1-7 

Towing vessel is a commercial vessel engaged in, or intending to engage in, pulling, 

pushing, or hauling alongside, or any combination of pulling, pushing, or hauling alongside. 

Towing vessel in inland service is a towing vessel that is not in ocean or coastal service. 

Towing vessel in ocean or coastal service is a towing vessel that operates beyond the 

baseline of the U.S. territorial sea. 

Work space is any area on the vessel where the crew could be present while on duty and 

performing their assigned tasks. 

The project team also found it necessary to agree on working definitions for other terms that are 

commonly used by the industry (and sometimes in Coast Guard regulations) but are not explicitly 

defined in the Coast Guard regulations. These terms are: 

Boundary line is a line of demarcation established under Section 2(b) of 33 U.S.C. 151. 

Generally, boundary lines follow the general trend of the shoreline and cross entrances to 

small bays, inlets, and rivers. For specific descriptions of boundary lines refer to 46 CFR 

Part 7. 

Certificate of Inspection is a Coast Guard document issued to U.S. vessels inspected by 

the Coast Guard and which contains, among other information: the description of the vessel, 

the route the vessel may travel, the minimum crew requirements, the safety equipment and 

appliances required to be on board, the total number of persons that may be carried, and the 

names of the owners and operators. [46 USC Section 3309] 

1.4 REPORT ORGANIZATION 

The remainder of this report describes the steps taken by the analysis team and the results of the 

analyses to describe the UTV community and to help the Coast Guard estimate the impact of 

towing vessel regulations they will develop. 

Section 2 Results of Specific Project Tasks 

Section 3 Analysis of Towing Industry Vessel Characteristics 

Section 4 Towing Vessel Accident History and Risk Evaluation

Section 5 Analysis of Economic Impacts of Towing Vessel Inspection 

Section 6 Project Conclusions and Recommendations 

Section 7 References 
1-8 
2-1 

2. RESULTS OF SPECIFIC PROJECT TASKS 

Two specific tasks that the Coast Guard requested be performed in this project were: 

• Estimation of the size of the current towing vessel fleet 

• Performance of a selected number of port visits to discuss towing vessel inspection issues 

with towing company personnel 

These tasks are described in Subsections 2.1 and 2.2, respectively. 

2.1 ESTIMATION OF TOWING INDUSTRY VESSEL POPULATION 

The UTV industry analysis project team performed a detailed analysis of data to gain an 

understanding of the towing vessel community operating in US waterways by reviewing a number 

of data sources, including: 

• MISLE vessel registry (2005) 

• Snapshots of the MISLE vessel registry for previous years (1997 to 2004) 

• USACE 2003 Waterborne Transportation Lines of the United States (WTLUS) vessel 

registry (WTLUS, 2003) 

• Inland River Record (IRR, 2006)

• Owner/operator vessel lists obtained during site visits 

In addition to these databases, the project team also consulted industry data provided by the 

American Waterways Operators (AWO), some of which were developed in conjunction with the 

Coast Guard as part of the Coast Guard-AWO Safety Partnership. (Selected AWO statistics are 

provided on the internet at http://www.americanwaterways.com/industry_stats/index.html). 

As shown in Figure 2.1, the Coast Guard's MISLE database contains more than 7,900 towing vessel 

records, but about 2,800 of them are recorded as "inactive." This leaves MISLE with 5,142 active 

towing vessels. This number is similar to the 5,172 vessels reported in the USACE WTLUS 

database (WTLUS, 2003), and manual comparison of entries in the two databases shows there is a 

very large overlap. However, each source contains some vessels that do not appear in the other 

source. For example, the MISLE database primarily consists of vessels documented with the Coast 

Guard; however, if a state-registered vessel (e.g., which could be a towing vessel less than 26 feet 

in length) is involved in an accident report to the Coast Guard, a MISLE entry would appear for 

that vessel. However, if the vessel was not involved in commercial towing as reported to the 

USACE, it would not appear in the WTLUS data source. The analysis team found that because of 

the quality of the data and the lack of consistently common data fields, it was not practical to make 

a reliable one-to-one comparison of the vessels in the two sources. Even within a single data set, 

the towboat population varies from year to year. The WTLUS, which is developed based on 

reports for vessels in waterborne commerce for that year, varies from year to year. For example, 

the WTLUS towboat population reported by the WTLUS varies from 4,954 to 5,314 in the years 
2-2 

from 1999 to 2004. However, the reported population did not steadily increase between those 

years, because it was higher in 2001 (at 5,127 vessels) than in 2002 (at 4,995 vessels). 

Obviously, there are numerous ways for boats to become active or to change to inactive status, the 

largest of which is likely to be the entry into and withdrawal out of active service by vessels as 

economic and industry conditions change. Given this type of population, the project team suggests 

that the Coast Guard consider 5,100 to 5,200 as a reasonable estimate of the active towing vessel 

population. This number may not include all of the towing vessels in service as construction 

support workboats, but based on checking a limited number of known workboats, many of them are 

included in the two databases used here. 

7931

5142 5172

3932

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

MISLE (all vessels) MISLE (active vessels) WTLUS AWO

# of Vessels

Note: The AWO estimate was stated as "active towing vessels operating in the towing industry." It is not 

intended to include towing vessels used in other roles (e.g., marine construction support). The other estimates 

are based on databases of vessels defined as towing vessels, regardless of service. 

Figure 2.1 Estimates of Number of Active Towing Vessels 

The analysis team found that because of the quality of the data and the lack of consistently 

common data fields, it was not practical to make a reliable one-to-one comparison of the vessels in 

the two sources. Also, it appears that each database has some vessels included that are no longer in 

service. Because of this, the project team suggests use of 5,100 vessels as an estimate of the 

number of towing vessels in active commercial service. 
2-3 

Specific observations regarding this project's estimate of 5,100 vessels: 

• The team believes the estimate represents the number of line haul boats on inland rivers, 

vessels operating on the intracoastal waterways and ocean routes, fleeting vessels that 

support towing operations, and harbor assist vessels. It also includes some tugboats that 

provide support to dredging and marine construction operations. 

However, with the current Coast Guard data, it is not possible to identify the number of 

boats in each class of service. The WTLUS divides inland commercial vessels into 

"tugboats" and "towboats/push boats"; however, it provides no additional service 

breakdown. AWO personnel who were consulted suggest that the number of vessels 

currently in the commercial towing industry (including harbor-assist vessels) is about 

4,000, and the AWO Web site shows an estimate of 3,942 (as of 2002). 

• The team believes the estimate of 5,100 vessels includes very few of the vessels providing 

assistance towing services to recreational boaters. 

These vessels are often less than 26 ft in length, are generally modified recreational boats, 

and are typically state registered. Based on discussions with the industry associations and 

major towing assistance franchise organizations (e.g., C-Port, Sea Tow, Boat US) that are 

involved in assistance towing, it appears that there are about 250 to 275 companies that 

provide assistance towing services, with somewhere between 1,200 and 1,400 vessels 

involved. 

• Although there are a number of industry "workboats" (i.e., tugboats or pushboats that 

support marine construction, dredging, and other limited geographic area operations such 

as marine support) included in the 5,100 vessels reported in the Coast Guard MISLE and 

USACE WTLUS databases, it is likely that there may be many more of these vessels that 

are not included. 

These vessels represent a large variety of sizes (and are sometimes less than 26 ft in 

length). Many of them are only operated on an intermittent basis and often operate only 

in a limited geographic area. 

Another important characterization of the industry is the distribution of towing vessels per 

company. Figure 2.2 displays the distribution of the size of towing vessel fleets by company (using 

the "TS Operator" designation from the WTLUS). This presents the 1,198 towing vessel 

companies from the WTLUS Volume 2 data, by size of their fleet. Figure 2.2 shows that there are 

more than 800 of the towing companies that have from 1 to 3 vessels, while only 3 towing 

companies reported ownership of more than 100 vessels. (Of the small towing companies, 474 

companies report operating only one towing vessel.) This presents a challenge for the Coast Guard 

to communicate new requirements to so many small companies, many of which are not members of 

industry organizations like AWO and the Offshore Marine Service Association (OMSA). 
2-4 

There are some issues with the data regarding vessel ownership: 

• In some cases, the WTLUS listed two companies with very similar names (e.g., names 

like "ABCD Marine Company" and "ABCD Marine Co."). If, based on knowledge of the 

industry and internet research, we believed them to be the same company, we combined 

the fleets for purposes of this graphic. In other cases, we chose to use the company 

designations as found in the WTLUS. 

• The WTLUS reports company fleets based on the regional location of the company 

operation (i.e., by USACE Engineer Division/District) where they operate. McAllister 

Towing and Moran Towing are examples of that approach, with each of their fleets 

reported as operated by eight or nine regional subsidiaries. We did not choose to combine 

these designations, so some of the large towing companies appear as a number of smaller 

companies. Once there is a towing vessel inspection regulation, some large companies 

may choose to have different management systems for vessels operated out of different 

offices. That is a decision that will need to be documented in any safety management 

system that is developed in response to the new towing vessel regulations. 

Figure 2.2 Towing Vessel Companies by Fleet Size (Based on WTLUS 2003) 

2.2 PERFORMANCE OF VISITS TO TOWING COMPANIES IN VARIOUS PORTS 

As part of this project, ABS Consulting personnel accompanied Coast Guard representatives on 

trips to several ports to discuss towing vessel inspection issues with various towing companies. 

The information gathered during those visits contributed to other activities in this project and to the 

conclusions and recommendations in this report (see Section 6). 
2-5 

Table 2.1 provides the dates and locations of the trips made, indicating which towing companies 

were visited and the project and Coast Guard staff participants. 

Table 2.1 Towing Company Visits by Project Personnel 

Date Location Towing Companies (Locations) 

Project and Coast Guard 

Participants 

1/10/06 

to 

1/11/06 

Houston • G&H Towing (Galveston) 

• Kirby Inland Marine 

• Higdon Marine 

Casada 

Dolloff 

Elsenburg 

1/23/06 

to 

1/25/06 

Seattle • Crowley Marine 

• Harley Marine 

• Tidewater (Vancouver, WA) 

Casada 

Dolloff 

2/7/06 

to 

2/9/06 

Norfolk • Allied Transportation 

• Moran Towing 

• McAllister Towing 

Casada 

Kuhaneck 

2/21/06 

to 

2/23/06 

Tampa • Seabulk Towing 

• Maritrans, Inc. 

• Dann Ocean Towing 

• Local towing assistance 

franchisee 

Casada 

Dolloff 

3/28/06 

to 

3/30/06 

St. Louis • American River Transportation 

Company 

• Ingram Barge Company 

• JB Marine Service 

• Osage Marine Services 

• National Maintenance and 

Repair (drydock and repair 

facility) 

Casada 

Kuhaneck 

ABS Consulting personnel involved: Myron Casada and Eddie Elsenburg 

Coast Guard personnel involved: David Dolloff and Scott Kuhaneck 

Activities during the towing company visits generally included: 

• Discussions with towing company management and safety personnel, including areas 

such as: 

− Company operations in terms of number of vessels, types of service, locations of 

operations 

− Company experience (if any) with safety management systems 

− Existing company procedures and policies pertinent to towing vessel safety 

− Approaches regarding vessel crew training and management of change 

− Hardware provided on vessels beyond what is required by current regulations 

(e.g., equipment for lifesaving, fire protection, communications, and navigation) 

− Opinions regarding the need for and appropriate focus of towing vessel 

inspection programs 
2-6 

• Discussions with engineering and maintenance personnel regarding: 

− Standards for towboat design and maintenance 

− Qualifications of port captains and inspection/survey personnel 

− Frequency of drydocking and tasks accomplished in drydock 

− Standards used for determining vessel fitness for service 

• Review of established safety management systems, including examination of procedures 

and policies that addressed: 

− Compliance with current Coast Guard and other applicable regulations 

− Compliance with the AWO Responsible Carrier program 

− Requirements established by towing company clients (e.g., major petroleum 

shipping companies) as a contractual condition 

• Visits onboard selected towing vessels to: 

− Examine safety management system documentation and procedures maintained 

by the crew 

− Observe the general condition of the vessel wheelhouse, engine room, and deck 

areas 

− Review the availability of lifesaving equipment 

− Discuss safety programs and needs with vessel crews, including vessel masters, 

pilots, engineers, and other towboat personnel 

During the St. Louis visit, the project team visited fleeting companies and a major drydock/vessel 

maintenance facility, in addition to towboat operating companies. In Tampa, the team also visited 

a company that provides assistance towing throughout a large section of the Gulf Coast of Florida 

as a member of a nationwide towing assistance organization. 

Many of the issues were discussed in the meetings with industry personnel. Not all of these issues 

were raised by every towing company, but the ones listed were either discussed in several meetings 

or were very important to the industry personnel who raised them. Many of these issues have also 

been discussed in meetings with the TSAC and its towing vessel inspection working group. (Note: 

These issues are not presented in any specific order, and simply because they are reported here does 

not mean that ABS Consulting or Coast Guard representatives who attended these meetings agree 

with the points raised.) 

• Potential for Business Impacts of Inspection Activity 

In many cases, the industry representatives expressed concern about the business 

impacts (largely the potential for delays and business interruption) that could be 

imposed by inspection activities. Use of third parties to assist the Coast Guard in 

performing inspection-related activities was considered more flexible than scheduling 

all activities with Coast Guard inspectors. 
2-7 

• Level and Location for Documentation Required for Inspected Status 

There appeared to be a wide range of levels of documentation developed by companies 

to satisfy the Responsible Carrier Program (RCP) and other safety management systems 

(SMSs). While everyone understood that a management system has to be documented, 

there was concern that the level of documentation was driven by auditor preferences, 

rather than the requirements or the "value" of the document for managing safety. Also, 

several companies indicated that they chose to maintain many vessel-related records in 

company offices rather than onboard the towing vessel; therefore, they believed that 

companies should be free to document record storage locations in their SMS. Of course, 

this could require vessel auditors to obtain access to company record locations. 

• Location of Towing Vessel Requirements in Numerous Regulations 

On several occasions, industry representatives expressed frustration with the 

organization of the current regulations that apply to towing vessels. They pointed out 

that the pertinent regulations were widely scattered across many different sections of 

Title 33 and Title 46. This makes it difficult to keep track of what applies to a towing 

vessel and makes training personnel harder. They expressed the hope that the new 

inspection towing vessel regulations could bring those requirements together, or at least 

provide a clearer roadmap to the pertinent regulations. 

• Need to Maintain Some Existing Exemptions 

On several occasions, industry personnel made the point that there are many different 

services provided by towing vessels, and that existing regulations sometimes recognize 

this by providing appropriate exemptions. For example, harbor assist tugs and 

assistance towing vessels are not currently required to meet all of the fire protection 

requirements in 46 CFR Part 27. The industry personnel requested that the new towing 

vessel inspection regulations be carefully drafted so that there are no "unintended 

consequences" of simply reorganizing existing requirements.

• Desire to Take Credit for Oil Company Vetting as Internal or External Audits 

Major oil companies that contract with towing companies to move oil in barges 

generally evaluate potential towing service suppliers, both prior to placing a contract 

and then periodically during the term of the contract. This process, called "vetting" by 

the industry, is considered an important aspect in assuring safety and environmental 

compliance in the oil industry. Several towing industry personnel expressed a desire to 

take credit for oil company vetting examinations as part of their in-house safety 

management audit and review process (e.g., in lieu of a separate internal audit 

performed by towing company personnel). They believed that the vetting process 

provides comprehensive reviews of the same topics an SMS audit would examine. 

However, vetting activities are not generally documented in the same manner that an 

internal or external audit would be and would not likely address issues not related to oil 

movements. 

• Need for Auditors to Have Appropriate Towing Industry Experience 

There has been extensive discussion of using third-party personnel to provide 

independent audits of towing company safety management systems and other regulatory 
2-8 

compliance activities. Coast Guard representatives have indicated that such personnel 

would have to meet specific qualification standards. The feedback from the industry 

personnel was that the auditors would need to have experience appropriate to the 

industry segment they would be auditing. They maintained that safety policies, 

practices, and equipment were different between brownwater (i.e., Western Rivers 

towing) and bluewater (i.e., coastal or ocean) towing operations. Simply because an 

auditor can meet some specified years of towing experience criteria, the opinion was 

that he or she might not have the right experience to provide an appropriate audit, 

depending on the service in which the vessel operates. 

• Lack of Experience of Some Coast Guard Inspectors 

Similarly, industry personnel emphasized the need for Coast Guard inspectors to receive 

training regarding the towing vessel industry and the specifics of any new regulations. 

Industry personnel realize that, because of the breadth of the Coast Guard's 

responsibilities, all Coast Guard inspectors cannot have detailed experience with the 

industry segment they may need to inspect. However, they pointed out the need to 

provide adequate training and resources to Coast Guard inspection personnel so that 

early implementation of the towing vessel inspection regulations will not be dominated 

by the need to appeal inspector actions to the local Coast Guard chain of command. 

Because towing vessels are widely distributed across all of the Coast Guard areas of 

operations, training programs and inspection aids (e.g., CG-840 books, inspection 

guidelines, navigation and vessel inspection circulars) will need to be developed and 

provided to the field early enough to help address this problem. 

• Impact and Difficulty of SMS Development for Small Companies 

Project personnel realize that the companies visited in this project were almost entirely 

AWO members, so they had at least implemented the RCP program, and some of them 

were also ISO or ISM certified. However, the industry personnel were clear that 

effective implementation of a safety management system was a very difficult task for a 

company that had not previously been highly structured and had not formally 

documented its policies and procedures. They pointed out three issues: 

1. It will be difficult for small companies to dedicate the time needed to develop 

and implement an effective SMS, in part because they have a limited number of 

people who are not involved in vessel operations on a day-to-day basis. 

Typically, AWO members have safety managers who have shared the SMS 

development task with port engineers and/or port captains. Small companies 

often do not include any of these positions, making program development 

difficult. 

2. On a relative basis, SMS costs will be high for small companies (i.e., costs-pervessel will be high), and those companies may not be able to afford to hire the 

outside assistance (i.e., consultants) that many larger companies use. 

3. For small companies (e.g., those involving one to three boats) there is less value 

in having a large number of detailed, written procedures and an associated audit 
2-9 

process. With a small number of employees, it is often possible to achieve 

consistent operation with company policies by direct supervision and 

coordination rather than more formal (i.e., written) management systems 

approaches. 

Industry personnel indicated that these issues make it essential that the Coast Guard and 

industry associations examine ways to provide compliance assistance to small 

companies. This assistance could take the form of template programs, training 

assistance, or other outreach activities. Such assistance would serve to help reduce the 

difficulty and cost of compliance, improve the level of compliance, and improve the 

safety performance of smaller towing companies. Another alternative discussed during 

the visits was to allow companies to opt for compliance with a more prescriptive 

regulation rather than develop their own safety management system. 

• Ability to Provide Documentation of Industry Vessel Survey/Inspection for Credit 

During the visits, industry personnel stressed the need for flexibility regarding 

drydocking schedules and for allowing companies to take credit for inspections 

performed by company and drydock facility personnel. Particularly for inland river 

vessels, the industry tends to drydock vessels frequently because of damage to 

propellers or other nonroutine maintenance needs. In some cases, depending on how 

long it has been since overall vessel inspection and repair, other drydock activities (like 

hull survey) might be performed. They expressed the need to be able to document such 

activities and make that documentation available to the Coast Guard inspector or thirdparty auditor as evidence of meeting required drydock inspections. Otherwise, there 

would have to be a separate drydock schedule simply for regulatory inspection 

purposes. In addition to seeing this as an unnecessary expense, they indicated that, at 

least for freshwater service, corrosion was not a significant threat to vessel 

serviceability or a significant contributor to the potential for a vessel loss; therefore, 

they did not believe that drydock surveys are an important risk mitigation measure. 

• Need for Consistency in Regulatory Review and Enforcement 

One issue that was raised by several companies was the need for consistency of 

regulatory review and enforcement by all of the various Coast Guard sectors and 

Captains of the Port (COTP). The companies generally want to develop and implement 

a safety management system on a companywide basis so they have the greatest 

flexibility to move vessels and personnel around. However, if safety management 

system review and vessel inspection activities vary from port to port, it makes 

compliance very difficult. Although any safety management system needs to ensure 

that vessel crews comply with local requirements that reflect real differences in local 

situations, the industry personnel were concerned that differences in opinions and 

interpretations would occur. If those differences result in different requirements for 

safety management systems in different areas, it is a problem. The industry personnel 

suggested that guidance documents and Coast Guard training for any local personnel 

involved in towing vessel inspection activities need to be provided in a timely manner 

(i.e., before the local personnel are expected to take action). 
2-10 

• The Need to Treat Towing Assistance Differently 

Both traditional towing companies contacted and the towing assistance company visited 

during the Tampa visit stressed how different the towing assistance industry, vessels, 

and daily operations are from other towing industry sectors. The masters operating 

towing assistance vessels are generally owners/operators for the vessels involved, 

although they may operate within a franchise system. They provide the waterway 

equivalent of roadside assistance available from an automobile club or tow truck 

company. Towing assistance masters are licensed by the Coast Guard, but very few of 

the other Coast Guard regulations that apply to the towing industry apply to towing 

assistance vessels. The general opinion expressed by the towing assistance and other 

towing industry personnel was that towing assistance vessels should either (1) be 

exempted entirely from the current regulations being developed or (2) be subject to new 

regulations developed specifically for them. It seemed clear to all involved that 

whatever potential industry risks are contributing to the pressure for inspection of 

towing vessels, they are not presented by the towing assistance industry. 
3-1 

3. ANALYSIS OF TOWING INDUSTRY VESSEL CHARACTERISTICS 

The first task in the data analysis was to create an in-depth profile of the towing vessel industry. 

This involved comparing and contrasting the registry of towing vessels in the two primary data 

sources, MISLE and WTLUS. The analysis team identified a number of vessel and operator 

characteristics of interest to help describe the industry. The key characteristics defining the 

industry are: 

• Length over deck (ft) 

• Gross registered tons (GRT) 

• Age 

• Horsepower 

• Waters 

• Service 

• Construction material 

For each of the characteristics, the team created a number of criteria to categorize each vessel. 

Table 3.1 illustrates the categories used for each of the characteristics. 

These characteristics and associated categories provided a number of criteria to subdivide the 

towing vessel industry. The following sections break down the industry based on the two primary 

vessel registries (Coast Guard’s MISLE and USACE’s WTLUS) for each of the characteristics. 

3.1 MISLE VESSEL REGISTRY 

The MISLE database is the Coast Guard enterprisewide repository for vessel and incident data; 

therefore, it was the primary source of data used in this analysis. At the time the towing vessel data 

were downloaded from the MISLE database (September 2005), there were 7,931 vessels registered 

as towing vessels with a status of either “Active” or “Unspecified.” Of these 7,931 vessels, 2,789 

had a status of “Unspecified,” while 5,142 had a status of “Active.” 

Please note that the datafile supplied to the project team by the Coast Guard did not include any 

vessels that the Coast Guard knew to have been scrapped or declared inactive by their owners. 

Those vessels are included in Coast Guard data the team did not use (i.e., vessel status of 

"Inactive") and comprise about 2,500 additional vessels. This industry profile also does not contain 

undocumented vessels or assistance towing vessels. 

Figures 3.1 through 3.6 illustrate the towing vessel profile for each of the characteristics, with the 

exception of “Service,” based on the data from the MISLE database. 
3-2 

Table 3.1 Categories for Vessel Characteristics 

Category Characteristic 1 2 3 4 5 

Length Over Deck (ft) 0 to <25 26 to ≤65 >65 to <79 79+ N/A Gross Registered Tons (GRT) 0 to <5 5 to <50 50 to <100 100 to <200 200 to <Age 0 to 5 6 to 10 11 to 15 16 to 25 >25 Horsepower 

< 100 hp 101 to 500 hp 500 to 1000 hp 

1000 to 5000 

hp 

5000 to 1

hp 

Waters Western 

Rivers 

Inland Great Lakes Lakes, Bays, 

and Sounds 

Coastwis

More Th

Nautical 

from Sh

Intraport 

(local area of 

operation, usually 

within a single harbor 

or port) 

33 CFR 27.101 

Service Intraport Interport Interport Ocean

Limited 

Geographic 

Area 

such as fleet, ship 

assist, harbor assist

Extended 

Limited 

Geographic 

Area 

such as rivers, lakes, 

bays, and sounds 

Rivers, Lakes 

Bays, and 

Sounds 

ICW 

Coastal Non-SO

Construction Hull Steel Wood Aluminum FRP OtheMaterial Superstructure Steel Wood Aluminum FRP OtheNote: The Coast Guard uses gross tons for most of its regulations related to vessels. That is what is reflected in this table. How

Engineers generally reports net tons in its data sets because that number is more pertinent to the cargo carrying capacity of the vessel. 
3-3 

Figure 3.1 Length Over Deck (ft) Categorization (MISLE Data) 

Figure 3.2 Gross Registered Tons (GRT) Categorization (MISLE Data) 
3-4 

Figure 3.3 Age Categorization (MISLE Data) 

Figure 3.4 Horsepower Categorization (MISLE Data) 
3-5 

Figure 3.5 Waters Categorization (MISLE Data) 

Figure 3.6 Construction Material – Hull (MISLE Data) 

Note: Data concerning vessel service and superstructure material are not available within MISLE. 
3-6 

3.1.1 MISLE Vessel Registry Conclusions 

The MISLE vessel registry is the central data repository for the Coast Guard and contains a wide 

breadth of vessel characteristics; however, the quality of the data varies widely, depending on the 

characteristics, with the level of UNKNOWN entries dominating some of the characteristics (e.g., 

waters, horsepower). The industry profile represented by Figures 3.1 through 3.6 also includes 22 

vessels that the MISLE registry identified as inspected under subchapter I. 

3.2 USACE WTLUS VESSEL REGISTRY 

The WTLUS database used for this analysis effort contains summary information of the vessel 

companies and American flag vessels operating or available for operation on August 1, 2004, in the 

transportation of freight. Specifically, this analysis used the WTLUS Vessel Characteristics 

database. The Vessel Characteristics database does not contain the breadth of information on each 

vessel compared to MISLE, but does have many of the characteristics of interest mentioned earlier. 

The available data include: 

• Vessel name 

• Vessel number 

• Coast Guard number 

• Net tonnage (Note: gross tonnage is not available) 

• Length 

• Breadth 

• Horsepower 

The WTLUS registry contains entries for 5,172 towing vessels, and the WTLUS database does not 

distinguish between inspected and uninspected vessels. Figures 3.7 through 3.10 illustrate the 

towing vessel profile for each of the characteristics based on the data from the WTLUS. 

3.2.1 WTLUS Vessel Registry Conclusions 

The WTLUS vessel registry tracks the operation of towing vessels through US waterways and 

records a number of the vessel characteristics of interests. Overall, the quality of the WTLUS data 

is better than the MISLE repository because of the much smaller percentage of unknowns for each 

characteristic. As noted previously, the WTLUS registry does not track gross tonnage (only net 

tonnage), service, waters, or hull construction material; however, it does track the primary 

characteristics of length, age, net tonnage, and horsepower. 
3-7 

Figure 3.7 Length Over Deck (ft) Categorization (WTLUS Data) 

Figure 3.8 Net Tonnage Categorization (WTLUS Data) 
3-8 

Figure 3.9 Age Categorization (WTLUS Data) 

Figure 3.10 Horsepower Categorization (WTLUS Data) 
3-9 

3.3 MISLE TO WTLUS COMPARISON 

There is a significant difference in the number of towing vessels in the MISLE (7,931 vessels) and 

WTLUS (5,172 vessels) data repositories. One reason for this difference is that the WTLUS is 

limited to vessels operating in 2004 while MISLE is a registry for all towing vessels. The MISLE 

data repository contains a vessel status field that indicates whether the vessel is active or not. If the 

MISLE data set (queried in October 2005) is limited to only active vessels, there is better 

agreement between the two data sets. The number of active vessels in each source is very 

consistent: MISLE (5,142 vessels) and WTLUS (5,172 vessels). 

A comparison of the “Active” MISLE data set to the WTLUS data set portrays a relatively 

consistent profile of the towing vessel industry across all of the characteristics of interest. As 

mentioned earlier, the quality of the MISLE data is generally lower than the WTLUS data asset as 

indicated by the higher number of UNKNOWN entries for every characteristic; however, the 

relationships between categories for each of the characteristics yield similar profiles between 

MISLE and WTLUS. 

If the UNKNOWN vessels in the MISLE registry are distributed proportionally, based on the 

known values for each characteristic, the values for each characteristic are comparable. 

Example: 

The MISLE data for the length characteristic are: 

Category # of Vessels % of Total 

1) < 26 ft 6 0.16%

2) >= 26 to 65 ft 1,877 50.12%

3) > 65 to 79 ft 459 12.26%

4) > 79 ft 1,403 37.46%

UNKNOWN 1,397

The 1,397 UNKNOWNs were distributed among the four length categories based on the 

proportion of the length category to the total (e.g., 50.12% of 1,397, or 700 vessels, were 

added to category 2). 

Figures 3.11 through 3.14 illustrate the industry profiles for the characteristics for three data sets: 

(1) active MISLE vessels, (2) WTLUS vessels, and (3) active MISLE vessels with UNKNOWN 

values distributed based on known values. Each bar represents the count of vessels in each 

characteristic category. 

As mentioned earlier, the WTLUS reports indicate that the WTLUS data set is a registry of towing 

vessels operating or available for operation in the transportation of freight. However, lists of 

individual ship assist vessels obtained during port visits show that many of the ship assist vessels 

are in the WTLUS vessel registry. The WTLUS does not track the smaller, assistance towing 

vessels. 
3-10 

Figure 3.11 Length Over Deck (ft) Categorization (“Active” MISLE Vessels vs. WTLUS 

Vessels vs. “Active” MISLE with Distributed Unknowns) 

Figure 3.12 Net Tonnage Categorization (“Active” MISLE Vessels vs. WTLUS Vessels vs. 

“Active” MISLE with Distributed Unknowns) 
3-11 

Figure 3.13 Age Categorization (“Active” MISLE Vessels vs. WTLUS Vessels vs. “Active” 

MISLE with Distributed Unknowns) 

Figure 3.14 Horsepower Categorization (“Active” MISLE Vessels vs. WTLUS Vessels vs. 

“Active” MISLE with Distributed Unknowns) 

Note: Data concerning waters and hull material are not available in the WTLUS data set. 
3-12 

Similarly, because the Coast Guard does not require towing vessels < 5 net tons to be documented, 

the MISLE data set does not include many of the assistance towing vessels or other small towing 

vessels. 

The goal of the in-depth analysis of the uninspected towing vessel industry is twofold: 

• Provide an estimate of the number of vessels and companies that would be affected by an 

inspection regime that applied to towing vessels of various sizes and service 

• Understand the level of incident exposure to the MTS offered by the UTV industry 

3.4 INDUSTRY TRENDING ANALYSIS 

The MISLE and WTLUS vessel registries represent the UTV industry at a snapshot in time, 2005 

and 2004, respectively. To understand how the industry has changed over time, the analysis team 

requested a snapshot of the MISLE registry for each year (1997 through 2004). Figures 3.15 

through 3.18 represent the trending analysis for the four primary vessel characteristics: length, 

gross tonnage, age, and horsepower. 

3.4.1 Trending Analysis Conclusions 

Few conclusions can be drawn from the trending analysis. Generally, the analysis points to relative 

proportional growth through the years for each of the characteristics. The conclusion of overall 

growth may be skewed due to the common practice of creating duplicate records in the MISLE 

database when vessels are involved in reportable incidents. Ferreting out duplicate records is an 

arduous process, beyond the scope of this effort. The primary conclusion from this analysis is that 

the towing vessel industry is a relatively stable and aging industry. 
3-13 

Note: The high number of UNKNOWN lengths in 2002 is assumed to be attributable to the switchover of Coast Guard data systems 

from MSIS to MISLE. The data anomaly was corrected and the overall quality improved over MSIS in subsequent years. 

Figure 3.15 Length Over Deck (ft) Trending Analysis (1997 – 2004). 

Figure 3.16 Gross Tonnage Trending Analysis (1997 – 2004) 
3-14 

Note: The high number of UNKNOWN ages in 2002 is attributable to the switchover of Coast Guard data systems from MSIS to 

MISLE. The data anomaly was corrected in subsequent years.

Figure 3.17 Age Trending Analysis (1997 – 2004) 

Figure 3.18 Horsepower Trending Analysis (1997 – 2004) 
4-1 

4. TOWING VESSEL ACCIDENT HISTORY AND RISK EVALUATION 

4.1 PREVIOUS EXAMINATIONS OF TOWING VESSEL ACCIDENT HISTORY 

There have been several studies of accidents and accident rates for the towing industry. This 

section presents two of them to allow comparisons to what was found during this project. 

The specific studies described here are: 

• The TSAC Towing Vessel Inspection Working Group report (TSAC, 2005) 

• A report by the Coast Guard – AWO Bridge Allision Working Group (BAWG, 2003) 

4.1.1 Report of the TSAC Working Group on Towing Vessel Inspection 

As part of TSAC’s Working Group on Towing Vessel Inspection activities, the working group 

formed a Risk-Based Decision-Making Subgroup to consider the casualty data and other evidence 

that should be reviewed to ensure that the working group’s recommendations considered appropriate 

risk information (TSAC, 2005). The subgroup used Coast Guard casualty data for the period 1994 to 

2003 as the basis for its work and provided reports to the working group on its findings and 

analyses throughout the working group’s deliberations. A summary report of the subgroup’s work 

is attached as Appendix C of the TSAC Working Group report. Among the subgroup’s key findings 

(taken from the TSAC report) were: 

• 89% of towing vessel casualties examined were low-severity events, 7% were 

medium-severity events, and 5% were high-severity events. Note: The TSAC 

Working Group used the Coast Guard’s 6 level vessel casualty damage classes (Class 

0 to 5) and divided the classes into 3 severity levels. 

• Approximately 13% of towing vessel casualties were caused by external factors; that 

is, events, actions, or decisions that arise from outside the towing vessel. The 

subgroup did suggest that safety management systems could help mitigate the impact 

of those casualties. 

• Equipment failures accounted for 33% of the medium- and high-severity incidents and 

about 45% of the low-severity incidents. (Note: The subgroup defined a low-severity 

incident as involving no personnel injuries or fatalities, pollution [if any] of 10 gallons 

or less, and dollar damages [if any] of $50,000 or less.) 

• A detailed analysis of the medium- and high-severity equipment failure incidents 

showed the systems that had failures were, in descending order of frequency: 

− Propulsion 

− Cables and lines 

− Electrical 

− Hull 
4-2 

− Fuel 

− Steering 

− Deck machinery 

− Navigation 

− Cargo handling equipment 

The leading preventive measure, where one could be identified, was maintenance 

standards, which the subgroup concluded could have played a role in preventing 43% of 

the medium- and high-severity incidents. The following vessel systems play a role in 

casualty mitigation: 

− Firefighting 

− Crew safety equipment such as chains and handrails 

− Pollution prevention 

• A technical analysis of the vessel systems involved in towing vessel equipment failures 

concluded that a comprehensive inspection regime for towing vessels should include 

these components: 

− The vessel owner/operator’s safety management system 

− Visual examinations of the vessel on dry dock 

− Operational tests 

− Other visual examinations 

− Regular external audits of the safety management system 

− Regulatory or manufacturer’s equipment standards 

• Human factors accounted for 54% of the medium- and high-severity incidents and about 

40% of the low-severity incidents. Of the medium and high-severity human factor 

incidents, 69% were related to failures in situational awareness or task performance. The 

leading preventive measures, where they could be identified, were planning in 25% of the 

cases and training in 36% of the cases. Planning and training are both important elements 

of a safety management system. 

Section 4.3.5 of this report compares the TSAC WG results to those found in this project’s review 

of a set of towing vessel accidents examined for causal factor information. 

4.1.2 Coast Guard – AWO Bridge Allision Working Group Causal Factor Results 

In 2003, the Coast Guard and AWO reported on their joint Bridge Allision Working Group 

activities (BAWG, 2003). The working group examined 459 bridge allisions in detail in order to 

investigate the causal factors behind the bridge allisions. These included 160 higher-severity 

allisions that had occurred, plus a random subset of all allisions for the years 1992 to 2001 (for a 

total of 459 events). 
4-3 

The BAWG report indicates that the casualty reports posed a significant challenge to the work 

group. Coast Guard standards for gathering casualty facts and information, especially human 

factors information, were incompatible with the intent of the work group to conduct a detailed 

analysis. In many cases, the detail necessary to determine precisely the causal factors of an allision 

was not available. Work group members were therefore forced to rely on their own operational 

experience, judgment, and knowledge of a particular waterway in interpreting the limited 

information in the Coast Guard casualty reports and classifying allisions by mishap type and 

causal factor. 

With this admittedly significant caveat, the work group concluded that: 

− 90% of the cases were related to human performance (78% to pilot error and 12% to other 

operational errors) 

− Only 5% were related to mechanical problems 

− For the remaining 5% there was insufficient information to assign a cause 

The work group’s analysis of the performance-based cases showed that the predominant causal 

factor in bridge allisions was decision-making error on the part of the towing vessel operator, 

which surfaced as a causal factor in 68% of the 435 sampled cases in which a mishap category 

could be identified. Significantly, this pattern was the same for cases across the range of severity 

classes, meaning that both high- and low-consequence cases exhibited the same causal factors. 

The BAWG went on to make specific recommendations regarding the prevention of bridge 

allisions; however, they are not directly applicable to towing vessel risks in general, so they are not 

repeated here. 

Section 4.3.5 of this report also compares these results to those found in the UTV industry analysis 

project’s review of a set of towing vessel accidents examined for causal factor information. 

4.2 UTV INDUSTRY ANALYSIS PROJECT RISK EVALUATION 

While risk is a commonly used term (especially within the Coast Guard), it is not always well 

understood. Figure 4.1 describes the key elements of risk understanding. 

Risk requires us to understand (1) what can go wrong, (2) how likely (frequent) it is, and (3) what 

are the impacts (consequences). By considering all three elements together, risk is a measure of 

expected loss over a period of time. Risk can be used to assess many different types of issues, with 

the approach varying, depending on the type of issue and the information available. For issues with 

limited historical information (like very severe accidents), the assessment process has to make use 

of the knowledge and experience of subject matter experts. 

For issues that have a long history and ample data, such as UTVs, the risk elements are best 

described by an evaluation of the historical incident data supplemented with the expertise of 

industry experts. The approach of the UTV data analysis team was to use the available incident 

data from a risk perspective to best describe the current risk environment for UTVs. 
4-4 

Figure 4.1 Basic Elements of Risk Measures 

4.3 UTV HISTORICAL RISK PROFILE 

The UTV data analysis team executed a number of tasks to translate the MISLE historical incident 

record into a historical risk profile. The following sections will detail the steps in the process, the 

results, supporting assumptions, and gaps. Throughout the process, the team worked closely with 

the Coast Guard’s HQ G-PCA staff to execute queries from MISLE to provide the foundational 

elements for the data analysis. 

4.3.1 Step 1 – Gather Incidents Involving UTVs 

The first step in the process was to gather a record of incidents involving towing vessels. The UTV 

analysis team requested a query of the MISLE database for all incidents involving or potentially 

involving towing vessels. Because towing vessels are often associated with barges, incident reports 

where a towing vessel was involved can report either the towing vessel or the barge as the vessel 

involved. G-PCA personnel queried the MISLE database for all incidents involving towing vessels 

or barges for the years of 1994 through 2003. They subsequently ran the same query for 2004, and 

the project team appended the data to the initial data set. There were a total of 19,039 towing 

vessel or barge incidents investigated by the Coast Guard over the 11-year period. 

Because of the reporting issue described above, many of these incidents were barge-only incidents 

(e.g., barge breakaways and subsequent allisions). Based on a sampling analysis of the data, about 

90% of the incidents in the database involved towing vessels. 
4-5 

The UTV risk analysis is divided into two distinct portions: vessel casualty incidents, and 

nonvessel casualty incidents. For instance, if a UTV crew member was injured due to slipping and 

falling when an allision with a dock occurred, the incident would be a vessel casualty incident; 

however, if a UTV crew member was injured due to slipping and falling during normal operation 

of the towing vessel, the incident would be classified as a nonvessel casualty incident. 

4.3.2 Step 2 – Apply Consequence Matrix to Vessel Casualty Incidents 

To enable systematic comparison of the impacts of incidents, the team applied a standard Coast 

Guard approach used in numerous risk studies, in the form of a consequence equivalency matrix, to 

determine the level of cumulative consequence, across impacts on (1) people, (2) property, and (3) 

the environment, for each incident in the data set. This matrix (see Table 4.1) equates levels of 

impact across different consequence types, using a unit called the risk index number (RIN). 

Each category of consequence has a different level of RIN (e.g., minor is 0.15 RIN while major is 

1650 RIN); however, across impact types, each category has the same value (e.g., the substantial 

category for impacts on people category is the same RIN level as the substantial category for 

environmental). 

Table 4.1 Consequence Matrix 

CONSEQUENCE CATEGORY 

Impact Types Minimal 

(0 RIN) 

Minor 

(0.155 RIN) 

Moderate 

(1.65 RIN) 

Substantial 

(16.5 RIN) 

Severe 

(165 RIN) 

Major 

(1650 RIN) 

Catastrophic 

(16,500 RIN) 

Impact on 

People 

Injuries that 

are 

not lifethreatening 

1 lifethreatening 

injury 

and no deaths 

>1 lifethreatening 

injury and no 

deaths 

1 to 9 deaths/ 

serious injuries

10 to 99 deaths/ 

serious injuries

100 to 999 

deaths/serious 

injuries 

> 1,000 deaths/ 

serious injuries

Property 

Damage/ 

Economic Loss 

<$10,000 in 

damage/loss 

$10,000 to 

$299,999 in 

damage/loss 

$300,000 to 

$2.9 million in 

damage/loss 

$3 million to 

$29 million in 

damage/loss 

$30 million to 

$299 million in 

damage/loss 

$300 million to 

$3 billion in 

damage/loss 

> $3 billion in 

damage/loss 

Environmental 

Impact 

<1.5 bbls 

of oil/ 

HAZMAT 

spilled 

1.5 bbls < 15 

bbls of oil/ 

HAZMAT 

spilled 

15 bbls < 150 

bbls of oil/ 

HAZMAT 

spilled 

150 bbls < 1,500 

bbls 

of oil/ 

HAZMAT 

spilled 

1,500 bbls < 

15,000 bbls 

of oil/HAZMAT 

spilled 

15,000 bbls < 

150,000 bbls of 

oil/HAZMAT 

spilled 

>150,000 bbls 

of oil/HAZMAT 

spilled 

The data analysis team applied this consequence matrix to the MISLE incident repository to 

categorize the impacts for each incident. Tables 4.2 through 4.4 illustrate the counts of incidents in 

each severity category for each impact type. 
4-6 

Table 4.2 Number of Vessel Casualty Incidents per Severity Category for Impacts on People 

Year Minor Moderate Substantial Severe Major Catastrophic

1994 21 4 8

1995 986

1996 17 1 5

1997 13 3 5

1998 787

1999 14 5 10

2000 14 3 4

2001 17 4 5

2002 22 7 7 1

2003 14 3 3

2004 23 7 6

Total 171 53 66 1 0 0

Table 4.3 Number of Vessel Casualty Incidents per Severity Category for Economic Impacts 

Year Minor Moderate Substantial Severe Major Catastrophic

1994 323 32 1

1995 298 24 3

1996 287 22 6

1997 323 28 1

1998 259 27 1

1999 292 15

2000 293 21 2

2001 305 26 2

2002 315 32 2 1

2003 277 30

2004 383 33 3

Total 3355 290 20 2 0 0

Table 4.4 Number of Vessel Casualty Incidents per Severity Category for Impacts on the 

Environment 

Year Minor Moderate Substantial Severe Major Catastrophic

1994 13 11 2 1

1995 9541

1996 8 12 5 1 1

1997 10 3 2 1

1998 11 4 1

1999 483

2000 631

2001 8231

2002 3 3

2003 4532

2004 11 10 3 1

Total 87 66 27 6 3 0
4-7 

Total Consequence 

One incident can have different levels for each type of impact. To calculate the level of impact for 

each incident in the historical record, the team used the equivalencies implicit in the consequence 

matrix listed in Table 4.1. The equivalencies relate impacts on people and the environment to 

dollar values. The equivalencies used are: 

• One death = $3 million 

• One barrel of oil/HAZMAT = $20,000 

With these equivalencies, the total consequences of an incident could be calculated across the three 

impact types. For example, a towing vessel collides with another commercial vessel, resulting in: 

• One death – Substantial Category (3 RIN) 

• $1 million property damage – Moderate (1 RIN) 

• Spill of 10 barrels of diesel – Minor (0.2 RIN) 

The total impact of the incident is 4.2 RIN (3 + 1 + 0.2). The team applied this approach to 

determine the total consequence for each of the incidents in the record. Table 4.5 illustrates the 

count of incidents within a range of RIN points for each year (1994 through 2004). 

Table 4.5 Count of Incidents by Year and RIN Range 

Counts of Incidents by RIN Range 

Year 

0 RIN 

>0 to 100 

RIN 100 to 1000 RIN 1000 to 2000 RIN Total 

1994 1049 407 1 1457 

1995 1535 359 1894 

1996 1690 344 1 2035 

1997 1476 381 1 1858 

1998 1643 320 1963 

1999 1455 345 1800 

2000 1338 340 1678 

2001 1367 370 1737 

2002 1361 383 1 1745 

2003 1072 327 1 1400 

2004 994 478 1472 

Total 14980 4054 4 1 19039 

4.3.3 Step 3 – Identify Vessels Involved in Incidents 

In addition to the characteristics of the incidents themselves, the team was interested in the 

characteristics of the UTVs involved in incidents. To determine the relationships between vessel 

characteristics and incidents, the team requested PCA to query the MISLE database for a listing of 

UTVs involved in incidents. This query yielded a count of 19,402 UTVs involved in incidents. 

Figure 4.2 represents the count of UTVs associated to incidents for each year 1994 through 2003. 
4-8 

Note: Reporting policy guidance issued in 1995 increased the number of minor incidents reported; however,guidance 

was revised in 1999, which reduced the reporting and/or investigation of minor incidents. 

Figure 4.2 Number of Vessel Casualty Incidents Related to Towing Vessels per Year 

(1994 – 2003)

4.3.4 Step 4 – Generate Historical Risk Profile for Vessel Characteristics 

This section presents the historical risk profile for each of the primary vessel characteristics: length, 

tonnage, age, and horsepower. As discussed in Section 4.2, risk is a measure of expected loss over 

time. The application of the impact equivalencies to the historical incident data to generate a total 

consequence in terms of RIN (step 2) is a measure of historical loss. To determine the risk, this 

consequence must be divided by a time period to get an expression representing historical loss over 

time. 

A couple of options for the time denominator are available. The analysis team could have used 

calendar years as a denominator in the risk equation; however, since the UTV industry was 

analyzed in detail, the team chose to use exposure years (i.e., total operating years for the pertinent 

class of vessel) as the denominator. The ideal denominator would be the exact number of hours 

each vessel operated; however, these data are unavailable. The exposure year approach is the best 

approximation using available information. 

As described in earlier sections, there is a unique distribution among the categories for each 

characteristic. To determine exposure years for each characteristic and category, the analysis team 

used the WTLUS vessel registry and calculated the years of exposure over the 10 years of the 

incident data (1994 through 2003) for each vessel. This approach assumed that the vessel was in 

full-time operation over the years of the time period for which the vessel was reported in the 

MISLE registry. 
4-9 

Example: 

“Tugboat A” has the following characteristics: 

• Built in 1963 

• 75’ long 

• 250 tons 

• 6,000 horsepower 

• UNKNOWN operation 

• UNKNOWN service 

Based on those characteristics, 10 years of exposure (since the vessel was in 

operation all 10 years of interest) were added to the following categories for 

“Tugboat A”: 

• Age Category 5: >25 years old 

• Length Category 3: 65 to 79’ 

• Tonnage Category 5: 200 to 300 tons 

• Horsepower Category 5: 5,000 to 10,000 horsepower 

With this, the team calculated an exposure-year denominator for each characteristic category. 

Then, the total consequence for the characteristic category was divided by the corresponding 

exposure year to determine the risk (RIN/exposure year) for the characteristic category. Figures 4.3 

through 4.6 present the historical risk profiles for each of the primary characteristics. The relative 

size of the bars in each graph represent the level of risk per exposure year for each category of 

vessel. 

Figure 4.3 Risk by Age Categories (RIN/Exposure Year) 
4-10 

Figure 4.4 Risk by Horsepower Categories (RIN/Exposure Year)

Note: Since small vessels (i.e., less than 5 net tons) are not required to register with the Coast Guard, they are often 

only entered into the MISLE vessel registry when involved in an incident, resulting in an underreporting of exposure 

years for smaller vessels and a skewed risk profile. The <26 ft vessel category was removed from the risk profile for 

this reason. 

Figure 4.5 Risk by Length Categories (RIN/Exposure Year)
4-11 

Note: Since smaller vessels are not required to register with the Coast Guard, they are often only entered into the 

MISILE registry when involved in an incident, resulting in an underreporting of exposure years for smaller vessels and 

a skewed risk profile. The <5 ton vessel category was removed from the risk profile for this reason. 

Figure 4.6 Risk by Net Tonnage Categories (RIN/Exposure Year) 

Historical Vessel Casualty Risk Profile Conclusions 

By reviewing the historical risk profile for each characteristic, a number of conclusions can be 

drawn. As mentioned in the UTV industry analysis section, smaller towing vessels are 

underrepresented in the vessel registries (both MISLE and WTLUS); therefore, the risk presented 

by smaller vessels (e.g., < 5 ton, < 26’) is overestimated because the denominator (exposure years) 

is too small. Towing vessels less than 5 tons are not required to be documented; therefore, they are 

often only recorded in the MISLE registry when they are involved in an incident. 

If the smaller vessels are ignored, the dominant risks lie with the largest and most powerful vessels 

(based on horsepower and length). This is intuitive because these vessels inherently have the 

greatest consequence potential because they move larger loads. This represents more potential to 

damage other vessels or infrastructure in collision/allison events and the potential for larger spills 

of cargo. 
4-12 

4.3.5 Step 5 – Causal Factor Analysis for High Consequence and Sampled Low Consequence 

Vessel Casualty Incidents 

The previous sections have described the steps taken by the analysis team to answer the historical 

who, what, and when questions for incidents involving towing vessels. This section will explore 

why these incidents are occurring. As mentioned earlier, over 19,000 vessel casualty incidents 

involving towing vessels and/or barges occurred between the years of 1994 and 2004. 

In this step, the project team restricted the analysis to reported loss events where the consequence 

(i.e., safety, economic, or environmental impact) occurred in an event that was initiated by a vessel 

casualty (e.g., a collision, allision, grounding). Therefore all of the results in Step 5 are only 

related to vessel casualties. However, in many cases safety consequences can result from events 

that do not involve a vessel casualty. For that reason, in Step 6, the project team went on to 

examine safety impacts for events that did not in a vessel casualty. 

The team did not have time to perform a detailed review of the causes of each of these incidents. 

Instead, the team reviewed the reports and case files (MISLE and NTSB, when available) for the 

highest consequence incidents (i.e., incidents with >3 RIN). In Step 2 the team had identified what 

were the highest consequence incidents that happened between 1994 and 2004, and the team 

reviewed case files for the 132 highest consequence incidents. The purpose of this review was to 

identify the primary causal factors for these high consequence incidents. In addition to the high 

consequence incidents, the team sampled 150 lower consequence incidents and performed the same 

causal factor analysis to see if the factors contributing to the lower consequence incidents were 

similar. 

In addition to determining the causal factors associated with the incidents, review of the individual 

case files offered an opportunity for the team to identify some of the vessel characteristics that were 

often unspecified in the MISLE and/or WTLUS vessel registries. Specifically, the team identified 

the vessel’s service and where it was operating at the time of the incident. 

 

The team used the following categorization approach to capture information about the incident and 

the vessel involved in the incident. Primary causal factors were divided into four main categories. 

For each main category, there were a number of subfactors (see Table 4.6). 

The team also categorized the vessel’s service (Table 4.7) and where it was operating at the time of 

the incident (Table 4.8). 
4-13 

Table 4.6 Causal Factors/Subfactor Categories 

Human Factors 

Situational Awareness 

Voyage Planning 

Helmsman Error 

Construction Accidents 

Loss of Stability/Overload 

Ballast Control Failure 

Other – Describe 

Equipment Failure 

Cables and Lines 

Generator 

Hull 

Navigation Equipment 

Propulsion 

Pumps 

Steering 

Communication 

Other – Describe 

Personnel Injury 

Medical 

Overboard 

Impact Injury 

Strain 

Other – Describe 

Other 

Table 4.7 Vessel Service Categories 

Vessel Service 

Assistance Towing 

Barge Fleeting 

Coastal Towing 

Other – Describe 

River Towing 

Ship Assist 

Unknown 

Work Site 

Table 4.8 Vessel Operation Categories 

Vessel Operation 

Coastwise NMT 20 NM fm shore 

Foreign 

Great Lakes 

Lakes, Bays, and Sounds 

Oceans 

Other – Describe 

Other River 

Western Rivers 
4-14 

As discussed earlier in Section 4.1, some of incidents in the incident repository involve barge-only 

incidents; however, these cannot be separated from incidents involving barges and towing vessels 

without a review of the case file. During the causal factor analysis, the team flagged all of the 

incidents that did not involve towing vessels. Similarly, some incidents were clearly not the fault 

of the towing vessel. The team also flagged all of the incidents where other parties were at fault for 

the incident. 

Figure 4.7 plots the distribution of the 132 high consequence incidents geographically on a map of 

the United States. The color, ranging from yellow to dark orange, and size of the dots correspond 

to the level of consequence (RIN) associated with the incident. 
4-15 

Figure 4.7 Geographic Distribution of High Consequence Incidents
4-16 

Figures 4.8 through 4.16 illustrate the percentage of the 132 high consequence vessel casualty 

incidents and the sample of 150 low consequence vessel casualty incidents that were caused by 

different factors and subfactors. These results are consistent with those of previous reviews by the 

TSAC Towing Vessel Inspection Working Group (discussed in Section 4.1.1) and the Bridge 

Allision Working Group. 

High Consequence Incidents Low Consequence Incidents

Figure 4.8 Percent of Incidents by Causal Factors 

High Consequence Incidents Low Consequence Incidents

Figure 4.9 Percent of Human Factor Incidents by Subfactors 
4-17 

High Consequence Incidents Low Consequence Incidents

Figure 4.10 Percent of Equipment Failure Incidents by Subfactors 

High Consequence Incidents Low Consequence Incidents

Figure 4.11 Percent of Incidents by Operation 
4-18 

High Consequence Incidents Low Consequence Incidents

Figure 4.12 Percent of Incidents by Service 

High Consequence Incidents Low Consequence Incidents

Figure 4.13 Percent of Human Factor Incidents by Operation 

 
4-19 

High Consequence Incidents Low Consequence Incidents

Figure 4.14 Percent of Equipment Failure Incidents by Operation 

High Consequence Incidents Low Consequence Incidents

Figure 4.15 Percent of Human Factor Incidents by Service 
4-20 

High Consequence Incidents Low Consequence Incidents

Figure 4.16 Percent of Equipment Failure Incidents by Service 

Causal Factor Analysis Conclusions for Vessel Casualty Incidents 

Based on review of the incident case files, human factors are the cause of incidents the majority of 

the time (58 to 63%), with lack of situational awareness and helmsman errors making up the 

dominant subfactors in this group. However, equipment failures should not be ignored because 

they cause 26 to 40% of the events. 

These results, along with those from previous studies (discussed in Sections 4.1.1 and 4.1.2), point 

out the importance of activities that help reduce human factors-related incidents, such as: 

• Effective safety policies and procedures 

• Crew training 

• Voyage planning 

• Adequate rest periods and consideration of crew endurance issues 

These are just a few of the types of activities that need to be addressed in a towing vessel safety 

management system. Although adequate, properly maintained hardware is a necessary condition 

for safe operation, equipment improvements alone cannot address what has consistently been 

demonstrated as the key to significant improvements in the towing industry. A focus on “human 

factors” is necessary to help prevent these types of incidents. Human factors does not mean more 

pressure on and enforcement action related to crew members. It means taking the steps to ensure 

that the Coast Guard, the industry, and individual employers contribute to providing an 

environment aboard towing vessels that helps reduce the likelihood of errors. 

For the high consequence incidents, the equipment failure subfactors are spread over many 

systems, with hull failures and cables/line failure providing the most significant percentages. For 

the low consequence incidents, propulsion system failure is the dominant subfactor, resulting in a 

high percentage of minor collisions/allision incidents. 
4-21 

4.3.6 Step 6 – Generate Historical Risk Profile for Nonvessel Casualties by Vessel 

Characteristic 

The goal of this section is to generate the historical risk profile for those incidents not involving 

vessel casualties to gain additional understanding of the frequency with which injuries and fatalities 

have occurred in the towing vessel industry. Figure 4.17 illustrates the number of injuries and 

fatalities that occurred from 1994 to 2004 in the towing vessel industry that were not related to 

vessel casualties (e.g., collisions, groundings) 

Note: Incident reporting guidance in 1995 decreased the number of minor injury reports. 

Figure 4.17 Injury vs. Fatality Trending Analysis (1994 – 2004) 

The causes of nonvessel casualty injuries and fatalities are varied, and the next section documents 

the causes of these incidents. The MISLE incident repository separates the causes into three main 

categories (contact, noncontact, overexertion) with each having a number of subcategories. The 

following figures (Figures 4.18 through 4.24) will identify each cause and the percentage of 

injuries/fatalities caused by it. 
4-22 

Figure 4.18 Fatalities by Accident Category (90 Fatalities) (1994 – 2004) 

Figure 4.19 Injuries by Accident Category (2,534 Injuries) (1994 – 2004) 

Figure 4.20 Contact Fatalities by Accident Type (80 Fatalities) (1994 – 2004) 
4-23 

Figure 4.21 Contact Injuries by Accident Type (1,935 Injuries) (1994 – 2004) 

Figure 4.22 Noncontact Fatalities by Accident Type (8 Fatalities) (1994 – 2004)

Figure 4.23 Noncontact Injuries by Accident Type (69 Injuries) (1994 – 2004) 
4-24 

Figure 4.24 Overexertion Injuries by Accident Type (481 Injuries) (1994 – 2004) 

The effects of injuries can vary widely from minor cuts/bruises to life-threatening wounds. Until 

recently, MISLE investigators were not required to capture the severity of injuries. Since 2005, 

investigators have begun to consistently categorize injury severity within the MISLE data 

repository. Table 4.9 shows the severity categories used in the MISLE incident data repository. 

Based on this characterization, Table 4.9 presents the counts of nonvessel casualty injuries by 

accident type and severity category from July 2005 to June 2006. 

Table 4.9 Injury Severity Counts (July 2005 to June 2006) 

Accident Type Minor Moderate Serious Severe Total 

Contact Injury – Fall onto Surface 12 15 6 1 34

Contact Injury – Line Handling/Caught in Lines 2 6 5 2 15

Contact Injury – Struck by Moving Object 3 5 4 12

Contact Injury – Crushed Between Objects 1 6 2 1 10

Contact Injury – Other 2 4 6

Contact Injury – Collision with Fixed Object 1 4 5

Contact Injury – Fall into Water 1 1

Overexertion Injury – Strain or Sprain 7 12 1 20

Noncontact Injury – Other 3 2 5

Noncontact Injury – Burn 1 1

Unknown Injury Type 2 3 5

Other Injury Type 1 1 2

Total 35 58 18 5 116

Note: Injury severities were not actively tracked until July 

4.3.7 Step 7 – Generate Historical Risk Profile for Nonvessel Casualties by Vessel 

Characteristic 

Section 4.3.4 characterized the historical risk profiles for vessel casualty incidents based on four 

primary vessel characteristics: age, horsepower, net tonnage, and length. The same approach of 

characterizing risk using consequence in terms of RIN and vessel exposure years was taken to view 
4-25 

the risk from nonvessel casualties. Because these incidents only concerned people, not property or 

the environment, the “Impact on People” (see consequence matrix, Table 4.1) impact category was 

the only type of impact considered. 

As noted in Table 4.1, the consequence matrix does not give any weight (0 RIN) to minor injuries. 

Only injuries classified as life-threatening are given any RIN weight. Since the vast majority of the 

incidents occurring over the selected period (1994 to 2004) do not characterize the severity of the 

incident, the analysis team was forced to estimate the percentage of towing vessel injuries that were 

life-threatening. To determine a percentage, the team used the recent injury severity data (July 

2005 to June 2006) ratio as a reasonable estimate. Roughly 20% of injuries occurring over that 

period were categorized as “Serious” or “Severe.” Using the 20% estimate, each injury was given 

a RIN weight of 0.6 RIN. This was calculated using the following equation: 

3.0 RIN * 20% + 0 RIN * 80% = 0.6 RIN 

The analysis team requested a query from G-PCA, which associated the incident information with 

the characteristics of the towing vessel involved. This enabled the analysis team to calculate a total 

RIN value for each of the vessel characteristics/categories. Since the data’s time period is the same 

as the vessel casualty data, the same vessel characteristic exposure years were used as the 

denominator to calculate the historical risk profile for each vessel characteristic. Figures 4.25 

through 4.28 illustrate the nonvessel casualty historical risk profile. 

Figure 4.25 Nonvessel Casualty Risk by Age Categories (RIN/Exposure Year) (1994 – 2004)
4-26 

Figure 4.26 Nonvessel Casualty Risk by Horsepower Categories (RIN/Exposure Year) 

(1994 – 2004)

Note: Since smaller vessels are not required to register with the Coast Guard, they are often only entered when 

involved in an incident, resulting in an underreporting of exposure years for smaller vessels and a skewed risk profile. 

The <26’ vessel category was removed from the risk profile for this reason. 

Figure 4.27 Nonvessel Casualty Risk by Length Categories (RIN/Exposure Year) 

(1994 – 2004) 
4-27 

Note: Since smaller vessels are not required to register with the Coast Guard, they are often only entered when 

involved in an incident, resulting in an underreporting of exposure years for smaller vessels and a skewed risk profile. 

The <5 ton vessel category was removed from the risk profile for this reason. 

Figure 4.28 Nonvessel Casualty Risk by Net Tonnage Categories (RIN/Exposure Year) 

(1994 – 2004)

Historical Nonvessel Casualty Risk Profile Conclusions 

As with the vessel casualty risk profile, the larger vessels present a greater risk per exposure year. 

This is due to their generally larger crews, which represent more working hours per vessel when 

compared to the smaller vessels. 

Upon review of the historical risk profile for each characteristic, a number of conclusions can be 

drawn. As mentioned in the UTV industry analysis section, smaller towing vessels are 

underrepresented in the vessel registries (both MISLE and WTLUS); therefore, the risk presented 

by smaller vessels (e.g., < 5 ton, < 26’) is overestimated because the denominator (exposure years) 

is too small. Towing vessels less than 5 tons are not required to be documented; therefore, they are 

often only recorded in the MISLE registry when they are involved in an incident. 
4-28 
5-1 

5. ANALYSIS OF ECONOMIC IMPACTS OF TOWING VESSEL 

INSPECTION 

As part of this project, the Coast Guard requested that the project team develop economic inputs 

to help it assess the economic impact that potential regulatory requirements might cause. 

However, the Coast Guard did not release a set of proposed regulatory alternatives, so the team 

was unable to provide a specific regulatory impact analysis. 

In the absence of specific proposed regulatory requirements, the Coast Guard, ABS Consulting, 

and Abt Associates developed burden categories (i.e., areas of potential future economic costs 

associated with an inspection regime for UTVs) by reviewing the recommendations of the 

Report of the Working Group (RWG) on Towing Vessel Inspection of the Towing Safety 

Advisory Committee (TSAC). 

The burden categories the team developed are based on those recommended in the TSAC RWG, 

and they consider potential onboard vessel equipment standards, drydocking requirements, and 

safety management requirements that are not already required by law. As a result, the 

assessment provides data that can be used to estimate the potential compliance costs that may be 

incurred by individual UTVs as a result of rulemaking. 

The report from Abt Associates is presented as Appendix A to this report. 
5-2 
6-1 

6. PROJECT CONCLUSIONS AND RECOMMENDATIONS 

Based on the activities performed in this project, the project team offers the following conclusions 

and recommendations. Obviously, there are other missions and constraints on the Coast Guard in 

addition to those that were examined in this study; therefore, the Coast Guard will need to evaluate 

the recommendations in light of its overall responsibilities. 

6.1 CONCLUSIONS 

• Resource issues for the Coast Guard and limited potential for involvement in high 

consequence events suggest exemption status for "workboats" and "assistance towing 

vessels" 

Volume 1 of the WTLUS indicates that there were nearly 9,000 self-propelled U.S.-flag 

vessels operating or available for operation in 2004 (not including floating equipment 

used for construction, fishing vessels, and recreational craft). Of these vessels, more than 

5,000 are towing vessels, with the vast majority being currently uninspected vessels. The 

remainder of the 9,000 vessels are in cargo, passenger, offshore support, ferry, and tanker 

services and are generally already inspected vessels, along with a large number of barges 

currently subject to inspection. The 5,100 to 5,200 towing vessels do not include 

workboats less that 26 ft in length or towing assistance vessels. However, simply adding 

the 5,100 to 5,200 as inspected vessels represents a large increase in vessel inspection 

activities that will be a challenge for the Coast Guard. Choosing not to also include 

workboats and towing assistance vessels in the proposed regulations (as recommended by 

TSAC) is one way to help limit the size of the task facing the Coast Guard (see 

Recommendation 6.2.1). In the case of towing assistance vessels, it would also eliminate 

an economic impact on a group of individuals and small companies that would otherwise 

bear the largest cost burden relative to their current cost of operation. 

• Risk information from the MISLE accident database indicates that historical accident 

risks are dominated by large horsepower vessels 

After adjusting for the fact that most small towing vessels (i.e., less than 26 ft) are not 

included in the MISLE vessel database unless they are involved in an accident, it is clear 

that the historical risk is dominated by large horsepower towing vessels. There are about 

400 towing vessels that are reported in the WTLUS as greater than 5,000 horsepower (see 

Figure 3.10). On an annual basis, these vessels pose risks that are 15 to 120 times larger 

than vessels of lower horsepower (see Figure 4.4). Ensuring that these vessels receive the 

most attention in a new inspection regime should be an objective of the regulatory 

strategy (see Recommendation 6.2.2). 

• An effective safety management systems requirement can be an important step in 

addressing both equipment issues that occur over time and human factors issues; however, 
6-2 

safety management systems invoked by regulations have been difficult for regulated 

communities to implement effectively 

Safety management systems offer the flexibility to have company policies, vessel 

operations procedures, and equipment maintenance procedures that are specific to the 

towing services and conditions under which the company and its vessels operate. If 

properly developed and implemented, a safety management system approach can be costeffective and contribute to safety improvements. However, implementation of safety 

management systems elsewhere in the marine industry (e.g., ISM requirements for vessels 

subject to SOLAS) and in other US industries (process safety management for highly 

hazardous chemicals) has required years to be effectively implemented. It has required 

strong initial implementation efforts by industry, followed by improvements based on 

several audit cycles, effective application of lessons learned over time, and effective 

regulatory oversight for such systems to make real differences in industry safety 

performance. Preparing a new regulation and getting it approved is only the start of the 

process that needs attention and resources devoted to it for a long period of time (see 

Recommendation 6.2.4). 

6.2 RECOMMENDATIONS 

6.2.1 Consider excluding workboats and towing assistance vessels from the proposed 

regulations for inspection of towing vessels. 

Workboats are vessels that operate in limited geographic areas and do not participate in 

transportation of goods or support to vessels that do. However, developing a definition of 

workboats to define this category of service may be difficult. The issue of differentiating 

between workboats and other small boats in towing service or supporting towing operations 

(e.g., fleeting boats) is likely to arise. Towing assistance vessels will be easier to define for 

purposes of exclusion, and as discussed in the previous section, may suffer a 

disproportionate economic impact if regulated like towing vessels. 

In addition, the risk review performed in this project did not indicate that either workboats 

or towing assistance vessels have been significantly involved in high consequence events in 

the time frame examined. Also, the characteristics of the vessels (e.g., length and 

horsepower) and their operations (i.e., not involving very large cargoes or hazardous 

materials) make it unlikely that such vessels pose significant risks in the future. 

Excluding these vessels from the proposed regulations does not mean they will be 

"unregulated." They will still be subject to numerous regulations, several of which (e.g., 

licensing and fire protection) have been revised recently. However, this assumes that the 

references in those current regulations that apply to existing towing vessels will not all be 

eliminated as new towing vessel regulations are promulgated. 
6-3 

6.2.2 Ensure that large horsepower towing vessels (i.e., greater than 5,000 horsepower) 

receive the regulatory attention they deserve based on historical accident experience 

examined in risk terms. 

See the risk analysis results in Section 4.3 and the discussion in the conclusion about risk 

information discussed above. 

6.2.3 Consider providing effective training when the towing vessel inspection regulation is 

released and then additional periodic training for Coast Guard inspectors and thirdparty personnel who will be involved in towing vessel inspections, in order to help 

ensure consistency in regulatory review and enforcement. 

Some of the personnel who will be involved in enforcing or auditing the new towing vessel 

regulations will have experience with ISM or RCP systems; however, it is likely that the 

safety management system developed for the towing vessel regulations will have some 

unique aspects. Providing regulation-specific training is essential to ensuring effective 

implementation. 

6.2.4 Consider encouraging small business outreach/assistance programs by industry 

organizations or by the Coast Guard to assist small towing companies in SMS 

development and implementation, both for compliance purposes and to help them 

achieve real human factors improvements. 

This effort will need to begin with an industry outreach program to first communicate that 

the regulation applies to them and then what they need to do in order to comply. Typically, 

small towing companies will not have any experience with SMSs for regulatory purposes. 

They will require a significant level of assistance or they will be risking noncompliance or 

having to leave the towing business. Also, to really reduce the potential for error-likely 

situations, an SMS needs to be well structured and implemented. It is unlikely that small 

towing companies without SMS experience can achieve that goal without assistance. 

6.2.5 Consider offering alternative inspection approaches (i.e., that do not require a 

company safety management system) for companies that prefer being subject to a 

more prescriptive inspection regime. 

The incentive to have a towing vessel inspection regime that incorporates a safety 

management system is largely applicable to the companies that comprise the AWO and 

have already implemented the RCP program, which they expect to help them meet most of 

any Coast Guard inspection requirement that involves a safety management system. That 

same benefit does not apply to many other companies. And for small towing companies, a 

safety management system may not a very cost-effective way to achieve safer operations. 

The Coast Guard should consider offering such companies a more traditional inspected 

vessel option, where the Coast Guard (or an authorized third party) provides inspection to a 

more prescriptive set of rules. 
6-4 
7-1 

7. REFERENCES 

AWO, 2002. American Waterways Operators, Our Compass Always Points to Safety: What You 

Should Know About Tugboat, Towboat and Barge Industry Safety, 2002. 

AWO, 2005. American Waterways Operators, Responsible Carrier Program, 2005. 

AWO, 2006. American Waterways Operators, ABS Consulting Discussions with AWO Staff, 

March, 2006. 

AWO, 2006a. American Waterways Operators, Towing Industry Statistics on the Internet at 

http://www.americanwaterways.com/industry_stats/index.html, 2006. 

BAWG, 2003. Bridge Allision Working Group Report, U.S. Coast Guard and American 

Waterways Operators, May 2003. 

Fed Reg, 2004. Federal Register, United States Coast Guard Notice in Federal Register, Vol. 69, 

No. 250, Thursday, December 30, 2004, Notices, p. 78471. 

Fed Reg, 2005. Federal Register, United States Coast Guard Notice in Federal Register, Vol. 70, 

No. 22, Thursday, February 3, 2005, Notices, p. 5691. 

IRR, 2006. Inland River Record, Waterways Journal, Inc., 2006. 

OSHA, 1996. Occupational Safety and Health Administration, OSHA/U.S. Coast Guard Authority 

Over Vessels, Compliance Policy Letter CPL 02-01-020, 11/08/1996. 

TSAC, 2005. Towing Safety Advisory Committee, Report of the Working Group on Towing 

Vessel Inspection, September 29, 2005. 

USACE, 2003. Department of the Army, Corps of Engineers, Waterborne Commerce of the 

United States, Calendar Year 2003, Part 1 - Waterways and Harbors, Atlantic Coast, IWRWCUS-03-1, 2003. 

USACE, 2003a. Department of the Army, Corps of Engineers, Waterborne Commerce of the 

United States, Calendar Year 2003, Part 2 - Waterways and Harbors - Gulf Coast Mississippi 

River System and Antilles, IWR-WCUS-03-2, 2003. 

USCG, 46 CFR 27. United States Coast Guard, Subpart A, General Provisions for Fire-Protection 

Measures and Fire-Suppression Equipment on Towing Vessels. 

U.S. Congress, 2004. 108th Congress, 2nd Session, House Of Representatives Report 108-616, 

July 20th, 2004. 

WTLUS, 2003. Waterborne Transportation Lines of the United States, Calendar Year 2003, 

Volume 1 - National Summaries, Department of the Army, Corps of Engineers. 
7-2 
APPENDIX A 

Preliminary Unit Cost Assessment of an Inspection Regime for the 

Uninspected Towing Vessel Industry 

 
A-2 
Preliminary Unit Cost Assessment of an Inspection Regime for the 

Uninspected Towing Vessel Industry 

Final Report 

 

Abt Associates Inc. 

August 30, 2006
UTV Industry Preliminary Cost Assessment i Abt Associates Inc.  August 30, 2006 

Table of Contents 

EXECUTIVE SUMMARY .......................................................................................................... 1

1. INTRODUCTION............................................................................................................. 9

2. SCOPE AND METHODOLOGY ................................................................................. 13

2.1 Burden Categories and Cost Elements ......................................................................... 13

2.2 Data Sources.................................................................................................................... 15

2.3. Presentation of Results ................................................................................................... 17

2.4 Inclusion of Towing Assistance Vessels ........................................................................ 17

2.5 Caveats to the Preliminary Cost Assessment ............................................................... 18

3. POTENTIAL COSTS OF RECOMMENDED EQUIPMENT STANDARDS ......... 19

3.1 Hull and Machinery........................................................................................................ 21

3.1.1 Design and construction (new vessels only) ........................................................................................21

3.1.2 Handrails and bulwarks.......................................................................................................................22

3.1.3 Emergency egress ................................................................................................................................23

3.1.4 Freeing ports and scuppers .................................................................................................................23

3.1.5 Guards for exposed hazards ................................................................................................................23

3.1.6 Alarms/monitoring and Gauges...........................................................................................................24

3.1.7 Steering................................................................................................................................................25

3.1.8 Electrical equipment and wiring standards.........................................................................................26

3.1.9 Fuel systems.........................................................................................................................................26

3.1.10 Electrical generating systems ..............................................................................................................27

3.1.11 Lighting................................................................................................................................................27

3.2 Navigation and Communication Equipment................................................................ 28

3.2.1 Capability of connecting a VHF radio to battery backup....................................................................28

3.2.2 Handheld VHF radio ...........................................................................................................................28

3.2.3 Second radar........................................................................................................................................28

3.2.4 Rudder angle indicator or means to visually indicate rudder position................................................29

3.2.5 Onboard crew communications ...........................................................................................................29

3.2.6 Means of ensuring visibility through pilothouse windows...................................................................30

3.2.7 Emergency communications capability ...............................................................................................30

3.3 Pollution Prevention Equipment ................................................................................... 31

3.3.1 Bilge pumps or other dewatering capability........................................................................................31

3.3.2 Oily Water Separators (OWS) .............................................................................................................31

3.3.3 Spill kit.................................................................................................................................................32

3.3.4 Closable scuppers or other containment method.................................................................................32

3.4 Lifesaving Equipment..................................................................................................... 34

3.4.1 Visual distress signals..........................................................................................................................34

3.4.2 First aid kit/trauma kit.........................................................................................................................34

3.4.3 Immersion suits....................................................................................................................................34

3.4.4 Inflatable life raft.................................................................................................................................35

3.5 Firefighting Equipment.................................................................................................. 35

3.5.1 Fire axe................................................................................................................................................35

3.5.2 Smoke alarms to protect all sleeping spaces .......................................................................................35

3.5.3 Heat or flame detector in galley ..........................................................................................................36

3.5.4 Remote manual engine shutdown.........................................................................................................37

3.5.5 Placarded storage area appropriate for flammable products .............................................................37

4. DRYDOCKING .............................................................................................................. 39

4.1 Direct Inspection Costs................................................................................................... 41
UTV Industry Preliminary Cost Assessment Abt Associates Inc.  August 30, 2006 

 

ii

4.2 Delay Costs ...................................................................................................................... 44

5. SAFETY MANAGEMENT SYSTEM DEVELOPMENT, IMPLEMENTATION 

AND MANAGEMENT............................................................................................................... 47

5.1 Safety Management System Development & Initial Implementation........................ 51

5.2 Ongoing SMS Maintenance & Activities ...................................................................... 55

5.3 Internal Auditing Programs........................................................................................... 58

5.4 External Auditing Programs.......................................................................................... 59

ATTACHMENT 1: TSAC Recommended Requirements for a UTV Inspection Regime 

ATTACHMENT 2: The Towing Assistance Industry 

ATTACHMENT 3: Contact Information for Telephone Interviews and Surveys 

ATTACHMENT 4: Copy of the Leave-Behind Questionnaire (Full and Abbreviated 

Versions) 
UTV Industry Preliminary Cost Assessment iii Abt Associates Inc.  August 30, 2006 

List of Exhibits 

Burden Categories and Cost Elements Included in the Preliminary Cost Assessment______________________14

UTV Vessel Specification Categories ____________________________________________________________15

Summary of Potential Per Vessel Costs of Prescribed Equipment Standards for the UTV Industry ___________20

Sample Radar Costs__________________________________________________________________________29

Typical OWS Equipment Cost Estimates _________________________________________________________32

Summary of Potential Containment Costs ________________________________________________________33

Summary of Typical First Aid Kit Costs __________________________________________________________34

Summary of Costs of Typical Heat Detectors ______________________________________________________37

Summary of Per Vessel Cost Estimates for Compliance with Potential Drydocking Requirements ___________41

Hourly Labor Rates for Towing Vessel Dry-Dock Inspections ________________________________________43

Summary of Cost Estimates for Potential Safety Management System Requirements ______________________50

Estimated Per Company Costs for SMS Development _______________________________________________53

Estimated Costs of Internal Audits ______________________________________________________________59

Cost for External SMS Audits, Excluding Travel and Other Expenses _________________________________60

Estimated Costs of External Audits______________________________________________________________61
UTV Industry Preliminary Cost Assessment 1 Abt Associates Inc.  August 30, 2006

EXECUTIVE SUMMARY 

This preliminary cost assessment was prepared to aid the United States Coast Guard (USCG or 

“Coast Guard”) in developing regulations governing a potential inspection regime for currently 

uninspected towing vessels (“UTVs”), pursuant to Section 415 of Public Law 108-293, “The 

Coast Guard and Maritime Transportation Act of 2004” (“the Act”). The Act added towing 

vessels to the list of vessels requiring inspection for certification. Prior to formulating a 

proposed rule regulating the UTV industry, the Coast Guard is interested in understanding the 

general scope of potential economic costs that the industry may incur as a result of new 

regulatory requirements. 

In the absence of specific regulatory requirements such as those that might be found in a 

proposed rulemaking, the Coast Guard, ABS Consulting, and Abt Associates Inc. developed 

burden categories - areas of potential future economic costs associated with an inspection regime 

for UTVs - through review of the following three sources: 

• Voluntary, industry-developed codes of practice developed by the American Waterways 

Operators’ (“AWO”) Responsible Carrier Program (“RCP”); 

• Compliance with regulatory standards included in the International Safety Management 

(“ISM”) Code; and 

• Recommended requirements for UTVs contained within the Report of the Working Group on 

Towing Vessel Inspection (“RWG”) of the Towing Safety Advisory Committee (“TSAC”). 

The burden categories developed are almost entirely those recommended by the TSAC RWG, 

and consider potential onboard vessel equipment standards, examination and drydocking 

requirements, and safety management requirements that are not already required by law. As a 

result, this assessment provides estimates of the potential unit compliance costs that may be 

incurred by individual UTVs as a result of rulemaking pursuant to Section 415 the Act. 

Exhibits ES-1 through ES-3 present cost estimates for each recommended requirement included 

in the preliminary cost assessment. Specifically, Exhibit ES-1 presents cost estimates for 

equipment standard recommendations, Exhibit ES-2 presents cost estimates for drydocking 

recommendations, including inspection standards, and Exhibit ES-3 presents cost estimates for 

safety management system recommendations. 

Equipment Standards 

Recommended equipment standards for UTVs contained in the TSAC RWG fall into five major 

categories: hull and machinery, navigation and communication, pollution prevention, lifesaving, 

and firefighting equipment. For each standard, the TSAC RWG provides information on the 

type of equipment that would allow a UTV to come into compliance. This information was used 

as the basis for the cost research conducted in this assessment. In addition, for some standards, 

the TSAC RWG indicates whether the standard applies to new (i.e., constructed after the date of 

regulation) or existing UTVs only, or provides different requirements for new and existing 
UTV Industry Preliminary Cost Assessment 2 Abt Associates Inc.  August 30, 2006

UTVs. It is important to note, however, that for many equipment standards the TSAC RWG 

does not differentiate between new and existing UTVs. 

Research into the costs associated with potential equipment standards generally began with a 

Web site search of relevant equipment suppliers. Companies involved in manufacturing, 

supplying, or purchasing the item in question were contacted by telephone and they either 

provided information or pointed to another supplier who might be able to provide the 

information. Ultimately, sources were selected for their involvement and expertise in the towing 

industry. To the extent possible, interviews were conducted with representatives from a variety 

of sources (large-scale/large-vessel towing operations, small-scale/small-vessel towing 

operations, marine equipment manufacturers or distributors, and shipbuilders) in order to obtain 

a range of potential compliance costs. Multiple sources were contacted for relatively expensive 

equipment items, with a minimum of three sources for all items over $100. Finally, the 

assessment prioritized obtaining commercial vessel cost data (as opposed to recreational vessel 

cost data) that would be relevant to commercial UTV operations. 

Research demonstrated that towing vessel design decisions and associated costs of compliance 

with potential equipment standards are based on a large number of factors, including vessel size, 

area and type of intended use, speed, power, and the needs of the particular vessel owner. 

Accordingly, as shown in Exhibit ES-1, cost estimates obtained from data sources frequently 

vary, and are presented as ranges where necessary to capture a range of costs representative of 

different vessel types and data sources. Costs in Exhibit ES-1 are presented separately for new 

and existing UTVs in those cases where the TSAC RWG differentiated standards between the 

two. 

Potential future costs of compliance will also vary with the degree of current compliance on a per 

vessel basis and within the UTV industry as a whole, and with UTV company size. While 

interview responses suggest that many of the recommended standards are already met by most 

towing vessels with which particular architects are familiar, there are standards for which there 

was no consensus on current levels of compliance among the sample of interviewees. 
UTV Industry Preliminary Cost Assessment 3 Abt Associates Inc.  August 30, 2006

Exhibit ES-1 

Summary of Potential Per Vessel Costs of Prescribed Equipment Standards for the UTV Industry 

Standards 

Category Cost Element 

Level of Current 

Compliance [1] 

Potential Per-Vessel Range of Unit Costs to 

Comply with Standard [2] 

New UTVs (Constructed after effective date of regulation) 

Design and construction to American Bureau 

of Shipping (ABS) or other standards High Unknown 

Emergency egress High $7,000 to $15,000 

Steering Variable $10,000 (average) 

Electrical equipment and wiring Variable $21,000 to $708,000 

Hull and 

Machinery 

Electrical generating systems Variable $2,000 to $100,000

Heat or flame detector in galley Unknown $14 to $184 Firefighting Remote manual engine shutdown High $1,500 to $8,000 

Existing UTVs (Constructed prior to effective date of regulation) 

Handrails and bulwarks High $10,000 to $50,000 

Freeing ports and scuppers High $1,000 to $30,000 

Guards for exposed hazards High $20 per linear foot 

Alarms/monitoring and gauges Variable $4,500 to $200,000 

Steering Variable $9,500 to $12,000 

Electrical equipment and wiring Variable Minimal [3] 

Fuel systems High $4,000 to $5,000 

Electrical generating systems Variable Minimal [4] 

Hull 

and 

Machinery 

Lighting High Unknown 

Connect VHF radio to battery backup Unknown $2,000 

Handheld VHF radio Unknown $100 to $300 

Second radar Unknown $3,850 to $6,650 

Rudder angle indicator Unknown $750 to $2,500 

Onboard crew communications Unknown $2,000 to $10,000 

Pilothouse window visibility High $1,000 to $15,500 

Navigation 

and 

Communication 

Emergency communications capability Unknown $200 to $2,000 

Bilge pumps High $5,000 to $80,000 

Oily water separators High $10,600 to $27,800 

Spill kit Unknown $320 to $600 

Pollution 

Prevention 

Closable scuppers Unknown $100 to $17,200 

Visual distress signals Unknown $171 to $504 

First aid kit/trauma kit Unknown $85 to $695 

Immersion suits Unknown $1,060 to $4,260 Lifesaving 

Inflatable life raft Unknown $3,400 to $6,400 

Fire axe Unknown $45 to $65 

Firefighting Smoke alarms Unknown $10 to $70,000 

Placarded storage area Unknown $2,000 

[1] Naval architects and other interviewees were asked about the level of general current compliance of vessels in the UTV industry with each 

recommended requirement. A “high” level of compliance indicates that all interviewees thought that most UTVs were already in compliance with the 

recommended requirement; a “variable” level of compliance indicates that interviewees differed in their statements about current levels of compliance; 

and an “unknown” level of compliance indicates that all interviewees did not know or did not provide information on the current level of compliance 

with the recommended requirement. 

[2] Non-compliance is assumed in calculating cost impacts; therefore, these cost impacts may be overstated to the extent that vessels are partly or fully 

in compliance. 

[3] TSAC’s recommended electrical equipment and wiring requirement for existing UTVs consists of relatively minor actions such as labeling and 

ensuring that all elements are in proper working condition. The analysis assumes that UTV owners/operators already conduct appropriate maintenance 

of electrical equipment and wiring for UTVs in the absence of regulation; therefore, potential costs are assumed to be minimal for this recommended 

requirement and may consist of such activities as equipment labeling. 

[4] TSAC’s recommended electrical generating system requirement for existing UTVs consists of proper maintenance. The analysis assumes that UTV 

owners/operators already conduct appropriate maintenance of these systems for UTVs in the absence of regulation; therefore, potential costs are 

assumed to be minimal for this recommended requirement.
UTV Industry Preliminary Cost Assessment 4 Abt Associates Inc.  August 30, 2006

Drydocking 

Recommended drydocking inspection requirements may pose direct and delay (opportunity) 

costs on vessel owners and operators. Direct costs include the costs of renting drydock slip 

space and labor costs associated with inspection. Potential delay costs under a regulation 

requiring a USCG or third party inspection may arise where UTVs must be drydocked for 

marginally longer periods of time than would occur in the absence of regulation. Delay costs 

may result from 1) longer periods of time required to ready the vessel for inspection; 2) longer 

periods of time required to inspect a vessel in accordance with all regulatory requirements; 3) 

time required for inspection by the U.S. Coast Guard or a third party inspector; and 4) time 

required to implement corrections to issues raised by the inspection. These delays may lead to 

economic opportunity costs in which the vessel in question is not being put to its intended 

economic purpose for a longer period of time than would have occurred in the absence of 

regulation. In this case, opportunity costs are likely to consist primarily of lost revenue 

associated with the day rate of the vessel. 

Six companies that provide drydocking services were interviewed about the cost and time 

required to perform internal and external inspections of vessels. Companies were selected for an 

interview if they maintained a Web site outlining their basic services, if they operated at least 

two drydocks, and if they offered ship repair as well as drydocking services for towing vessels. 

The interviewees were asked a variety of questions associated with the hourly labor rate for 

drydock internal and external inspections of vessels, the cost of renting drydock space, and the 

time required to perform an inspection. 

As summarized in Exhibit ES-2, direct costs for potential drydocking requirements as 

recommended by the TSAC RWG may range from $410 to $5,000 per vessel. These costs 

include both drydock slip rental and labor costs for inspectors. The range in potential costs 

results from variations in company hourly rates, inspection times, and vessel size characteristics 

such as length and weight. 

While the assessment obtained cost estimates associated with direct drydocking inspection costs 

as shown in Exhibit ES-2, opportunity costs of delay are not estimated. Without information 

about new regulatory requirements associated with drydocking inspections, and given the wide 

range of differences in vessel operations, it was not feasible, given the resources available for 

this cost assessment, to estimate meaningful dollar delay costs for all vessels affected by a future 

regulation. However, the assessment does note that there may be opportunity costs of delay 

associated with a future regulation that may consist of foregone profits if regulations require a 

vessel to spend longer periods of time out of service, or drydocked, and less time performing 

operations that generate revenue. 
UTV Industry Preliminary Cost Assessment 5 Abt Associates Inc.  August 30, 2006

Exhibit ES-2 

Summary of Per Vessel Cost Estimates for Compliance with Potential Drydocking Requirements 

Cost Category Estimated Range of Potential Per Vessel Cost [1] 

Direct Inspection Costs [2] $410 to $5,000 

Delay Cost [3] Not Estimated 

Notes: 

[1] Interviewees were asked to estimate the time and cost required to comply with standards recommended 

by TSAC in its September 2005 Report of the Working Group on Towing Vessel Inspection. 

[2] Direct inspection costs include the total cost for a company to conduct a drydock inspection, including 

drydock slip rental, and varies by company, vessel length, weight, and the time required to conduct an 

inspection. 

[3] Delay poses opportunity costs on vessel owners and/or operators. Opportunity cost includes the 

economic activities that a vessel could undertake if it were not out of service. These activities vary by 

company, vessel weight, and vessel length, among other factors, and therefore complicate cost estimation. 

Safety Management Systems 

The TSAC RWG recommends that the UTV industry be required to develop, implement, and 

maintain a safety management system (SMS) as part of any future proposed rule creating an 

inspection regime for the UTV industry. An SMS is a structured and documented system that 

enables company personnel to effectively implement the company’s safety and environmental 

protection policy. 

Information sources for the SMS cost data include nine telephone interviews with SMS auditors 

and vessel companies and a leave-behind questionnaire delivered to ports during ABS 

Consulting port visits. SMS interviewees were selected through Web-site searches and from the 

AWO RCP auditor list to represent a range of geographic regions in the United States. 

Interviewees were asked a variety of questions associated with SMS costs, such as the relative 

comprehensiveness of the SMS process, the method through which SMS fees are determined, 

factors that impact SMS development and/or implementation time and cost, documentation and 

recordkeeping procedures, and external and internal auditing procedures. Both small and large 

companies that prepare SMSs for vessel companies were interviewed. The geographic range of 

companies as well as company size differences yielded a broad sample of the SMS auditing 

industry. Research conducted revealed the following elements of SMSs: 

 

• SMS development involves laying out requirements and the collection and compilation of 

relevant company information (policies, procedures, processes, and other documentation as 

listed above) into a single, organized document system. Most companies already maintain 

many of the SMS components in some form, and require simply integrating these 

information resources, thereby incurring a relatively low cost for SMS development. Other 

companies that do not maintain much relevant documentation incur higher costs of SMS 

development, as the missing policies or procedures must be developed. 

 

• SMS implementation generally involves implementing methods to achieve established safety 

objectives, training to ensure proper application of the SMS, and internal audits to ensure 

compliance. Interviewees indicated that SMS implementation generally takes 12 to 18 
UTV Industry Preliminary Cost Assessment 6 Abt Associates Inc.  August 30, 2006

months but can take as little as one month. This depends, in part, on company motivation and 

management buy-in, and the stringency of its implementation. Reportedly, companies may 

shelve SMS plans because they do not have consistent vessel/shore-side communication, 

because they do not have the commitment of management, or because they have high rates of 

turnover or have not administered training, which can be expensive. 

• Ongoing SMS maintenance and activities include staff training, updates to the SMS 

documents, recordkeeping, and internal audits. 

• An internal auditing program is the foundation of an oversight system, and serves to assess 

compliance with the requirements of the particular SMS program. The internal audit helps to 

maintain the SMS, including detecting and rectifying problems before an external audit. The 

AWO and ISM standards explicitly recommend establishing internal auditing programs. 

Internal auditing procedures are generally company-specific, and can be conducted by trained 

company personnel or outsourced to companies such as those that develop SMSs. 

• Once the SMS is prepared and implemented, a qualified external auditor must perform initial 

and periodic external audits in order for the company to obtain and maintain certification 

under a formal certification program. While the external audits discussed with interviewees 

are specifically associated with AWO’s RCP or ISM Code compliance, cost estimates may 

be indicative of costs that could be incurred for companies to undergo an audit to 

demonstrate compliance with potential Coast Guard SMS requirements, if audits are required 

by personnel outside the company. 

Costs associated with these SMS elements are summarized in Exhibit ES-3. Actual costs 

incurred by UTV industry members may differ from the estimated potential costs summarized in 

Exhibit ES-3 for the following reasons: 

• Because the current SMSs associated with the entities interviewed for this assessment differ 

in scope and content from TSAC’s recommended requirements for SMSs and those 

requirements that may be finalized in a future UTV regulation, cost estimates obtained may 

overstate or understate the actual future costs to comply with a future UTV regulation. 

• Costs of implementing SMSs are likely to vary according to company size and other 

company-specific characteristics that may differ from the average-sized towing vessel 

company used for many of the cost estimates. For this reason, cost estimates summarized in 

Exhibit ES-3 may overstate or understate future costs. 

• While employee training costs comprise a large percentage of initial SMS implementation 

costs as reported in the leave-behind questionnaire, training on such issues as safety and 

emergency response may already be conducted in the absence of regulation. To the extent 

that this is true, all training costs presented may not be attributable to a future Coast Guard 

SMS regulation. Similarly, ongoing SMS maintenance and activities that may already be 

conducted in the absence of regulation such as safety program drill performance, safety 

meetings, and emergency drills and exercises, comprise a large percentage of ongoing SMS 

maintenance and activities. To the extent that these are already conducted in the absence of 
UTV Industry Preliminary Cost Assessment 7 Abt Associates Inc.  August 30, 2006

regulation, costs presented for ongoing SMS maintenance and activities may not be 

attributable to a future Coast Guard SMS regulation. 

Exhibit ES-3 

Summary of Cost Estimates for Potential Safety Management System Requirements

Cost Element [1] Estimated Potential Costs [2] 

SMS development [3] $750 to $70,000 (One-time cost) 

SMS initial implementation 

$311,000 overall for an average towing vessel company 

$1,680 per employee for an average towing vessel company 

(One-time cost) 

Ongoing SMS maintenance and activities [4] 

$2.5 million for an average towing vessel company 

$14,490 per employee for an average towing vessel company 

(Annual cost) 

Internal auditing $5,000 to $18,000 audit cost (Per audit) 

 $1,700 training cost (Per employee trained as auditor) 

External auditing $750 to $6,000 

Notes: 

[1] Safety management cost elements included in this exhibit represent only a portion of the recommended standards 

included in TSAC’s RWG. To the extent that certain recommended SMS components are not included in these cost 

estimates, the estimates will understate potential future costs of complying with RWG recommendations. 

[2] Per employee costs for SMS initial implementation represent training costs only; per employee costs for ongoing SMS 

maintenance and activities represent personal protective equipment and maintenance, safety program drill performance, 

safety meetings, emergency drills and exercises, recordkeeping, and period refresher training programs for personnel 

policies; per employee costs for other activities were not estimable given the lack of data on the number of employees 

implementing those activities. To the extent that these activities are already conducted in the absence of a future Coast 

Guard SMS regulation, these costs will overstate potential future costs of complying with RWG recommendations. 

[3] The range of potential costs for SMS development is estimated using cost information obtained from interviews with 

towing vessel companies, interviews with SMS development professionals, the response to the leave-behind questionnaire 

distributed to towing vessel companies during ABS Consulting port visits, and from personal communication with the 

company that completed the leave-behind questionnaire on August 25, 2006. 

[4] The reported company cost for ongoing SMS maintenance and activities represents the sum of the cost of company 

safety, health, and security policy; SMS updating; emergency preparedness and response procedures; personnel policies 

and procedures; documentation and recordkeeping; and incident reporting. These costs represent costs reported in the 

leave-behind questionnaire by a single average-sized towing vessel company with 24 vessels and between 100 and 200 

employees, and may not be representative of towing vessel companies in the UTV industry. 

 

Caveats to the Preliminary Cost Assessment 

A variety of factors may cause estimates summarized in Exhibits ES-1 through ES-3 to overstate 

or understate actual future costs. These factors and their potential impacts on cost estimates are 

as follows: 

 Uncertainty regarding future regulatory requirements. The Coast Guard has not issued a 

proposed rule, so the specific potential requirements for UTVs are currently unknown. In 

addition, regulations could be scaled according to vessel size, horsepower, type of 

operation, area of operation, number of vessels, and the nature of the risk associated with 

the vessel operation. To the extent that future regulatory requirements are either more or 

less stringent than TSAC RWG recommendations, cost estimates contained within this 

report will either be underestimated or overestimated, respectively. 
UTV Industry Preliminary Cost Assessment 8 Abt Associates Inc.  August 30, 2006

 

 Degree to which UTVs are currently in compliance with TSAC RWG recommendations. 

This preliminary assessment does not account for UTVs’ current level of compliance 

with TSAC RWG recommendations. For example, some towing companies are already 

in partial or full compliance with the ISM code; other towing companies may be in 

compliance with and certified by the AWO RCP. If the Coast Guard accepts compliance 

with ISM and/or AWO standards as sufficient in meeting SMS standards for UTVs, UTV 

operations in compliance would not incur SMS costs associated with the regulation, and 

those in partial compliance would have reduced costs. To the extent that this is true, 

upper-bound estimates (assuming zero compliance within the industry) will be 

overestimates. 

 Potential grandfathering provisions. If certain UTV regulations are “grandfathered” in 

situations where it is impractical for the Coast Guard to require vessel reconfigurations 

that are prohibitively expensive, such vessels would not incur costs of compliance. 

 UTV characteristics. UTVs vary widely in length, tonnage, age, area and type of 

operation, and construction material (see Exhibit 2). The costs of compliance depend 

significantly on these characteristics. For example, the cost of electrical wiring increases 

with vessel size. Costs of such requirements are presented as ranges to account for 

differing vessel sizes. To the extent that a particular vessel is smaller or simpler, etc., 

than the vessel size designated for the corresponding upper-bound estimate, the upperbound estimate will be overstated. 
UTV Industry Preliminary Cost Assessment 9 Abt Associates Inc.  August 30, 2006

1. INTRODUCTION 

This preliminary cost assessment is intended to aid the United States Coast Guard (USCG or 

“Coast Guard”) in developing regulations governing a potential inspection regime for currently 

uninspected towing vessels (“UTVs”), pursuant to Section 415 of Public Law 108-293, “The 

Coast Guard and Maritime Transportation Act of 2004” (“the Act”). The Act added towing 

vessels to the list of vessels requiring inspection for certification. Prior to formulating a 

proposed rule regulating the UTV industry, the Coast Guard is interested in understanding the 

general scope of potential economic costs that the industry may incur as a result of new 

regulatory requirements. 

In the absence of specific regulatory requirements such as those that might be found in a 

proposed rulemaking, the Coast Guard, ABS Consulting, and Abt Associates Inc. developed 

burden categories - areas of potential future economic costs associated with an inspection regime 

for UTVs - through review of the following three sources: 

• Voluntary, industry-developed codes of practice developed by the American Waterways 

Operators’ (“AWO”) Responsible Carrier Program (“RCP”)1; 

• Compliance with regulatory standards included in the International Safety Management 

(“ISM”) Code2

; and 

• Recommended requirements for UTVs contained within the Report of the Working Group on 

Towing Vessel Inspection (“RWG”) of the Towing Safety Advisory Committee (“TSAC”).3

The burden categories developed are almost entirely those recommended by the TSAC RWG, 

and consider potential onboard vessel equipment standards, examination and drydocking 

requirements, and safety management requirements that are not already required by law. As a 

result, this assessment provides an estimate of the potential unit compliance costs that may be 

incurred by individual UTVs as a result of rulemaking pursuant to Section 415 the Act. The 

TSAC RWG was formed in September 2004 to assist the Coast Guard in developing an 

inspection regime for the UTV industry, and is therefore an appropriate source of potential 

regulatory requirements.4

 

1

 The American Waterways Operators is the national trade association of the U.S. tugboat, towboat, and barge 

industry. AWO’s Responsible Carrier Program consists of best industry practices for company management policies, 

vessel equipment, and human factors. Compliance with the program is certified through a third-party AWO-certified 

auditor. Information on the Responsible Carrier Program, including the RCP document available for download, is 

available from the AWO website at http://www.americanwaterways.com. 2

 The International Safety Management Code is the international standard for safe management and operation of 

ships, and for pollution prevention. Flag states are responsible for ISM Code Certification of flagships. The ISM 

Code is available for download on the International Maritime Organization website, at http://www.imo.org. 3

 Working Group on Towing Vessel Inspection, “Report of the Working Group on Towing Vessel Inspection.” 

Memorandum submitted to the Towing Safety Advisory Committee, September 29, 2005. Recommended 

requirements contained within the TSAC RWG are reproduced in Attachment 1 of this report. 4

 The ISM code and AWO RCP were consulted in the preparation of the TSAC RWG. 
UTV Industry Preliminary Cost Assessment 10 Abt Associates Inc.  August 30, 2006

1.1 Regulatory and Industry Background 

Section 415 of Public Law 108-293 added all towing vessels to the list of regulated vessels that 

must comply with prescribed equipment, drydocking, and safety standards in order to pass an 

inspection and obtain certification for operation from the Coast Guard. As a result, vessels that 

were not previously inspected would incur two related sets of costs: the costs of complying with 

new standards (e.g., purchasing a previously unrequired piece of equipment) and inspection 

costs. Prior to the Act, the Coast Guard was required to inspect only towing vessels greater than 

or equal to 300 gross registered tons that operate beyond the boundary line.5

 Vessels that did not 

require inspection prior to the Act are termed uninspected towing vessels (“UTVs”).6

 UTVs are 

also characterized by length and propulsion parameters: UTVs range from less than 26 feet in 

length with outboard motor propulsion to vessels up to 1,800 gross tons with propulsion power 

inside the boundary line, winch systems, and lengths of 180 feet or greater.7 

A proposed rulemaking governing inspection of the UTV industry would revise current Coast 

Guard regulations by adding a new Subchapter M to Title 46 of the Code of Federal Regulations. 

Under Subchapter M, the Coast Guard would issue a Certificate of Inspection (COI) to UTVs 

that meet specified equipment, drydocking, and safety management standards. For example, the 

new regulations may prescribe equipment standards for hulls, fittings, equipment, appliances, 

propulsion machinery, auxiliary machinery, boilers, unfired pressure vessels, piping, electrical 

installations, accommodations, lifesaving equipment and its use, firefighting equipment and its 

use, precautionary measures to guard against fire, inspections and tests related to the list above, 

and the use of vessel stores and other supplies of dangerous nature. The new regulations may 

also require drydocking and related inspections within a specified time period. Finally, the new 

regulations may outline required elements of safety management systems for UTVs, including 

internal and external audits, in which all regulated towing vessels would be required to 

participate. 

The TSAC RWG recommends the following vessels for exemption: 

• Towing vessels under 26 feet in length; 

• Workboats and tenders that do not engage in commercial towing for hire but may 

intentionally move a piece of equipment in a limited geographic area, such as a dredging 

or construction jobsite or a vessel maintenance yard; and 

• Vessels that tow disabled vessels for consideration (assistance towing vessels).8

 

5

 A boundary line is a line of demarkation established under Section 2(b) of 33 U.S.C. 151. Generally, boundary 

lines follow the general trend of the shoreline and cross entrances to small bays, inlets and rivers. For specific 

descriptions of boundary lines refer to 46 CFR Part 7. 

6

 While inspection by the Coast Guard is not currently required for UTVs, the Coast Guard regulates these vessels as 

uninspected commercial vessels pursuant to Subchapter C of Title 46 of the Code of Federal Regulations. 

7

 The precise number of UTVs is unknown; however, the Coast Guard estimates that roughly 7,000 such vessels 

(including towing assistance vessels) constitute the industry and would be regulated pursuant to the Act. 8

 This assessment considers impacts to assistance towing vessels separately from the other classes of vessels 

irrespective of whether they are recommended for exclusion from new regulations by the TSAC RWG. Research 

findings associated with assistance towing vessels are presented in Attachment 2 of this report. 
UTV Industry Preliminary Cost Assessment 11 Abt Associates Inc.  August 30, 2006

To the extent that the Coast Guard accepts the TSAC RWG recommendations regarding 

applicability of the regulation and includes them in future rulemaking, the universe of potentially 

regulated towing vessels would be reduced.
UTV Industry Preliminary Cost Assessment 12 Abt Associates Inc.  August 30, 2006
UTV Industry Preliminary Cost Assessment 13 Abt Associates Inc.  August 30, 2006

2. SCOPE AND METHODOLOGY 

This section outlines the scope of the preliminary cost assessment and the methodology used to 

develop the estimates. The section first discusses the collaborative process used to identify 

burden categories and cost elements for inclusion in the assessment. Then, sources of data are 

discussed, followed by an explanation of the results and of the inclusion of towing assistance 

vessels in the report. Finally, caveats to the assessment are presented and discussed. 

2.1 Burden Categories and Cost Elements 

Without information about new regulatory requirements such as those that might be contained in 

a proposed rulemaking, the Coast Guard, ABS Consulting, and Abt Associates developed burden 

categories (areas of potential future economic costs associated with UTV inspection 

requirements) through review of existing vessel inspection standards of the AWO RCP, the ISM 

Code, and the TSAC RWG.9 As stated previously, the burden categories developed are almost 

entirely those recommended by the TSAC RWG, and consider potential onboard vessel 

equipment standards, examination and drydocking requirements, and safety management 

requirements that are not already required by law. 

The TSAC RWG recommendations for a new inspection regime for UTVs, including existing 

regulations, are reproduced in Attachment 1 of this report. Exhibit 1 presents burden categories 

and cost elements included in the preliminary cost assessment, which represent a subset of the 

information provided in Attachment 1. In developing the content for Exhibit 1, the Coast Guard, 

ABS Consulting, and Abt Associates determined that burden categories and cost elements should 

be limited to potential requirements that are not currently covered by existing towing-vessel 

regulations. As a result, this assessment provides an estimate of the potential unit compliance 

costs that may be incurred by individual UTVs as a result of rulemaking pursuant to Section 415 

the Act. 

 

9

 The TSAC RWG recommends that all of the requirements for inspected towing vessels be housed in a single 

subchapter. Further, they suggest that whenever possible, existing requirements be relocated to, or cross-referenced 

in, a new Subchapter M to Title 46 of the Code of Federal Regulations. 
UTV Industry Preliminary Cost Assessment 14 Abt Associates Inc.  August 30, 2006

Exhibit 1 

Burden Categories and Cost Elements Included in the Preliminary Cost Assessment

BURDEN 

CATEGORY COST ELEMENT [1] Report Section 

Hull and Machinery 

 Design, construction, alteration, and repair of vessel components in accordance with ABS 

Rules or other recognized standards* 

 Handrails and bulwarks 

 Emergency egress* 

 Freeing ports and scuppers 

 Guards for exposed hazards 

 Alarms/monitoring and gauges 

 Steering 

 Electrical equipment and wiring 

 Fuel systems 

 Electrical generating systems 

 Lighting 

3.1 

3.1.1 

3.1.2 

3.1.3 

3.1.4 

3.1.5 

3.1.6 

3.1.7 

3.1.8 

3.1.9 

3.1.10 

3.1.11 

Navigation and Communication Equipment 

 Capability of connecting a VHF to battery backup 

 Handheld VHF radio 

 Second radar 

 Rudder angle indicator or means to visually indicate rudder position 

 Onboard crew communications 

 Means of ensuring visibility through pilothouse windows 

 Emergency communications capability 

3.2 

3.2.1 

3.2.2 

3.2.3 

3.2.4 

3.2.5 

3.2.6 

3.2.7 

Pollution Prevention Equipment 

 Bilge pumps or other dewatering capability 

 Oily water separators 

 Spill kit 

 Closable scuppers or other containment method

3.3 

3.3.1 

3.3.2 

3.3.3 

3.3.4 

Lifesaving Equipment 

 Visual distress signals 

 First aid kit/trauma kit 

 Immersion suits 

 Inflatable life raft 

3.4 

3.4.1 

3.4.2 

3.4.3 

3.4.4 

COMPLIANCE 

WITH PRESCRIBED 

EQUIPMENT

STANDARDS

Firefighting Equipment 

 Fire axe 

 Smoke alarms to protect all sleeping spaces 

 Heat or flame detector in galley* 

 Remote manual engine shutdown 

 Placarded storage area appropriate for flammable products 

3.5 

3.5.1 

3.5.2 

3.5.3 

3.5.4 

3.5.5 

DRYDOCKING

Drydocking Costs 

 Direct inspection costs 

 Delay costs 

4 

4.1 

4.2 

SAFETY 

MANAGEMENT 

SYSTEM

SMS Costs: 

 SMS development & initial implementation 

 Ongoing SMS maintenance & activities 

 Internal auditing programs 

 External auditing programs 

5 

5.1 

5.2 

5.3 

5.4 

Notes: 

[1] Equipment, drydocking, and safety management cost elements included in this table represent new potential standards that may be 

required under Section 415 of the Act. 

*For some equipment standard recommendations, the TSAC RWG specifies whether the recommendation is for new and/or existing 

vessels. The asterisk indicates that the requirement is recommended for new vessels only (i.e., vessels constructed after the effective date 

of the regulations). Recommended equipment standards for which asterisk(s) are not used indicates that the TSAC RWG does not specify 

whether the requirement is recommended for new or existing vessels. 
UTV Industry Preliminary Cost Assessment 15 Abt Associates Inc.  August 30, 2006

2.2 Data Sources 

This section discusses the methodology followed to identify data sources and obtain cost 

information for each burden category. Information was obtained through online searches of 

products and services; telephone interviews with suppliers, ship builders, shipyards, naval 

architects, drydocks, and Safety Management System (SMS) auditors and preparers; and 

information supplied by towing companies and vessels during port visits.10, 11 In order to comply 

with the Office of Management and Budget’s (OMB) Information Collection Request (ICR) 

requirements, no more than nine individuals were contacted for cost information on the same 

recommended requirement. Given the small number of interviews and surveys, the unit cost 

estimates cannot be extrapolated reliably to the entire UTV industry. Nevertheless, the estimates 

do supply useful information regarding the relative magnitude of potential costs to the UTV 

industry. 

UTV vessel specification categories provided by the Coast Guard and reproduced in Exhibit 2 

guided telephone interviews, online research, and survey development; however the preliminary 

cost assessment does not disaggregate costs into these categories.

Exhibit 2 

UTV Vessel Specification Categories 

Specification Category 

Length Over Deck (ft) 0 – <25 26- ≤65 >65 - <79 79+ 

Gross Registered Tons (GRT) 0 -<5 5 - <50 50-<100 100-<200 200-<300 ≥300 

Age 0-5 6-10 11-15 16-25 >25 

Propulsion 

Waters Western 

Rivers Inland Great 

Lakes 

Lakes, 

Bays & 

Sounds 

Coastwise 

NMT 20 

NM fm 

shore 

Oceans 

Intraport [1] Intraport Interport Interport Oceans Oceans 

Service 

Limited 

Geographic 

Area 

(e.g., Fleet, 

Ship Assist, 

Harbor Assist, 

TBD)

Extended 

Limited 

Geographic 

Area 

(e.g., rivers, 

lakes, bays & 

sounds) 

Rivers; 

lakes bays 

& sounds 

ICW 

Coastal NonSOLAS SOLAS 

Hull Steel Wood Aluminum FRP Other Construction 

Material Superstructure Steel Wood Aluminum FRP Other 

Source: Coast Guard. 

Notes: 

[1] An intraport is a local area of operation, usually within a single harbor or port. 

 

10In addition, docket materials associated with regulations similar in subject and content in the Federal Docket 

Management System were reviewed but did not yield relevant information. 

11 Web site references are not cited in this report to prevent the appearance of the assessment’s endorsement of 

specific vendors. In addition, interviewees and survey respondents are not cited individually, to respect their desire 

to remain anonymous. Nevertheless, Attachment 3 of this report provides a list of individuals interviewed along 

with their affiliations. 
UTV Industry Preliminary Cost Assessment 16 Abt Associates Inc.  August 30, 2006

Equipment

Research into the costs associated with potential equipment standards generally began with a 

Web site search of relevant equipment suppliers. Companies involved in manufacturing, 

supplying, or purchasing the item in question were called and they either provided information or 

pointed to another supplier who might be able to provide the information. Ultimately, sources 

were selected for their involvement and expertise in the towing industry. To the extent possible, 

interviews were conducted with representatives from a variety of sources (large-scale/largevessel towing operations, small-scale/small-vessel towing operations, marine equipment 

manufacturers or distributors, and shipbuilders) in order to obtain a range of potential 

compliance costs. Multiple sources were contacted for relatively expensive equipment items, 

with a minimum of three sources for all items over $100.12 Finally, the assessment prioritized 

obtaining commercial vessel cost data (as opposed to recreational vessel cost data) that would be 

relevant to commercial UTV operations. 

Interviewees were asked a variety of questions, beginning with how much they thought it would 

cost to install the specific piece of equipment on a towing vessel. Follow-up questions generally 

addressed price ranges across the spectrum of potentially regulated vessels (e.g., large vs. small), 

breakdown of cost (e.g., “Does that include installation?” and “How might installation costs 

vary?”), the use of alternative options (e.g., “What if the vessel operator decided to meet the 

requirement using another method?”), and alternate sources for information. Interviewees were 

also asked about the level of current compliance in the UTV industry overall for each 

recommended requirement. 

For certain standard products with minimal installation requirements, (e.g., handheld VHF 

radios), price data were obtained from multiple online marine retailers selected for high Web site 

rank and large product stock.13 Phone interviews with industry professionals confirmed the use 

of the Web sites as reliable data sources. 

Drydocking

Six companies that provide drydocking services were interviewed about the cost and time 

required to perform internal and external inspections of vessels. Companies were selected for an 

interview if they maintained a Web site outlining their basic services, if they operated at least 

two drydocks, and if they offered ship repair as well as drydocking services for towing vessels. 

The interviewees were asked a variety of questions associated with the hourly labor rate for 

 

12 Where possible, the assessment used commercial vessel sources of information, given that these represent vendors 

that would normally supply UTV owners and/or operators. Where commercial information was unavailable, or 

where UTVs are likely to use recreational vessel sources of equipment, recreational sources were consulted. 

Specifically, the assessment relies on recreational vessel equipment cost data for visual distress signal costs and for 

first aid/trauma kit costs, but uses commercial vessel cost data for all other equipment cost estimates presented. 13 Assuming that the existence of a Web site suggests that the supplier’s audience is nationwide in scope, data were 

obtained from a subgroup of marine equipment suppliers with Web sites. A link popularity tool 

[www.marketleap.com/publinkpop] was applied to the universe of all marine equipment supplier Web sites to justify 

the use of a subset of Web sites as a source of economic data. 
UTV Industry Preliminary Cost Assessment 17 Abt Associates Inc.  August 30, 2006

drydock internal and external inspections of vessels, the cost of renting drydock space, and the 

time required to perform an inspection of vessels. 

Safety Management Systems

Information sources for the SMS section of this report include nine telephone interviews with 

SMS auditors and vessel companies and a leave-behind questionnaire delivered to ports during 

ABS Consulting port visits.14 To comply with ICR requirements, no more than nine interviewees 

or vessel companies were asked for the same information. 

SMS interviewees were selected through Web-site searches and from the AWO RCP auditor list 

to represent a range of geographic regions in the United States. Interviewees were asked a 

variety of questions associated with SMS costs, such as the relative comprehensiveness of the 

SMS process, the method through which SMS fees are determined, factors that impact SMS 

development and/or implementation time and cost, documentation and recordkeeping 

procedures, and external and internal auditing procedures. Both small and large SMS companies 

that prepare SMSs for vessel companies were interviewed. The geographic range of companies 

as well as company size differences yield a broad sample of the SMS auditing industry. 

2.3. Presentation of Results 

For each cost element, quantitative estimates are provided wherever possible; in some cases, 

only qualitative information is available. Quantitative cost estimates are provided as ranges or 

data points, as appropriate. Overall, research demonstrated that some UTVs are more in 

compliance than others, and that some UTVs will require less costly equipment than others to 

come into compliance due to vessel-specific characteristics such as size, area of operation, and 

other characteristics summarized in Exhibit 2 of this report. 

All findings are presented as unit costs. When the Coast Guard proposes new requirements for 

UTVs, these costs can be incorporated into a regulatory impact analysis to evaluate total 

compliance costs for the UTV industry as a whole. 

2.4 Inclusion of Towing Assistance Vessels 

The TSAC RWG recommends the exclusion of towing assistance vessels from future inspection 

requirements; however, it is uncertain whether the new regulations will follow this 

recommendation. For this reason, Appendix B of the report includes an assessment of potential 

impacts to these vessels, to assist the Coast Guard in evaluating the recommended exclusion. 

 

14 “Leave-behind questionnaire” refers to a questionnaire distributed to vessel companies by ABS Consulting during 

port visits, to distinguish it from a shorter questionnaire that was also distributed. After the initial distribution of the 

leave-behind questionnaire yielded just one response, an abbreviated version of the questionnaire was created and 

distributed to the same set of companies. Two responses to the abbreviated version were subsequently received. 

Attachment 4 reproduces the questions asked in both the initial and abbreviated questionnaires. 
UTV Industry Preliminary Cost Assessment 18 Abt Associates Inc.  August 30, 2006

2.5 Caveats to the Preliminary Cost Assessment 

A variety of factors may cause the preliminary cost assessment to overstate or understate actual 

future costs. These factors and their potential impacts on cost estimates are as follows: 

 Uncertainty regarding future regulatory requirements. The Coast Guard has not issued a 

proposed rule, so the specific potential requirements for UTVs are currently unknown. In 

addition, regulations could be scaled according to vessel size, horsepower, type of 

operation, area of operation, number of vessels, and the nature of the risk associated with 

the towing vessel operation. To the extent that future regulatory requirements are either 

more or less stringent than TSAC RWG recommendations, cost estimates contained 

within this report will either be under- or overestimated, respectively. 

 

 Degree to which UTVs are currently in compliance with TSAC RWG recommendations. 

This preliminary assessment does not account for UTVs’ current level of compliance 

with TSAC RWG recommendations. For example, some towing companies are already 

in partial or full compliance with the ISM code; other towing companies may be in 

compliance with and certified by the AWO RCP. If the Coast Guard accepts compliance 

with ISM and/or AWO standards as sufficient in meeting SMS standards for UTVs, UTV 

operations in compliance would not incur SMS costs associated with the regulation and 

those in partial compliance would have reduced costs. To the extent that this is true, 

upper-bound estimates (assuming zero compliance within the industry) will be 

overestimates. 

 Potential grandfathering provisions. If certain UTV regulations are “grandfathered” in 

situations where it is impractical for the Coast Guard to require vessel reconfigurations 

that are prohibitively expensive, such vessels would not incur costs of compliance. 

 UTV characteristics. UTVs vary widely in length, tonnage, age, area and type of 

operation, and construction material (see Exhibit 2). The costs of compliance depend 

significantly on these characteristics. For example, the cost of electrical wiring increases 

with vessel size. Costs of such requirements are presented as ranges to account for 

differing vessel sizes. To the extent that a particular vessel is smaller or simpler, etc., 

than the vessel size designated for the corresponding upper-bound estimate, the upperbound estimate will be overstated. 
UTV Industry Preliminary Cost Assessment 19 Abt Associates Inc.  August 30, 2006

3. POTENTIAL COSTS OF RECOMMENDED EQUIPMENT STANDARDS 

This section presents the potential unit costs of compliance for UTV owners and operators to 

purchase and install sufficient equipment to meet the TSAC RWG recommended standards. 

Potential costs are estimated quantitatively where possible; where quantitative estimates were not 

feasible, a qualitative discussion of cost factors is provided. In addition, costs are presented 

separately for those recommended requirements that differ for new and existing vessels.15 

Finally, costs are presented on a per-unit or per-vessel basis, and are not aggregated to the UTV 

industry. 

Towing vessel design decisions and associated costs of compliance with potential equipment 

standards are based on a large number of factors, including vessel size, area and type of intended 

use, speed, power, and the needs of the particular vessel owner. Accordingly, cost estimates 

obtained from data sources frequently vary, and are presented as ranges where necessary to 

capture a range of costs representative of different vessel types. Potential future costs of 

compliance will also vary with the degree of current compliance on a per vessel basis and within 

the UTV industry as a whole, and with UTV company size. While interview responses suggest 

that many of the recommended standards are met by most towing vessels with which particular 

architects are familiar, there are standards for which there was no consensus on current levels of 

compliance among the sample of interviewees. 

Exhibit 3 provides a range of potential future costs for each recommended equipment standard. 

The following sections provide more detail on the results. In each section, the proposed standard 

from the TSAC RWG is presented in italics and is followed by a discussion of cost information 

obtained from the sources listed above. 

 

15 Exhibit 1 identifies the equipment standards recommended by TSAC RWG specifically for new or existing 

vessels. 
UTV Industry Preliminary Cost Assessment 20 Abt Associates Inc.  August 30, 2006

Exhibit 3 

Summary of Potential Per Vessel Costs of Prescribed Equipment Standards for the UTV Industry 

Standards 

Category Cost Element 

Level of Current 

Compliance [1] 

Potential Per-Vessel Range of Unit Costs to 

Comply with Standard [2] 

New UTVs (Constructed after effective date of regulation) 

Design and construction to American Bureau 

of Shipping (ABS) or other standards High Unknown 

Emergency egress High $7,000 to $15,000 

Steering Variable $10,000 (average) 

Electrical equipment and wiring Variable $21,000 to $708,000 

Hull and 

Machinery 

Electrical generating systems Variable $2,000 to $100,000

Heat or flame detector in galley Unknown $14 to $184 Firefighting Remote manual engine shutdown High $1,500 to $8,000 

Existing UTVs (Constructed prior to effective date of regulation) 

Handrails and bulwarks High $10,000 to $50,000 

Freeing ports and scuppers High $1,000 to $30,000 

Guards for exposed hazards High $20 per linear foot 

Alarms/monitoring and gauges Variable $4,500 to $200,000 

Steering Variable $9,500 to $12,000 

Electrical equipment and wiring Variable Minimal [3] 

Fuel systems High $4,000 to $5,000 

Electrical generating systems Variable Minimal [4] 

Hull 

and 

Machinery 

Lighting High Unknown 

Connect VHF radio to battery backup Unknown $2,000 

Handheld VHF radio Unknown $100 to $300 

Second radar Unknown $3,850 to $6,650 

Rudder angle indicator Unknown $750 to $2,500 

Onboard crew communications Unknown $2,000 to $10,000 

Pilothouse window visibility High $1,000 to $15,500 

Navigation 

and 

Communication 

Emergency communications capability Unknown $200 to $2,000 

Bilge pumps High $5,000 to $80,000 

Oily water separators High $10,600 to $27,800 

Spill kit Unknown $320 to $600 

Pollution 

Prevention 

Closable scuppers Unknown $100 to $17,200 

Visual distress signals Unknown $171 to $504 

First aid kit/trauma kit Unknown $85 to $695 

Immersion suits Unknown $1,060 to $4,260 Lifesaving 

Inflatable life raft Unknown $3,400 to $6,400 

Fire axe Unknown $45 to $65 

Firefighting Smoke alarms Unknown $10 to $70,000 

Placarded storage area Unknown $2,000 

[1] Naval architects and other interviewees were asked about the level of general current compliance of vessels in the UTV industry with 

each recommended requirement. A “high” level of compliance indicates that all interviewees thought that most UTVs were already in 

compliance with the recommended requirement; a “variable” level of compliance indicates that interviewees differed in their statements 

about current levels of compliance; and an “unknown” level of compliance indicates that all interviewees did not know or did not provide 

information on the current level of compliance with the recommended requirement. 

[2] Non-compliance is assumed in calculating cost impacts; therefore, these cost impacts may be overstated to the extent that vessels are 

partly or fully in compliance. 

[3] TSAC’s recommended electrical equipment and wiring requirement for existing UTVs consists of relatively minor actions such as 

labeling and ensuring that all elements are in proper working condition. The analysis assumes that UTV owners/operators already conduct 

appropriate maintenance of electrical equipment and wiring for UTVs in the absence of regulation; therefore, potential costs are assumed to 

be minimal for this recommended requirement and may consist of such activities as labeling of equipment. 

[4] TSAC’s recommended electrical generating system requirement for existing UTVs consists of proper maintenance. The analysis

assumes that UTV owners/operators already conduct appropriate maintenance of these systems for UTVs in the absence of regulation; 

therefore, potential costs are assumed to be minimal for this recommended requirement. 
UTV Industry Preliminary Cost Assessment 21 Abt Associates Inc.  August 30, 2006

3.1 Hull and Machinery 

3.1.1 Design and construction (new vessels only) 

Inland towing vessels built after the effective date of the regulations must be designed and 

constructed in accordance with ABS Rules for Building and Classing Steel Vessels for Service on 

Rivers and Intracoastal Waterways (version in effect as of the date the contract was signed), or 

other published, recognized standards, to be determined. Coastal/ocean towing vessels built 

after the effective date of the regulations must be designed and constructed in accordance with 

ABS Rules for Building and Classing Steel Vessels Under 90 Meters (295 feet) in Length (version 

in effect as of the date the contract was signed), or other published, recognized standards, to be 

determined. Classification by a recognized classification society is not required. 

Vessels constructed after the effective date of the regulations that are essentially sister vessels of 

a class or series of previously built vessels may be constructed to the same design as previously 

built vessels in the class or series, provided that 1) the class or series of vessels has a history of 

safe operation and 2) the new vessels meet all of the requirements outlined in items c) through r) 

below, including the provisions for vessels constructed after the effective date of the 

regulations16

New designs that deviate from applicable ABS Rules for Building and Classing Steel Vessels or 

other published, recognized standards may be permitted if approved by the Coast Guard or a 

recognized classification society. 

Vessel plans must be reviewed and approved by a Professional Engineer with marine expertise. 

Builder must certify that vessel was built in accordance with approved plans. Vessel owner must 

retain a copy of the approved plans in the company office. Plan approvals and builder 

certifications must be available for review by Coast Guard or third-party auditor. 

Existing vessels that undergo substantial modification may be rebuilt as original or to the 

standards above. 

The American Bureau of Shipping (ABS) is a classification society that sets forth standards for 

materials and welding, hull construction and equipment, and vessel equipment and machinery.17 

Vessels that meet these standards are eligible for an ABS-issued certificate of classification. 

This classification, in turn, may be a requirement for vessel insurance.18 

 

16 Items c) through r) in the TSAC RWG correspond to recommended hull and machinery equipment standards in 

Section 3.1 of this report; however, this report does not assess costs of all recommended hull and machinery 

equipment standards contained in the TSAC RWG as per agreement with ABS Consulting and the Coast Guard. 

17 ABS rules applicable to most UTVs are contained within “Rules for Building and Classing Steel Vessels Under 

90 Meters (295 Feet) in Length – 2006” available for download from www.eagle.org. Most vessels over 300 feet in 

length are already currently inspected. 

18 However, vessels can choose to meet ABS standards even if they do not require classification for insurance or 

other purposes. 
UTV Industry Preliminary Cost Assessment 22 Abt Associates Inc.  August 30, 2006

Vessel owners that would not comply with ABS standards in the absence of a regulatory 

requirement would incur costs for this recommended requirement. These costs could include 

labor costs associated with using a marine architect to ensure compliance, the cost of materials 

and equipment required to comply with ABS structural standards, and the cost of ABS plan 

review and surveying where ABS classification is required. 

While a majority of existing vessels do not meet ABS standards, discussions with marine 

architects and experienced towing industry personnel indicate that most new vessels designed by 

reputable marine architects are designed to these standards. However, there are some new 

vessels built by shipyards based on previous vessel designs that would not meet ABS standards. 

Potential costs of this required recommendation are not estimated in this report due to a lack of 

information on the degree to which vessel designs for noncompliant vessels deviate from ABS 

standards; however, the assessment notes that certain vessel owners and/or operators may incur 

costs of compliance associated with bringing new vessels into compliance. 

3.1.2 Handrails and bulwarks 

Rails or equivalent protection must be installed near the periphery of all decks accessible to 

crew. Equivalent protection may include lifelines, wire rope, chains, and bulwarks that provide 

strength and support equivalent to fixed rails. Where space limitations make deck rails 

impractical, such as at the narrow catwalks in the deckhouse sides, hand grabs may be 

substituted. 

The incremental costs of this standard to the UTV industry will depend on the extent to which all 

towing vessels already have bulwarks or handrails. Per vessel costs will depend on a number of 

vessel-specific factors such as the length of the deck accessible to the crew and the extent to 

which hand grabs are substituted for handrail requirements. 

While the percentage of towing vessels that already have bulwarks or handrails is unknown, the 

naval architects interviewed indicated that towing vessels with which they are familiar do have 

handrails or bulwarks. To estimate per vessel costs for UTVs that might not currently be in 

compliance with this recommended requirement, shipyards were consulted for cost estimates 

associated with installing handrails and bulwarks.19 One shipyard stated that providing a cost 

estimate is impossible given the variation of potential costs across vessels. A second shipyard 

noted that the cost of installing a handrail or bulwark may include multiple components, such as 

the cost of materials, surface preparation of the steel, structural modification, and labor costs. 

This shipyard estimated that installing a bulwark on a 35-foot vessel would cost between 

$10,000 and $12,000, while installing a bulwark on a 100-foot vessel would cost between 

$40,000 and $50,000. Similar estimates for installing handrails were not provided by this 

shipyard, but handrails are typically less expensive than bulwarks. Costs for this recommended 

requirement are estimated to range from $10,000 to $50,000 for installing bulwarks depending 

 

19 Shipyards were also consulted regarding the cost of hand grabs. One shipyard stated that there are many variables 

that influence the cost of hand grabs, including length, material, and any required modification of the vessel to 

install the hand grab. This shipyard offered a rough estimate of $1,000 to $2,000 for installing hand grabs on a fivefoot section of a vessel. 
UTV Industry Preliminary Cost Assessment 23 Abt Associates Inc.  August 30, 2006

on vessel size; however, to the extent that handrails are used rather than bulwarks, this range may 

be an overestimate of actual costs. 

3.1.3 Emergency egress 

A towing vessel constructed after the effective date of the regulations must have at least two 

means of egress from the engine room and the overall crew accommodations area. This does not 

mean individual spaces, such as staterooms, within the accommodations area. Doors and escape 

hatches must be operable from either side. The lower section of the engine room must be 

provided with at least two means of egress to the upper engine room or the exterior of the vessel. 

Interviews with naval architects suggest that this requirement is currently met by most towing 

vessels. Two of the naval architects indicated that small towing vessels might not currently be 

designed with two means of egress from the lower engine room to the upper engine room, 

because the lower engine room in small towing vessels is very small. Small towing vessels may 

also not have two-level engine rooms. 

Conversations with shipyards indicated that the potential per vessel costs of meeting this 

requirement may depend on the method through which two means of egress is achieved on the 

vessel. One shipyard noted that parts and installation for an escape hatch and ladder would cost 

between $7,000 and $8,000. Another shipyard stated that this requirement would usually be met 

using a vertical escape trunk, which would cost approximately $15,000. Per vessel costs for this 

recommended requirement are therefore estimated to range from $7,000 to $15,000. 

3.1.4 Freeing ports and scuppers 

For each towing vessel that is fitted with installed bulwarks around the exterior of the main deck, 

sufficient freeing ports and/or scuppers must be provided and maintained to allow water to run 

off the deck quickly without adversely affecting the stability of the vessel. 

All interviewees stated that towing vessels that have bulwarks generally have sufficient freeing 

ports or scuppers to allow water to run off the deck quickly. To the extent that this is true of all 

vessels within the UTV industry, this requirement would have a marginal impact on the industry. 

Individual vessels that do not have sufficient freeing ports or scuppers will incur costs of meeting 

this recommended requirement. One shipyard noted that adding a freeing port or scupper in an 

open bulwark would cost approximately $1,000. In a closed bulwark, the cost would range from 

$2,000 to $2,500. Small vessels have fewer scuppers than larger vessels, which may have up to 

twelve. Costs are therefore assumed to range from $1,000 to $30,000 (twelve scuppers at $2,500 

each) per vessel for this recommended requirement. 

3.1.5 Guards for exposed hazards 

An exposed hazard, such as gears or rotating machinery, must be properly protected by a cover, 

guard, or rail. 
UTV Industry Preliminary Cost Assessment 24 Abt Associates Inc.  August 30, 2006

Most interviewees indicated that this standard would already be met by most towing vessels 

because vessels typically contain guards for exposed hazards; however, where the requirement is 

not met, guards could be engineered in a wide variety of ways for a wide variety of exposed 

hazards, leading to a wide range in potential costs for non-compliant vessels. For this reason, 

shipyards provided examples of the costs of installing guards around specific exposed hazards, 

but were unable to provide a general per vessel cost for this required recommendation. 

One shipyard stated that it may cost $3,500 to build a guard for a towing winch, while another 

shipyard stated that a sheet metal guard around a rotating coupling may cost $1,500. One naval 

architect also stated that a guardrail could be installed at the cost of $20 per linear foot; however, 

the number of feet required per vessel is unknown for the reasons previously listed. Given the 

significant uncertainty surrounding potential costs associated with this recommended 

requirement on a per vessel basis, a specific range of costs is not provided. Rather, potential 

costs are assumed to vary considerably across all UTVs. 

3.1.6 Alarms/monitoring and Gauges 

Each towing vessel must be equipped with an alarm system that includes main engine lubricating 

oil pressure, main engine cooling water temperature, auxiliary generator engine lubricating oil 

pressure, auxiliary generator engine cooling water temperature, hydraulic steering fluid levels, 

and bilge levels. Alarms must be audible and visible at the primary operation station. 

Each towing vessel must be equipped with gauges for the following: main engine lubricating oil 

pressure, main engine cooling water temperature, auxiliary generator engine lubricating oil 

pressure, auxiliary generator engine cooling water temperature, and hydraulic steering fluid 

pressure if equipped with hydraulic steering systems. Gauges must be accessible to crewmembers for monitoring. 

The extent to which towing vessels already meet the alarm requirement is unknown. Three 

interviewees indicated that most towing vessels currently have these alarms. Two other 

interviewees indicated that alarms for hydraulic steering fluid levels, main and auxiliary engine 

lubricating oil pressure, and main and auxiliary engine cooling water temperature are standard, 

but that bilge level alarms and gauges are present on only some towing vessels. Similar to the 

recommended alarm standard, the impact at the industry level of requiring gauges for oil 

pressure, cooling water temperature, and steering fluid pressure on towing vessels is unknown 

due to disagreement over current levels of compliance. Most interviewees indicated that 

virtually all new vessels already have these gauges, while one said that vessels frequently do not 

have these gauges, but have alarms and warning lights. Further, one interviewee said that older 

vessels often do not have these gauges. For this reason, it is possible that some UTVs will 

already have alarm systems, but will require adding gauges to the alarm system in order to 

comply with this recommended requirement. 

 

While some UTVs may require adding gauges to an existing alarm system, interviewees 

provided combined costs for this recommended requirement because alarm systems and gauges 

are typically installed together. The cost estimates provided varied significantly. One 

interviewee noted that the cost of a bilge level alarm and gauge varies with vessel size, but 
UTV Industry Preliminary Cost Assessment 25 Abt Associates Inc.  August 30, 2006

averages approximately $4,500. One shipyard stated that it would cost between $10,000 and 

$12,000 to add the recommended gauges and alarms to a vessel. Another shipyard noted that 

there is a wide variety of quality and complexity, and therefore costs, among different systems. 

This shipyard stated that purchasing and installing a simple system would cost between $30,000 

and $40,000, while a complex system may cost between $100,000 and $200,000. However, the 

high-end estimate of this range is likely to be rare because a vessel requiring this type of 

equipment would be a large, relatively expensive vessel which would probably already contain 

the recommended requirement. In addition, costs for vessels that have to add gauges to an 

existing alarm system would be lower than the combined cost estimates provided. Overall, the 

cost range for an alarm and gauge system to meet the recommended requirements for alarms and 

gauges are estimated to range from $4,500 to $200,000. 

3.1.7 Steering 

A towing vessel constructed after the effective date of the regulations must be equipped with two 

independently operating sources of power (e.g., two steering pumps and two fluid reservoirs) for 

the steering system. Each source of power must be capable of operating the entire steering 

system. 

An existing towing vessel that has only one source of power for the steering system must have an 

emergency backup system or process that will allow the vessel to be moved to a safe location in 

the event of a steering failure.

Cost estimates for this recommended requirement as applied to new towing vessels vary widely, 

based primarily on differing assumptions regarding the degree of current compliance in the UTV 

industry and on vessel size. For example, one interviewee stated that two independent sources of 

power for the steering system are not standard on towing vessels, while one interviewee stated 

that fully independent sources of power are common in large towing vessels, but are rare in small 

vessels such as harbor tugs. Yet another two interviewees indicated that this potential 

requirement is normally met on large vessels, as it is a requirement for vessel inspection and 

classification; however, the potential requirement is not currently met on some smaller towing 

vessels. In contrast, two interviewees suggested that all towing vessels would probably meet this 

requirement. While some small vessels may not meet the requirement, one interviewee 

suggested that the additional cost of meeting this requirement on a small vessel would be 

relatively low. 

The cost of steering equipment depends on the size of the vessel, the size of the rudder(s), and 

the speed at which the vessel travels. One interviewee suggested that having two independent 

sources of power for the steering system would add approximately $10,000 on average to the 

cost of a new vessel. This interviewee further estimated that retrofitting a vessel with only one 

source of power for the steering system with a backup source of power would cost approximately 

$7,500 to $10,000 for materials and $2,000 for installation, yielding a range of $9,500 to 

$12,000. Therefore, potential per vessel costs for this recommended requirement are estimated 

to be $10,000 on average for new vessels, and to range from $9,500 to $12,000 per vessel for 

existing vessels. 
UTV Industry Preliminary Cost Assessment 26 Abt Associates Inc.  August 30, 2006

3.1.8 Electrical equipment and wiring standards 

A towing vessel constructed after the effective date of regulations must have electrical equipment 

and wiring that meet the standards of 46 CFR subchapter L or appropriate equivalent standard. 

For existing towing vessels, all electrical equipment and wiring must be maintained in good 

operating condition such that no fire hazards or other hazards to personnel are present. All 

wiring terminations must be made in junction boxes or other electrical fixtures suitable for the 

purpose intended. All machinery switches, energizers, and circuit breakers must be labeled and 

maintained in good operating condition. When electrical equipment or wiring must meet UL 

Marine standards or an appropriate equivalent standard. 

Impact and cost estimates for this recommended requirement vary widely. While new UTVs 

owners/operators may incur costs of installing electrical equipment and wiring that is more 

expensive than what they would have installed in the absence of regulation, cost impacts to 

existing vessels may be limited to such actions as labeling machinery switches, energizers, and 

circuit breakers. In addition, the extent of cost impacts to new UTVs will vary according to the 

type of system that would have been installed in the absence of regulation. For example, while 

one interviewee stated that wiring on towing vessels designed by his company frequently 

complies with ABS standards or an Institute of Electrical and Electronics Engineers (IEEE) 

standard, which appears to meet this requirement, two interviewees indicated that towing vessel 

wiring is not typically done to the specifications of a particular standard. Another interviewee 

suggested that wiring might be done to standard for large vessels but not for small vessels. 

As stated above, cost estimates for this recommended requirement vary according to the extent 

of new construction required for new vessels. One interviewee stated that wiring relatively small 

vessels to meet a standard would add at least $20,000 to $30,000 to the cost of the vessel, and 

that large vessels would already meet the requirement. By contrast, a second interviewee 

indicated that the additional cost of vessel wiring to comply with a standard would be small. 

One shipyard stated that electrical systems on vessels are usually designed and constructed to 

this standard, but that it is impossible to separate the cost of meeting the standard from the total 

cost of installing an electrical system on a vessel, which may range from $500,000 to $700,000. 

Another interviewee stated that an additional cost of this requirement would be the cost of 

engineering and plan submittal required to document compliance with the standard, which may 

range from $1,000, for the simplest towing vessel, to $8,000 for the most complex. The 

assessment adds estimated electrical system costs to documentation costs to estimate per vessel 

costs for this recommended requirement of $21,000 to $708,000 for vessels constructed after the 

date of regulation. Under regulation, existing vessels would incur marginal costs of labeling and 

other maintenance activities. 

3.1.9 Fuel systems 

Vessels whose construction was contracted for after January 18, 2000, must comply with the 

requirements for fuel systems at 46 CFR 27.211. 
UTV Industry Preliminary Cost Assessment 27 Abt Associates Inc.  August 30, 2006

For all towing vessels, the fuel systems for the vessel and for main engine propulsion and 

auxiliary generator systems must be maintained in good operation condition. Each towing vessel 

must be able to supply clean fuel to the main engines and auxiliary generator engines via a 

filtering system that may include filters, a centrifuge, and/or a day tank. A towing vessel 

equipped with a day tank must be equipped with a low fuel level alarm. 

Because the fuel filter on vessels eventually becomes fouled, TSAC recommends that UTVs 

either have multiple fuel filters or the ability to rapidly change the fuel filters. All marine 

architects contacted indicated that all towing vessels have systems to supply clean fuel to the 

engines; for this reason, current compliance in the UTV industry is considered high. According 

to these individuals, most vessels accomplish this using fuel filters. Two shipyards also stated 

that all towing vessels have fuel filters that can be changed while the vessel is underway. One 

shipyard stated that most towing vessels accomplish this standard using duplex filter systems, but 

some larger vessels may use a centrifuge for fuel filtration. One shipyard stated that if a vessel 

did not have this capability, adding a duplex valve system may cost between $4,000 and $5,000. 

A centrifuge would cost considerably more, in the tens of thousands of dollars. 

3.1.10 Electrical generating systems 

A towing vessel constructed after the effective date of the regulations must be equipped with two 

electrical generating systems. Each electrical generating system, regardless of type, must be 

capable of carrying the essential electrical load of the vessel under normal operating conditions. 

Electrical generating systems on existing towing vessels must be maintained in good operating 

condition. 

Impact and cost estimates for this recommended requirement vary widely. One interviewee 

indicated that this requirement is frequently not met, while another stated that new vessels 

generally have two electrical generating systems, but that very small towing vessels may not. 

Another interviewee stated that a backup generator is included on all vessels that his company 

designs. Given differences in interviewee comments on current compliance, the overall level of 

current compliance with this recommended requirement in the UTV industry is unknown. 

Per-vessel cost estimates provided for this recommended requirement for new UTVs range from 

$2,000 for a backup generator to $100,000 or more for an additional generator, switchboard, 

exhaust system, and cooling system. Actual costs incurred for new UTVs will depend on the 

degree of current compliance of the vessel design with the recommended requirement. Existing 

UTVs are likely to require minimal maintenance costs in excess of maintenance costs incurred 

by vessel owners/operators in the absence of regulation. 

3.1.11 Lighting 

A towing vessel must be equipped with appropriate illumination in crew work areas. 

All interviewees indicated that virtually all towing vessels are constructed with appropriate 

illumination in crew work areas. Two shipyards contacted were unable to provide specific per 

vessel costs of lighting to meet this standard, stating that there are too many variables that may 
UTV Industry Preliminary Cost Assessment 28 Abt Associates Inc.  August 30, 2006

determine potential costs on a per vessel basis; however, the costs may be similar to costs of 

wiring. 

3.2 Navigation and Communication Equipment 

3.2.1 Capability of connecting a VHF radio to battery backup 

At least one VHF radio required under 33 CFR 164.72(a)(3) must be installed at the operating 

station in the pilothouse and connected to a properly operating battery backup. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Where UTVs are not in compliance, one towing vessel company employee stated that 

the cost of connecting a VHF radio to battery backup is approximately $2,000. Much of this cost 

derives from the fact that the backup battery will slowly lose charge and thus needs to be wired 

into the ship’s main power supply for trickle charging. 

3.2.2 Handheld VHF radio 

Each towing vessel must have at least one properly operating handheld VHF radio. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Several vendors supply handheld VHF radios, with prices varying from $100 to $300 

depending on the make and type. Variables affecting price include size, display, battery life, 

durability, water-resistance (splash-proof or submersible), and the ability to receive weather 

alerts. High-end models include additional features such as sending GPS coordinates with 

distress calls. 

3.2.3 Second radar 

Each towing vessel that operates on oceans, near coastal, or on Great Lakes routes more than 

12 miles from shore, must be equipped with second radar.20 The second radar must meet the 

requirements of the Federal Communications Commission specified by 47 CFR part 80, and 

TRCM Standard for Marine Radar Equipment Installed on Ships of Less than 300 Tons Gross 

Tonnage, TRCM Paper 71-95/SC 112-STD, Version 1.1, display Category II and stabilization 

Category Bravo.

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Radar systems are available from several online recreational marine vendors and 

range in price from $1,000 to $2,500; however, these recreational cost estimates may be low for 

UTVs. Variables affecting the price of recreational radars include display quality, range, waterresistant, and automatic image optimization software. 

A representative from the marine electronics industry indicated that radars are not made 

differently for commercial and recreational use, but that they do come in a wide range of models, 

with varying strength, range, resolution, and other specifications. Exhibit 4 summarizes cost 

 

20 The first radar is required on vessels by 33 CFR 164.72(a)(1). 
UTV Industry Preliminary Cost Assessment 29 Abt Associates Inc.  August 30, 2006

information for two radars recommended by this individual. As shown, per vessel costs for 

radars that meet this recommended requirement are estimated to range from $3,850 to $6,650. 

Exhibit 4 

Sample Radar Costs 

Model Price 

Installation 

Cost 

Total 

Cost 

Dome Model (smaller vessels) $3,200 $650 $3,850 

Array Model (larger vessels) $6,000 $650 $6,650 

3.2.4 Rudder angle indicator or means to visually indicate rudder position 

Each towing vessel must be equipped with a rudder angle indicator if it is fitted with non-followup steering gear. Towing vessels fitted with follow-up type of steering are not required to have a 

separate rudder angle indicator as long as the position of the towing vessel’s rudders is 

appropriately indicated by the relative position of the steering levers. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Costs for rudder angle indicator (RAI) systems vary by vessel size: smaller vessels 

would generally use a “Standalone RAI System,” which may cost approximately $750, while 

larger vessels would generally use a “Panoramic Read-out System,” which may cost 

approximately $2,500. The majority of the total cost (and cost variation) is installation-related 

and depends on factors such as rudder shape, whether the installation company has outfitted 

similar vessels previously (and already has an established installation plan), and the amount of 

wiring required. Large vessels with many waterproof bulkheads can be especially expensive, 

because water-proofness must be restored after the cable has been run. Retrofits are likely to be 

less expensive than new installations, because some of the wiring may already be in place. 

3.2.5 Onboard crew communications 

Each towing vessel must have an internal communication system or other means of 

communication that allows the vessel operator to communicate with crewmembers on watch. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Advanced onboard crew communications systems may not be necessary for small 

vessels on which all crewmembers are within earshot of the others. On larger vessels, 

communication typically involves a PA system with speakers in several locations throughout the 

vessel, and a warning light that activates in the engine room (because announcements cannot be 

heard over the sound of the machinery). 

One interviewee estimated $5,000 to $10,000 to outfit a large vessel with an onboard crew 

communications system. Another interviewee estimates this system would cost $1,000 to $2,000 

for equipment, and $1,000 to $5,000 for labor, depending on factors including the difficulty of 

the wiring and the size of the vessel, yielding a range of total costs of $2,000 to $7,000. Per 
UTV Industry Preliminary Cost Assessment 30 Abt Associates Inc.  August 30, 2006

vessel costs for this recommended requirement are therefore estimated to range from $2,000 to 

$10,000. 

3.2.6 Means of ensuring visibility through pilothouse windows 

Each towing vessel must have a means of ensuring that the window immediately forward of the 

steering station in the wheel house allow for adequate visibility to ensure safe navigation. 

According to TSAC, the main components of the recommended pilothouse visibility system are 

windshield wipers and defogging/defrosting capabilities installed for the window immediately 

forward of the steering station in the wheelhouse. The size of this window will most likely 

determine the method selected to achieve this recommended requirement: oceangoing vessels 

tend to have smaller windows and are more likely to use window heaters whereas inland vessels 

tend to have larger windows and are more likely to use warm air blowers for defogging. For this 

reason, potential costs of meeting this recommended requirement will vary according to the 

vessel’s specific characteristics. In addition, vessels are likely to already be equipped with a 

means of ensuring visibility through pilothouse windows, as this is a standard and practical 

feature for a vessel. 

A system for ensuring visibility through the pilothouse window may include several components, 

including heat and defogging equipment, wiper kits, and de-icing sprays; however, it is uncertain 

whether all of these components will be required as part of future UTV regulations. Industry 

estimates for these components vary widely, from $1,000 to $15,500. For example, an estimated 

price for a 4-wiper system suitable for a large vessel of over 100 feet, with wash capabilities, 

wiring, and controls, is roughly $15,500. For this system, the wash capability is over 50 percent 

of the cost, because it requires piping from a water source. Estimates for minimal systems on 

small vessels are much lower, ranging from $1,000 to $3,000. 

3.2.7 Emergency communications capability 

Each towing vessel must maintain an emergency communications capability appropriate for the 

vessel’s area of operation. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. As suggested by the recommended requirement, the appropriate emergency 

communications system will vary based on the vessel’s area of operation. Interviewees 

suggested that one to two handheld VHF radios were sufficient within the United States or in 

U.S. coastal waters, ranging in cost from $200 to $500 each. Several other systems include 

emergency position indicating radio beacons (EPIRGs), which broadcast identifying information 

if a vessel sinks, and satellite communications systems, each of which may cost approximately 

$2,000. Per vessel cost of this recommended requirement are therefore estimated to range from 

$200 to $2,000. 
UTV Industry Preliminary Cost Assessment 31 Abt Associates Inc.  August 30, 2006

3.3 Pollution Prevention Equipment 

3.3.1 Bilge pumps or other dewatering capability 

All towing vessels must have either an installed bilge pump or another method for emergency 

dewatering, such as a portable pump with hoses. 

The price of dewatering systems is a function of variables such as pump size, vessel type, and 

number of vessel compartments and their location. Water pumped from vessel compartments 

must be piped out through the hull, making installation costs very specific to individual vessels 

and setups. Pumping also has an electrical impact, requiring switchboard modification in many 

cases and sufficient generator capacity. Most UTVs are expected to already be in compliance 

with this recommended requirement. 

While large towing vessels that do not have a bilge pump or other dewatering capability may 

incur costs from $10,000 to $80,000, a commercial tugboat might incur costs for bilge pumps at 

a cost of $5,000 per vessel. One interviewee suggested a cost of $43,000 for a 130-foot vessel, 

which falls within the range mentioned previously. Per vessel costs of this recommended 

requirement are therefore estimated to range from $5,000 to $80,000. 

3.3.2 Oily Water Separators (OWS) 

The requirement to manage oily waters already applies to UTVs as stated at 33 CFR 155.350, 

155.360, 155.370, and 155.380.21 Vessels may comply with the requirement by either storing 

oily water onboard and discharging to specified locations, or by using an oily water separator. 

While this requirement already applies to UTVs, the Coast Guard requested that cost estimates 

associated with oily water separators be included for purposes of this preliminary cost 

assessment. 

Exhibit 5 provides cost estimates for typical OWS systems. As shown, costs vary with the size 

and model of the OWS. In addition to the cost of the system, installation and training may range 

from at least $800 to $900 per day, and may take one to two days. 

 

21 33 CFR 155.350 applies to oily mixture (bilge slops)/fuel oil tank ballast water discharges on oceangoing ships of 

less than 400 gross tons; 155.360 applies to oily Mixture (bilge slops) discharges on oceangoing ships of 400 gross 

tons and above but less than 10,000 gross tons, excluding ships that carry ballast water in their fuel oil tanks; 

155.370 applies to oily mixture (bilge slops)/fuel oil tank ballast water discharges on oceangoing ships of 10,000 

gross tons and above and oceangoing ships of 400 gross tons and above that carry ballast water in their fuel oil 

tanks; and 155.380 contains oily-water separating equipment, bilge alarm, and bilge monitor approval standards. 
UTV Industry Preliminary Cost Assessment 32 Abt Associates Inc.  August 30, 2006

Exhibit 5 

Typical OWS Equipment Cost Estimates 

Models for OWS 

Size of OWS USCG certified MEPC 60(33) [1] USCG certified MEPC 107(49) [2] 

2 Gallons per 

Minute (GPM) 

$5,600 to $9,500 $9,800 to $26,000 

5 GPM $83,00+ $12,700+ 

Notes: 

[1] This system was the standard prior to January 2005, but can be still used by boats under 400 

gross tons. 

[2] This system is the new standard after January 2005. 

To estimate potential per vessel costs of meeting this recommended requirement, the assessment 

assumes that UTVs will be required to have USCG-certified MEPC 107(49) OWS system, which 

is the currently active standard. As shown in Exhibit 5, the cost of such a system may range 

from $9,800 to $26,000. Assuming a lower-bound estimate of installation and training of $800 

and an upper-bound estimate of $1,800 ($900 per day for two days), the assessment estimates a 

range of per vessel costs for this recommended requirement of $10,600 to $27,800. 

3.3.3 Spill kit 

During fueling operations, each towing vessel must have ready for immediate use equipment and 

supplies to clean up and remove an on-deck oil spill of at least one barrel. The equipment and 

supplies must include sorbents; non-sparking hand scoops, shovels, and buckets; containers 

suitable for holding recovered waste; emulsifiers for deck cleaning; and protective clothing. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Recommended oil spill kits typically include absorbents, containers, and protective 

goggles, are sold commercially, and cost between $200 and $350. The kits generally do not 

contain non-sparking scoops and shovels, emulsifiers, and full-body protective clothing, which 

may be purchased separately. Tyvek disposable full-body protective suits are available for $10 

to $20, depending on size. Non-sparking shovels are available for $20 to $50, depending on 

length, capacity, and strength. Non-sparking scoops are available for under $10 each. 

Purchasing two of each item, which is standard in larger-volume spill kits that do include scoops 

and shovels, may cost between $80 and $160. A high-end emulsifier (Hydroclean HT-504) is 

$90 for a five-gallon container; on non-porous surfaces, Hydroclean’s HT-40 is sufficient at $40 

for five gallons. Adding the costs of recommended spill kit components, the total per vessel cost 

incurred for an appropriately stocked spill kit to comply with this recommended requirement 

may range between $320 and $600. 

3.3.4 Closable scuppers or other containment method 

Each towing vessel must be capable of preventing spills to the deck during oil or fuel transfers 

from reaching the water, whether by 1) pre-closing of the scupper/freeing ports, if the vessel is 

so equipped, or 2) pre-deploying absorbent booming/pads on the deck around vents and fills. 
UTV Industry Preliminary Cost Assessment 33 Abt Associates Inc.  August 30, 2006

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Two possible options can contain oil flow during oil transfer operations: closeable 

scuppers or the use of absorbents to block the flow of oil from the deck. A common method 

currently in use involves plugging gunwale scuppers with an appropriately sized piece of wood 

or metal. Larger vessels may have drains with special valves on the deck that run through the 

vessel and drain overboard. A typical large vessel might have four such drains; smaller vessels 

would have only gunwale scuppers that could be blocked by wood or metal. 

The cost of the required absorbents may range from $100 for a small vessel to $1,000 for a large 

vessel. In both cases, the absorbents would require replacement only in the event of a spill. 

Large vessels with deck drains would need special valves installed to block the flow of oil 

(regardless of the choice between absorbents and closeable scuppers). Costs may include $300 

per valve for equipment and $1,000 per valve for installation, yielding a total of $1,300 per 

valve. The number of drains per vessel varies, but a typical large vessel might have four drains 

requiring valves, yielding a total of $5,200 for deck drain valves. 

 

Large vessels may choose to use closeable scuppers instead of absorbents. The cost to make a 

scupper closeable is approximately $1,000 per scupper. The number of scuppers per vessel 

varies, but a large vessel may have 12 scuppers, yielding a total cost of $12,000 to equip a large 

vessel with closeable scuppers. Vessels with closeable scuppers would not require the 

absorbents discussed above. Rather than install closeable scuppers, interviews suggested that 

small towing vessels likely use absorbents or blocks. 

Exhibit 6 summarizes costs of closeable scuppers and other containment methods discussed. As 

shown, costs will vary depending on the size of the vessel and the method of containment 

selected. Exhibit 6 shows a range of potential per vessel costs for this recommended requirement 

of $100 (small vessels) to $17,200 (large vessels). 

 

Exhibit 6 

Summary of Potential Containment Costs 

Containment Method 

Large Vessels With Deck 

Drains Small Vessels 

Choosing to use 

absorbents 

$1,000 absorbents 

$5,200 deck drains 

$6,200 total $100 absorbents 

Choosing to use closeable 

scuppers 

$5,200 deck drains 

$12,000 scuppers 

$17,200 total 

N/A 
UTV Industry Preliminary Cost Assessment 34 Abt Associates Inc.  August 30, 2006

3.4 Lifesaving Equipment 

3.4.1 Visual distress signals 

Each towing vessel operating on oceans, near coastal, or on Great Lakes routes, must carry six 

red flares and six smoke distress signals. Each towing vessel operating on lakes, bays, and 

sounds must carry three red flares and three smoke distress signals. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Red flares range in cost from $15 to $42, depending on intensity, yielding a total 

potential cost per vessel of $45 to $252. Smoke distress signals cost approximately $42, yielding 

a total potential cost per vessel of $126 (assuming three signals) to $252 (assuming six signals). 

Given uncertainty associated with vessel operating areas, the costs per flare and signal, per vessel 

costs are estimated to range from $171 to $504 for this recommended requirement. 

3.4.2 First aid kit/trauma kit 

Each towing vessel must be equipped with an industrial type first aid cabinet/kit appropriate to 

the size of the crew. A vessel operating on oceans, near coastal, or Great Lakes routes must 

have a means to take blood pressure readings, provide splints for broken bones, and provide 

large bandages for serious wounds. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Exhibit 7 summarizes costs for typical first aid kits, which vary based on area of 

operation and kit components. As shown, per vessel costs for this recommended requirement are 

estimated to range from $85 to $695. 

Exhibit 7 

Summary of Typical First Aid Kit Costs 

Type of First Aid Kit Price 

Designed for use while at sea or in a remote harbor, but within 24 

hours of medical care. Includes required blood pressure cuff, splints, 

and bandages. 

$630 

Designed for voyages over 48 hours away from professional help. 

Contains required blood pressure cuff, splints, and bandages. $695 

Contains major wound treatment module, fractures module. Does not 

contain blood pressure cuff. Manual and automatic blood pressure 

monitors are available for $15-$100. 

$85 

3.4.3 Immersion suits 

Each towing vessel operating on oceans, near coastal, or on Great Lakes routes whose voyage 

takes it above Latitude 32 degrees North, must carry an appropriately sized immersion (survival) 

suit for each person onboard. 
UTV Industry Preliminary Cost Assessment 35 Abt Associates Inc.  August 30, 2006

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Immersion suits vary in price based on quality, material, and added features. Less 

expensive survival suits tend to be one-piece neoprene suits. The drawbacks of these suits 

include deterioration over time, difficulty putting the suit on, and reduced dexterity to the wearer. 

The Mustang Ocean Commander, a high-end suit, is not made of neoprene; instead it has a 

urethane coated nylon shell, with closed-cell foam for insulation and buoyancy. It is warmer, and 

contains removable gloves and replaceable components. 

Immersion suits that meet the SOLAS standards and are Coast Guard-approved cost between 

$265 and $710. Given an average crew size of four to six, the total cost of immersion suits per 

vessel may range from $1,060 to $4,260. 

3.4.4 Inflatable life raft 

Each towing vessel operating on oceans, near coastal, or on Great Lakes routes more than one 

mile from shore, must carry an inflatable life raft appropriate for the number of persons on 

board. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Life rafts vary in cost, based on the quality of material of the raft and its components 

and the quality of construction, both of which influence the durability of the rafts. Importantly, a 

more expensive life raft may have a better, more advanced design, which can improve the raft’s 

ease of use. 

A SOLAS-certified life raft would meet or exceed regulations for towing vessels. An estimated 

average cost of a four-person life raft, including a cradle and hydrostatic release for mounting 

and installing the life raft, is $3,400. A six-person life raft with similar specifications ranges 

from $5,200 to $6,400. Given uncertainty associated with crew size on each UTV vessel, per 

vessel costs for this recommended requirement are estimated to range from $3,400 to $6,400. 

3.5 Firefighting Equipment 

3.5.1 Fire axe 

Each towing vessel must be equipped with at least one fire axe that is readily accessible for use 

from the exterior of the vessel. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. The average price of a fire axe ranges from $45 to $65, which is the estimated range 

of per vessel costs for this recommended requirement, assuming that each vessel purchases one 

axe. 

3.5.2 Smoke alarms to protect all sleeping spaces 

Each towing vessel must be equipped with a means to detect smoke in the sleeping spaces and 

lounges that will alert individuals in those spaces. This can be accomplished via an installed 
UTV Industry Preliminary Cost Assessment 36 Abt Associates Inc.  August 30, 2006

detection system or by using individual battery-operated detectors. Detection systems or 

individual detectors must be kept in operational condition at all times. 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Residential smoke alarms are typically different than commercial smoke alarm 

systems in both specifications and price. Residential smoke alarms range in price from $10 to 

$40, while smoke alarm systems provided by specialist companies may range in price from 

$60,000 to $70,000 for the whole vessel or $15,000 to $20,000 for the sleeping accommodation 

areas of the vessel only. One shipyard stated that residential smoke alarms could be used on 

towing vessels, while another shipyard stated that these vessels may use specialized smoke alarm 

systems. Given the range in smoke alarms vessels may be able to use, per vessel costs are 

estimated to range from $10 to $70,000 for this recommended requirement. 

3.5.3 Heat or flame detector in galley 

Each towing vessel constructed after the effective date of the regulations and equipped with a 

galley must have a heat or flame detector with an audible alarm at the primary operating 

station. (Galley = a space containing appliances with cooking surfaces that may exceed 250 

degrees Fahrenheit). 

The current level of compliance with this recommended requirement in the UTV industry is 

unknown. Heat detectors vary in price according to their specifications, as summarized in 

Exhibit 8. As shown, given the range of available heat detectors, costs may range from $14 to 

$184 per vessel for this recommended requirement, assuming that each vessel uses only one 

detector at the primary operating station. 
UTV Industry Preliminary Cost Assessment 37 Abt Associates Inc.  August 30, 2006

Exhibit 8 

Summary of Costs of Typical Heat Detectors

Relevant Specifications Price 

135°F fixed temperature/rate-of-rise $14 

194°F fixed temperature/rate-of-rise $14 

Signals alarm if temperature > 135 F or rate of temperature increase > 

15 F/minute $47 

Heat detector signals if temperature is > 140°F. Horizontal Flush Unit. $184 

3.5.4 Remote manual engine shutdown 

Each towing vessel constructed after the effective date of the regulations must have a remote 

manual main engine shutdown for each main engine and auxiliary generator engine, which can 

be operated from a location outside the machinery spaces where engines are located. The 

required fuel shutoff may serve as this shutdown if each engine is fitted independently.

According to the interviewees consulted for this analysis, a remote manual engine shutdown is 

already standard equipment on towing vessels and therefore would impose little to no additional 

cost to the industry.22 Individual vessels that do not meet the standard will, however, incur costs. 

One shipyard stated that the cost of installing remote manual engine shutdown on a towing 

vessel ranges from $1,500 to $2,000. Another shipyard stated that, while almost all towing 

vessels have this feature, installing it would cost approximately $6,000 to $8,000. Taking both 

cost estimates into account, the per vessel cost of this recommended requirement is estimated to 

range from $1,500 to $8,000.

3.5.5 Placarded storage area appropriate for flammable products 

Placarded storage area appropriate for flammable products. A towing vessel that has paints, 

coatings, or other flammable products on board must have a designated storage area for 

unopened containers of flammable products. Previously opened containers of flammable 

products should be located away from ignition sources, and protected by a nearby fire 

extinguisher. 

One shipyard stated that a storage cabinet for flammable materials may cost $1,000, and 

installation may cost another $1,000, yielding a total potential cost of $2,000. Signs vary in price 

from $2.50 to $11 per sign, or $6.75 per sign on average. Per vessel costs of one placarded 

storage area with one sign are therefore estimated to be roughly $2,000 for this recommended 

requirement. 

 

22 Fuel shutoff requirements are described at 46 CFR Part §27.340(f) as follows: “A positive shut-off valve must be 

fitted on any fuel line that supplies fuel directly to an engine or generator to stop the flow of fuel in the event of a 

break in the fuel line. The valve must be located near the source of supply (for instance, at the day tank, storage 

tank, or fuel-distribution manifold). Furthermore, the positive shut-off valve must be operable from a safe place 

outside the space in which the valve is located. Each remote station for fuel shut-off should be marked in clearly 

legible letters at least 25 millimeters (1 inch) high indicating the purpose of the valve and the way to operate it.” 
UTV Industry Preliminary Cost Assessment 38 Abt Associates Inc.  August 30, 2006
UTV Industry Preliminary Cost Assessment 39 Abt Associates Inc.  August 30, 2006

4. DRYDOCKING 

 

Recommended drydocking procedures contained within the TSAC RWG specify drydocking 

intervals and inspection components/standards required during each drydock as follows: 

 

Intervals: 

Drydocking intervals should be based on time of service in salt water. The most restrictive 

schedule would require inspections twice in five years, with no more than three years between 

inspections. Five-year intervals shall be permitted for vessels in fresh water service. A vessel will 

be deemed to be in fresh water service if it has operated in fresh water for at least six months in 

every 12-month period since the last required drydocking. 

Underwater inspections in lieu of drydocking may be permitted for alternating examinations if 

no obvious defects are present and the vessel has a satisfactory operating record. 

A drydocking that meets the standards below, conducted within the specified intervals, will 

satisfy this requirement. Drydocking due dates will be based on the last drydocking conducted 

that meets the standards below. 

Components/Standards: 

Towing vessels required to have a loadline will be considered to meet the requirements below for 

hull and seachest examinations only. Towing vessels whose hull is classed by a recognized 

classification society will be considered to meet all the drydocking requirements specified below. 

For other towing vessels, a drydocking for regulatory credit must satisfy the following 

requirements: 

 The vessel owner or operator shall ensure that all components that affect the safe 

operation and hull integrity of the vessel are inspected. 

The vessel owner or operator must maintain documentation of: 1) the condition of the 

hull, underwater propulsion, and steering system as inspected; and 2) all repairs and 

alterations to the hull, underwater propulsion, and steering systems. Documentation must 

be retained for review by the Coast Guard or approved third-party auditor. 

At a minimum, the following inspections shall be performed and documented: 

 Hull: Inspect on drydock the hull bottom, sides, headlog and stern for indentation, 

fractures, holes, and other deficiencies that may affect the watertight integrity of the 

vessel. Assess by appropriate means the condition of the hull for watertight and 

structural integrity. Any steel replacement must be done to original construction or 

better. Hull fractures in any plating except an oil tank may be covered with an 
UTV Industry Preliminary Cost Assessment 40 Abt Associates Inc.  August 30, 2006

appropriately sized double plate, installed using good marine practice, if the hull 

thickness and condition is suitable. 

 Tailshafts: Inspect for bends, cracks, and damage from rope, wires, or other foreign 

objects. The tailshaft need not be removed for inspection if these items can be 

properly evaluated without doing so. Repair or replace as necessary to ensure safe 

operation and avoid excessive vibration. Inspect the sleeve (or other bearing contact 

surface) on the tailshaft for wear. Repair or replace as necessary for safe operation. 

 Rudders: Inspect for skin or plate damage or fractures, upper and lower bearing 

wear, and bent rudder stock. Rudders need not be removed for inspection if these 

items can be properly evaluated without doing so. Repair or replace as necessary in 

accordance with good marine practice. 

 Propellers: Inspect for cracks and damage from foreign objects. Propellers need not 

be removed for inspection if these items can be properly evaluated without doing so. 

Repair or replace as necessary in accordance with good marine practice. 

 Keel Coolers: Inspect the exterior components of the machinery cooling system for 

leaks or damage. Repair or replace as necessary to ensure proper operation of the 

system. 

 Seachests and Through-Hull Fittings: Inspect condition of seachest and through-hull 

fittings. Repair or replace as necessary in accordance with good marine practice. 

Ensure proper operation of associated valves. 

Generally, direct inspection costs associated with meeting these recommended requirements 

primarily involve labor and drydock rental costs. In addition to these primary direct inspection 

costs, UTV owners and operators may also incur economic opportunity costs associated with 

delay. While most UTV owners and operators probably drydock their vessels periodically, 

current drydocking procedures may not include inspection sufficient to meet recommendations 

contained within the TSAC RWG. For this reason, implementation of TSAC’s drydocking 

recommendations may also result in delays to normal vessel operations arising from 1) longer 

periods of time required to ready the vessel for inspection; 2) longer periods of time required to 

inspect a vessel in accordance with all regulatory requirements; 3) time required for inspection 

by the U.S. Coast Guard or a third party inspector; and 4) time required to implement corrections 

to issues raised by the inspection. These delays may lead to economic opportunity costs in 

which the vessel in question is not being put to its intended economic purpose. In this case, 

opportunity costs are likely to consist primarily of lost revenue associated with the day rate of the 

vessel. 

The preliminary assessment considers the incremental economic costs to UTVs that may be 

associated with direct inspection costs and delays pursuant to TSAC’s recommended drydocking 

requirements. Exhibit 9 summarizes cost estimates assessed in this section. 
UTV Industry Preliminary Cost Assessment 41 Abt Associates Inc.  August 30, 2006

Exhibit 9 

Summary of Per Vessel Cost Estimates for Compliance with Potential Drydocking Requirements 

Cost Category [1] Estimated Range of Potential Per Vessel Cost 

Direct Inspection Costs [2] $410 to $5,000 

Delay Cost [3] Not Estimated 

Notes: 

[1] Interviewees were asked to estimate the time and cost required to comply with standards recommended 

by TSAC in its September 2005 Report of the Working Group on Towing Vessel Inspection. 

[2] Direct inspection costs include the total cost for a company to conduct a drydock inspection, including 

drydock slip rental, and varies by company, vessel length, weight (displacement), and the time required to 

conduct an inspection. 

[3] Delay poses opportunity costs on vessel owners and/or operators. Opportunity cost includes the 

economic activities that a vessel could undertake if it were not out of service. These activities vary by 

company, vessel weight, and vessel length, among other factors, and therefore impede cost estimation. 

4.1 Direct Inspection Costs 

Cost factors that determine the cost of an inspection include drydock rental costs and the labor 

costs associated with hiring a drydock inspector. These potential costs will vary with the length 

and frequency of inspections, which in turn relate to the number and type of inspection 

requirements. UTV owners will incur additional direct costs to the extent that the recommended 

requirements presented in italics above increase the duration of a drydocking period over the 

normal duration absent regulation, thereby requiring the owner to incur higher total labor and 

slip rental costs. 

Drydock Rental and Inspection Costs

While drydock rental costs are theoretically separate from labor costs, cost estimates obtained for 

rental include the cost of inspection, because most drydock inspection businesses interviewed for 

this assessment contract externally for inspectors and were unwilling to disaggregate costs into 

their respective rental and labor components. The numbers reported therefore represent the cost 

of both rental and external inspection. Exhibit 10 summarizes cost information obtained from 

inspection businesses, and estimates a range of future costs associated with potential drydocking 

requirements. As shown, costs for potential drydocking requirements as recommended by the 

TSAC RWG may range from $410 to $5,000 per vessel. The range in potential costs results 

from variations in company fees per hour, inspection times, and vessel size characteristics such 

as length and weight.
UTV Industry Preliminary Cost Assessment 42 Abt Associates Inc.  August 30, 2006

Exhibit 10 

Summary of Per Vessel Drydock Costs (Drydock Rental and Inspection) 

Company Cost Variables 

Company Cost 

Estimate 

(Drydock 

Rental and 

Inspection) 

Estimated Inspection Time 

Estimated Total Per 

Vessel Inspection 

Costs 

Vessels 60 to 85 feet $1,500 

A [1] Vessels 100 to 140 feet $2,500 

Visual external inspection can be 

completed in as little as one day. Time 

required for internal inspection depends 

on variables listed below. 

$1,500 to $2,500 

Vessels of 400 GRT $2,500 

B 

Vessels of 800 GRT $5,000 

Two to three days for full internal 

inspection. External inspection can be 

performed in as little as a day but 

generally takes longer. Total time spent 

in port estimated to be between 3 and 5 

days. 

$2,500 to $5,000 

C Cost quoted includes 

inspection and labor 

$1,000 + $468 

labor 

At least half a day for both external (two 

hours) and internal (four hours) 

inspection. 

$1,468 

D Direct price quote $2,500 100 hours $2,500 

E Direct price quote $1,000 One day $1,000 

F Direct price quote 

$300 per day 

and $35 per day 

for electricity 

and $75 initial 

hookup fee 

Visual external inspection can be 

completed in as little as one day. Time 

required for internal inspection depends 

on variables listed below. 

$410 

Overall Estimated Total Potential Inspection Costs $410 to $5,000 

Notes: 

[1] Length approximations provided by Company A are based on the capacity of two separate drydocks intended to handle 

smaller and larger vessels.

General differences in the cost of drydock rental are due to the following three factors: 

1. Configuration of vessel hull: A drydock company will custom-build blocks for each 

vessel that is suspended out of the water. Block configuration varies based on the size of 

the vessel and the underwater hull structure, and is different for ocean-going versus 

inland push boats due to the nature of the hulls. Further, blocks are built to accommodate 

each vessel and the unique structure of the hull such that it is not damaged when brought 

up to rest on the dock. A rail system is also constructed to haul the vessel out of the 

water. The cost of building blocks is based on time invested for each vessel and the 

company’s specific hourly labor rate. 

2. Length of the vessel: Some drydock companies maintain different docks that handle 

vessels of different lengths. Rental costs vary with length. 
UTV Industry Preliminary Cost Assessment 43 Abt Associates Inc.  August 30, 2006

3. Duration of time since last inspection: A vessel may be docked longer if more time is 

required to appropriately clean it (for internal inspections). Longer periods between 

inspections are likely to increase time in port, because more time may be required to 

prepare and clean the vessel. 

Labor Costs

Because drydock companies do not provide labor rates separately, the preliminary assessment 

relies on telephone interviews with five companies that perform drydocking inspections in order 

to estimate an average labor rate per hour. The interviews were conducted to capture a wide 

geographic range. Exhibit 11 summarizes these labor rates. The average labor rate for 

drydocking inspectors across five companies is $52 per hour. Applying this average labor rate to 

the average duration of inspection provided by one company – a duration ranging from three to 

four hours for small vessels to one day (eight hours) for large vessels – the assessment suggests a 

range of labor costs for inspections of $156 to $416 per inspection, depending on the size of the 

vessel. 

Exhibit 11 

Hourly Labor Rates for Towing Vessel DryDock Inspections 

Company City, State 

Rate Per 

Hour 

A Seward, AK $59 

B St. Rose, LA $50 

C Portland, OR $50 

D San Francisco, CA $56 

E Morgan City, LA $45 

Average hourly labor rate $52 

Frequency of Inspection

The TSAC RWG recognizes that many towing vessels currently operate in compliance with 

either the ISM or the AWO’s RCP-recommended inspection intervals in the absence of federal 

regulation requiring drydocking, and contends that a majority of companies follow individual 

schedules for drydockings. However, the TSAC RWG recommends that specific drydocking 

interval times be included in any future rulemaking on UTV inspection. 

The 2005 AWO RCP manual recommends that vessels in freshwater service drydock as needed 

with a maximum interval of 36 months.23 For vessels in saltwater service, the manual 

recommends drydocking twice in five years with not more than 36 months between successive 

drydockings. For vessels operating exclusively in coastal harbor service (i.e., not beyond the 

 

23 According to the TSAC RWG, a vessel is deemed to be in freshwater service if it has operated in freshwater for at 

least six months in every twelve-month period since the last required drydocking. 
UTV Industry Preliminary Cost Assessment 44 Abt Associates Inc.  August 30, 2006

boundary line), drydocking is recommended on an as-needed basis, with a minimum of once 

every five years, and with a mid-term underwater inspection recommended between the 24th and 

36th month. 

Industry input yielded two estimates of inspection frequency from two companies. One 

company reported drydocking towing vessels for inspection every two to three years, while the 

other reported intervals for the same vessel type of three to five years. Overall, inspection 

requirements are likely to vary according to the drydocking frequency requirements included in 

any proposed rulemaking and the area of operation of UTVs (fresh or saltwater). 

4.2 Delay Costs 

Potential delay costs under a regulation requiring a USCG or third party inspection will arise 

where UTVs must be drydocked for marginally longer periods of time than in the absence of 

regulation. Specifically, delay costs may result from 1) longer periods of time required to ready 

the vessel for inspection; 2) longer periods of time required to inspect a vessel in accordance 

with all regulatory requirements; 3) time required for inspection by the U.S. Coast Guard or a 

third party inspector; and 4) time required to implement corrections to issues raised by the 

inspection. Opportunity costs associated with these increased drydocking periods include such 

elements as lost profits and other foregone economic benefits of having the vessel on the water. 

The amount of lost profit will depend primarily on the day rate of the vessel. 

The length of potential delay will depend on the size of the vessel and the interval time between 

successive drydockings, as well as on the availability of inspectors. Larger vessels require 

longer periods in port for inspection, simply because there are usually more components to 

inspect. This issue is of particular importance with respect to internal inspections. The interval 

time between inspections is relevant because longer intervals can necessitate more cleaning and 

inspection time. One company reported that the determining factor in the length of inspection 

time is the cleaning and preparing of sea valves, including the time required to disassemble parts 

of the vessel. 

Estimates for overall time spent in port vary from “at least one day” to one business week (five 

days). The length of delay is not itemized based on the number or type of element inspected. 

Rather, estimates are provided for external and internal inspections in terms of the time required 

to complete an average inspection that would commonly include the elements listed in section 

4.1. 

Opportunity costs of delay consist of profits foregone as a result of regulations that may require a 

vessel to spend longer periods of time out of service, or drydocked, and less time performing 

operations that generate revenue. A company may also lose future business if it is not able to use 

time in service to conduct valuable client and person-to-person interactions. Opportunity cost 

will also vary to some degree based on the size of the company and the number of vessels run by 

the company (larger companies might be affected less by one vessel out of service for a short 

period of time than smaller companies), number of employees, and other revenue-generating 

activities that cannot be conducted because the vessel is drydocked. 
UTV Industry Preliminary Cost Assessment 45 Abt Associates Inc.  August 30, 2006

External Inspections

Several interviewees indicated that an external inspection could be performed in a single day. 

However, interviewees indicated that a more thorough inspection would likely require at least 

two days. Other interviewees estimated that an external inspection requires between three and 

five days. The length of time is in part dependent on the items requested for inspection, which 

are currently unknown. 

Internal Structural Inspections

Interviewees reported between one and three days required for proper full inspection. This time 

period allows for vessel preparation to allow safe entry into confined spaces. Time required 

depends in part on the condition of the vessel, including tank cleaning, which can vary by the 

type of material and buildup in the tanks. The internal inspection may be performed 

concurrently with the external inspection and may result in a total docking period of 

approximately one business week (five days). As stated previously, most drydock companies 

interviewed contract out this work and would not provide specific cost estimates.
UTV Industry Preliminary Cost Assessment 46 Abt Associates Inc.  August 30, 2006 
UTV Industry Preliminary Cost Assessment 47 Abt Associates Inc.  August 30, 2006 

5. SAFETY MANAGEMENT SYSTEM DEVELOPMENT, IMPLEMENTATION 

AND MANAGEMENT 

The TSAC RWG recommends that the UTV industry be required to develop, implement, and 

maintain a safety management system (SMS) as part of any future proposed rule creating an 

inspection regime for the UTV industry. An SMS is a structured and documented system that 

enables company personnel to effectively implement the company’s safety and environmental 

protection policy.24 The AWO RCP and the International Maritime Organization’s ISM Code 

provide guidelines that are currently used, on a voluntary basis, throughout the towing industry 

by those companies choosing to develop an SMS and become certified by these organizations. 

Based upon the AWO RCP and ISM Code standards, the TSAC RWG recommends the 

following:25

Any company that operates a towing vessel must have a Coast Guard-accepted safety 

management system. To be accepted by the Coast Guard, the safety management system must 

include, at a minimum, the following components: 

1) Safety, Security, and Environmental Protection Policies 

a) Company safety and security policy 

b) Company environmental policy 

c) Accountability and commitment at all organizational levels 

2) Company responsibilities 

a) Explain or depict company organization and authority and responsibility of 

individuals at different levels 

b) Designated Person 

c) Vendor safety 

3) Master (Captain) Authority & Responsibilities; Crew Responsibilities 

a) Master’s authority and responsibilities 

b) Explain or depict responsibility of individuals at different levels 

(i) Authority of crewmembers not to perform task in the event of an unsafe situation 

4) Personnel Procedures 

a) Hiring 

b) Physical exams and physical standards 

c) Drug, alcohol, and prescription medication 

 

24 This definition is from ISM Code 2002, section 1.1.4. 

25 However, the TSAC RWG states that while the working group “...recognizes that many towing vessels currently 

operate in compliance with either the International Safety Management (ISM) Code or the American Waterways 

Operators (AWO) Responsible Carrier Program (RCP),” they nevertheless believe that “...it is important that a 

towing company’s safety management system include all of the SMS components proposed in section I of 

Attachment D.” Attachment 1 to this report reproduces Section D of the TSAC RWG. Working Group on Towing 

Vessel Inspection, “Report of the Working Group on Towing Vessel Inspection.” Memorandum submitted to the 

Towing Safety Advisory Committee, September 29, 2005, page 4. 
UTV Industry Preliminary Cost Assessment 48 Abt Associates Inc.  August 30, 2006

d) New hire orientation and familiarization 

e) Performance evaluations 

f) Performance expectations and disciplinary procedures 

g) Personnel development 

h) Training program (initial and periodic refresher training by crew position) 

i) Vessel manning 

j) Crew Endurance Management 

5) Vessel and Shoreside Operating Procedures 

a) Procedures to ensure compliance with applicable federal laws and regulations 

concerning marine safety, security, and environmental protection 

b) Bridge or pilothouse management 

c) Operator incapacitation 

d) Procedures for making horsepower-to-tow-size decisions 

e) Minimum rigging or towing gear requirements according to vessel service 

f) Navigation and watchstanding 

g) Voyage or trip planning 

h) Lightering 

i) Procedures for identifying critical stores and supplies 

j) Security 

6) Safety and Health Procedures 

a) Company safety and health rules 

b) Personal protective equipment procedures appropriate for vessel operation 

(i) Use, inspection, maintenance, and replacement 

(ii) Respiratory protection 

(iii)Fall arrest 

c) Safety program – training, drills, and meetings 

d) Safe use of equipment 

(i) Deck machinery 

(ii) Rigging 

(iii)Welding and cutting 

(iv)Hand tools 

(v) Ladders 

(vi)Abrasive wheel machinery 

e) Slip, trip, and fall prevention 

f) Fall overboard protection 

g) Hazard communication and cargo knowledge 

h) Confined space entry 

i) Bloodborne pathogens 

j) Lock-out/tag-out 

k) Hearing conservation 

l) Back safety 

m) Personal hygiene 

n) Sanitation and safe food handling 
UTV Industry Preliminary Cost Assessment 49 Abt Associates Inc.  August 30, 2006

7) Emergency Preparedness and Response 

a) Company emergency preparedness and response procedures, drills and training 

program 

b) Vessel specific emergency preparedness and response procedures, drills and training 

program 

8) Maintenance of Vessel: Hull, Machinery, and Equipment 

a) Hull maintenance and inspection procedures 

b) Machinery maintenance and inspection procedures 

c) Equipment maintenance and inspection procedures 

d) Inspection and replacement program for rigging or towing gear 

e) Maintenance recordkeeping 

9) Documentation 

a) Procedures to ensure proper and valid documentation carried aboard vessels 

b) Document control, updating, and distribution 

10)Internal Audits, External Audits and Evaluation of the SMS 

a) Internal audit – schedule, topics, and scope 

b) External audit – schedule, topics, and scope 

c) Annual evaluation of SMS for effectiveness 

11)Incident Investigation, Management of Non-conformities & Corrective Action 

a) Incident reporting and investigation procedures 

b) Communication procedures for disseminating lessons learned 

c) Procedures for identifying and reporting safety deficiencies and non-conformities 

d) Procedures for determining, implementing, and tracking corrective action 

e) Performance management procedures 

In order to estimate potential costs associated with TSAC’s recommended requirements for 

SMSs, the preliminary cost assessment acquired cost information from entities that currently 

develop and implement SMSs, including towing vessel companies and professional SMS 

auditors. Based on information obtained from these sources, the assessment separates the costs 

of an SMS into five categories: 1) SMS development; 2) SMS initial implementation; 3) ongoing 

SMS maintenance and activities; 4) internal auditing programs; and 5) external auditing 

programs. Cost estimates for these categories are summarized in Exhibit 12. These components 

are discussed in greater detail in the sections that follow. 
UTV Industry Preliminary Cost Assessment 50 Abt Associates Inc.  August 30, 2006

Exhibit 12 

Summary of Cost Estimates for Potential Safety Management System Requirements 

Cost Element [1] Estimated Potential Costs [2] 

SMS development [3] $750 to $70,000 (One-time cost) 

SMS initial implementation 

$311,000 overall for an average towing vessel company 

$1,680 per employee for an average towing vessel company 

(One-time cost) 

Ongoing SMS maintenance and activities [4] 

$2.5 million for an average towing vessel company 

$14,490 per employee for an average towing vessel company 

(Annual cost) 

Internal auditing $5,000 to $18,000 audit cost (Per audit) 

 $1,700 training cost (Per employee trained as auditor) 

External auditing $750 to $6,000 

Notes: 

[1] Safety management cost elements included in this exhibit represent only a portion of the recommended standards 

included in TSAC’s RWG. To the extent that certain recommended SMS components are not included in these cost 

estimates, the estimates will understate potential future costs of complying with RWG recommendations. 

[2] Per employee costs for SMS initial implementation represent training costs only; per employee costs for ongoing SMS 

maintenance and activities represent personal protective equipment and maintenance, safety program drill performance, 

safety meetings, emergency drills and exercises, recordkeeping, and period refresher training programs for personnel 

policies; per employee costs for other activities were not estimable given the lack of data on the number of employees 

implementing those activities. To the extent that these activities are already conducted in the absence of a future Coast 

Guard SMS regulation, these costs will overstate potential future costs of complying with RWG recommendations. 

[3] The range of potential costs for SMS development is estimated using cost information obtained from interviews with 

towing vessel companies, interviews with SMS development professionals, the response to the leave-behind questionnaire 

distributed to towing vessel companies during ABS Consulting port visits, and from personal communication with the 

company that completed the leave-behind questionnaire on August 25, 2006. 

[4] The reported cost for ongoing SMS maintenance and activities represents the sum of the cost of company safety, 

health, and security policy; SMS updating; emergency preparedness and response procedures; personnel policies and 

procedures; documentation and recordkeeping; and incident reporting. These costs represent costs reported in the leavebehind questionnaire by a single average-sized towing vessel company with 24 vessels and between 100 and 200 

employees, and may not be representative of towing vessel companies in the UTV industry. 

 

Caveats to the Analysis 

Actual costs incurred by UTV industry members may differ from the estimated potential costs 

summarized in Exhibit 12 for the following reasons: 

• Because the current SMSs associated with the entities interviewed for this assessment differ 

in scope and content from TSAC’s recommended requirements for SMSs and those 

requirements that may be finalized in a future UTV regulation, cost estimates obtained may 

overstate or understate the actual future costs to comply with a future UTV regulation. 

• Costs of implementing SMSs are likely to vary according to company size and other 

company-specific characteristics that may differ from the average-sized towing vessel 

company used for many of the cost estimates. For this reason, cost estimates summarized in 

Exhibit 12 may overstate future costs for a smaller company. 
UTV Industry Preliminary Cost Assessment 51 Abt Associates Inc.  August 30, 2006

• While employee training costs comprise a large percentage of initial SMS implementation 

costs as reported in the leave-behind questionnaire, training on such issues as safety and 

emergency response may already be conducted in the absence of regulation.26 To the extent 

that this is true, all training costs presented may not be attributable to a future Coast Guard 

SMS regulation. Similarly, ongoing SMS maintenance and activities that may already be 

conducted in the absence of regulation such as safety program drill performance, safety 

meetings, and emergency drills and exercises, comprise a large percentage of ongoing SMS 

maintenance and activities. To the extent that these are already conducted in the absence of 

regulation, costs presented for ongoing SMS maintenance and activities may not be 

attributable to a future Coast Guard SMS regulation. 

 

Data Sources 

Data and information in this section are drawn from interviews with professional SMS auditors 

and towing vessel companies, from responses to surveys distributed to towing vessel companies, 

and from personal communication on August 25, 2006 with the towing vessel company that 

completed the leave-behind questionnaire. Eight professional SMS auditors employed by private 

consulting companies or major certification organizations were interviewed for this effort. Five 

of these individuals also develop SMSs for their clients. Data were also drawn from 

communication with three vessel companies, representing different areas of the United States: 

Houston, Seattle, and Tampa. Two of the three companies prepare their SMSs in-house. While 

specific citations for data sources are not included in this section, Attachment 3 to this report 

provides specific company names and contact information for these interviewees. Finally, a 

leave-behind questionnaire associated with specific costs related to SMS development and 

implementation was distributed to towing vessel companies during port visits conducted by ABS 

Consulting from January to March 2006. The assessment relies on one response to this 

questionnaire, as well as on an abbreviated version of this questionnaire that was also distributed 

to these companies, as other sources of data. Attachment 4 reproduces the original and 

abbreviated questionnaires. 

5.1 Safety Management System Development & Initial Implementation 

SMS Development: Costs Associated with Developing SMSs In-House and Outsourcing 

SMS development involves laying out requirements and the collection and compilation of 

relevant company information (policies, procedures, processes, and other documentation as listed 

above) into a single, organized document system. Most companies already maintain many of the 

SMS components in some form, and require simply integrating these information resources, 

thereby incurring a relatively low cost for SMS development. Other companies that do not 

maintain much relevant documentation incur higher costs of SMS development, as the missing 

policies or procedures must be developed or written. 

The assessment uses three sources of information to develop an overall range of potential costs 

for SMS development and initial implementation: interviews with towing vessel companies, 

 

26 For example, employee training costs represent 95% of total SMS initial implementation costs. 
UTV Industry Preliminary Cost Assessment 52 Abt Associates Inc.  August 30, 2006

interviews with SMS development professionals, and the response to the leave-behind 

questionnaire distributed to towing vessel companies during ABS Consulting port visits. Exhibit 

13 summarizes this cost information; the paragraphs that follow discuss the specific cost 

information provided by each source. As Exhibit 13 shows, overall estimated per company costs 

for SMS development may range from $750 to $70,000. As stated, actual costs will depend on 

the degree to which companies already engage in SMS-related development and/or 

implementation activities. 
UTV Industry Preliminary Cost Assessment 53 Abt Associates Inc.  August 30, 2006 

Exhibit 13 

Estimated Per Company Costs for SMS Development 

Data Source Cost Variable 

Estimated Range of 

Potential Costs Notes 

Interviews with Towing Vessel 

Companies SMS Development $10,000 to $70,000 per 

company 

Represents costs of SMS plan 

development only 

Interviews with SMS Development 

Professionals SMS Development $750 to $30,000 per company 

Represents costs of SMS 

preparation by an SMS 

development professional 

only 

Leave-Behind Questionnaire SMS Development $50,000 for an average 

towing company [1] 

Represents costs of SMS 

development for an average 

towing company 

Overall Estimated Per Company Cost Range $750 to $70,000 

[1] The towing company that completed the leave-behind questionnaire has 24 vessels and between 100 and 200 

employees and may not be representative of all companies in the UTV industry. 

Of the towing vessel companies interviewed, two companies developed their SMSs in-house, 

while one company outsourced this activity. The vessel company that outsourced estimated a 

cost of $10,000 and a time frame of 1,000 hours. The two vessel companies that prepared their 

SMSs in-house were not able to estimate a cost for the development, but did report a time frame 

of 1,440 to 2,000 hours.27 Applying an average labor rate in this industry of $35 per hour to 

these time frames yields a range of in-house SMS preparation costs of $50,400 to $70,000.28 

Overall, cost information from towing vessel companies suggests that costs for SMS preparation 

may range from $10,000 to $70,000 per company. 

The SMS development professionals that were interviewed provided the rates that they charge 

their clients for preparation of an SMS. Rates for interviewees that charged by the hour range 

between $65 and $150 per hour, plus expenses (such as travel). The ultimate price, therefore, is 

based primarily on the amount of time required to prepare the SMS. Interviewees reported that 

the time required to develop the basic structure of an SMS varies from 100 hours to 200 hours. 

Applying the hourly rate range of $65 to $150 per hour to the time required to develop the basic 

structure of an SMS yields a range of $6,500 to $30,000 for this cost factor. The actual cost is 

dependent on several factors, including the size of the company, the complexity of operations, 

and, most importantly, the extent to which relevant information already exists. Some 

interviewees charge a flat fee instead of charging by the hour; these fees range from $750 to 

$5,000. Overall, cost information from SMS development professionals suggests that costs for 

SMS preparation may range from $750 to $30,000 per company. 

In talking with towing vessel companies and SMS development professionals, interviewers 

initially tried to obtain separate cost and time estimates for each of the SMS components listed in 

 

27 The towing vessel companies reported that the most time-intensive component involved in developing an SMS is 

developing standard procedures. One vessel company estimated the cost of procedure development alone at $3,000 

and 120 hours. 

28 The labor rate used in the analysis is based on an interview with the towing vessel company that completed the 

leave-behind questionnaire and quoted $35 per hour as an average rate for internal employees. 
UTV Industry Preliminary Cost Assessment 54 Abt Associates Inc.  August 30, 2006

at the beginning of this section; however, all interviewees had a difficult time separating costs or 

hours spent on particular components. They stated that such differentiations are highly sitespecific, and dependent upon the information available. Itemized costs were provided, however, 

in one response from a towing company to the leave-behind questionnaire distributed to vessel 

companies during port visits. For initial SMS development, this company reported a cost of 

$50,000 for the company, which includes $10,000 in external consultant fees and $40,000 in 

internal labor costs allocated to the SMS development process. This company is of average size, 

with 24 vessels and between 100 and 200 employees, and may not be representative of all 

companies in the UTV industry. 

SMS Initial Implementation 

Generally, SMS implementation involves establishing safety objectives and associated personnel 

support, training to ensure proper application of the SMS, and internal audits to ensure 

compliance. Interviewees indicated that initial SMS implementation generally takes 12 to 18 

months but can take as little as one month. This depends, in part, on company motivation and 

management buy-in, and the stringency of its implementation. Reportedly, companies may 

shelve SMS plans because they do not have consistent vessel/shore-side communication, because 

they do not have the commitment of management, or because they have high rates of turnover or 

have not administered training, which can be expensive. SMS development professionals stated 

that the most time-intensive components of SMS development were collecting information and 

becoming familiar with unique company policy and procedures. They also indicated that 

documentation of various procedures was time-consuming. The vessel construction material, 

type of service, and length of the vessel do not reportedly affect the time required to develop an 

SMS. However, many respondents agreed that low rates of company participation and 

involvement in SMS development provided the largest obstacle to creating a comprehensive 

plan. 

The towing vessel company that completed the leave-behind questionnaire was able to itemize 

costs for SMS implementation. Exhibit 14 presents these cost estimates for initial 

implementation activities for the entire company and also estimates the per person cost. As 

shown, per company costs for this company are estimated at $311,000, or $1,680 per employee 

for SMS implementation.29 Costs incurred by UTV companies under a future Coast Guard 

regulation may differ from these costs for two primary reasons: 1) as stated, this company is of 

average size in the towing industry with 24 vessels and between 100 and 200 employees and may 

not be representative of companies in the UTV industry, which may be smaller; and 2) a future 

Coast Guard regulation incorporating SMSs may include more or less activities than those 

presented in Exhibit 14, leading these estimates to understate or overstate actual future costs. 

 

29 Total one-time costs per employee represent training costs only; per employee costs for other activities were not 

estimable given the lack of data on the number of employees implementing those activities. Training is generally 

oriented toward teaching personnel about the contents of the SMS, characteristics of the vessel, and personal safety. 

Training programs for vessel crews are usually company-specific and commonly include training in such topics as 

firefighting, and study of navigation charts, first aid, and engine room maintenance. Training for shore-side 

company personnel is typically less hands-on, and involves becoming familiar with SMS components and 

procedures. 
UTV Industry Preliminary Cost Assessment 55 Abt Associates Inc.  August 30, 2006 

Exhibit 14 

Estimated Costs of Initial SMS Implementation by Activity For an Average Towing Vessel Company 

SMS 

Component Activity 

Annual 

Number of 

Hours $/hour 

Number 

of 

Employees 

Total 

OneTime 

Cost 

Total 

OneTime 

Cost Per 

Employee 

[2] 

Post Signs N/P N/P N/P $1,000 N/A

Staff Training on Overall SMS 8 hours per 

person $35 175 $49,000 $280 

Develop Emergency Response 

Procedures 120 N/P N/P $3,000 N/A

Staff Training on Emergency 

Response Procedures 

4 hours per 

person $35 175 $24,500 $140 

Staff Training on Personnel 

Procedures 

32 hours 

per person $35 175 $196,000 $1,120 

Purchase of Personal Protective 

Equipment N/P N/P N/P $5,000 N/A

Staff Training on Personal 

Protective Equipment 

4 hours per 

person $35 175 $24,500 $140 

SMS Initial 

Implementation 

[1] 

Develop Safety Training 

Program 300 N/P N/P $8,000 N/A

Total $311,000 $1,680

N/P indicates the response was not provided. N/A indicates an estimate is not applicable. 

Notes: 

[1] Cost data for initial SMS implementation are from a single response to the leave-behind questionnaire from a 

towing vessel company of average size, and from personal communication with this company on August 25, 2006. 

All other industry participants who were interviewed did not break down costs into these categories. Costs incurred 

by UTV companies under a future Coast Guard regulation may differ from these costs for two primary reasons: 1) as 

stated, this company is of average size in the towing industry with 24 vessels and between 100 and 200 employees 

and may not be representative of companies in the UTV industry, which may be smaller; and 2) a future Coast 

Guard regulation incorporating SMSs may include more or less activities than those presented here, leading these 

estimates to understate or overstate actual future costs. 

[2] Total one-time costs per employee represent training costs only; per employee costs for other activities were not 

estimable given the lack of data on the number of employees implementing those activities. To the extent that these 

activities are already conducted in the absence of a future Coast Guard SMS regulation, these costs will overstate 

potential future costs of complying with RWG recommendations. 

5.2 Ongoing SMS Maintenance & Activities 

Ongoing SMS maintenance and activities include staff training, updates to the SMS documents, 

recordkeeping, and internal audits. Exhibit 15 summarizes ongoing SMS maintenance and 

activity costs as provided by the one survey response to the leave-behind questionnaire submitted 

by a towing vessel company of average size. As shown, this company estimates a cost of 

approximately $2.5 million for ongoing SMS maintenance and activities, or an equivalent of 

$15,000 per employee. Costs incurred by UTV companies under a future Coast Guard regulation 

may differ from these costs for two primary reasons: 1) as stated, this company is of average size 
UTV Industry Preliminary Cost Assessment 56 Abt Associates Inc.  August 30, 2006

in the towing industry with 24 vessels and between 100 and 200 employees and may not be 

representative of companies in the UTV industry, which may be smaller; and 2) a future Coast 

Guard regulation incorporating SMSs may include more or less activities than those presented in 

Exhibit 15, leading these estimates to understate or overstate actual future costs. 
UTV Industry Preliminary Cost Assessment 57 Abt Associates Inc.  August 30, 2006

 

Exhibit 15 

Estimated Annual Costs of Ongoing SMS Activities 

SMS Category [1] Activity 

Annual 

Number 

of 

Hours $/hour 

Number 

of 

Employees 

Total 

Annual 

Cost 

Total 

Annual 

Cost Per 

Employee 

[2] 

Personal protective equipment 

inspection and maintenance 

100 per 

person $35 175 $612,500 $3,500

Hazard communication and 

cargo knowledge 100 N/P N/P $2,500 N/A

Safety program drill 

performance 

200 per 

person $35 175 $1,225,000 $7,000

Company Safety, 

Health, and 

Security Policy 

Safety meetings 100 per 

person $35 175 $612,500 $3,500

SMS Update Periodic SMS update 416 $35 N/P $14,560 N/A

Drills and exercises 4 per 

person $35 175 $24,500 $140 Emergency 

Preparedness and 

Response 

Procedures 

Recordkeeping 2 per 

person $35 50 $3,500 $70

Personnel Policies 

and Procedures 

Periodic refresher training 

programs 

8 per 

person $35 175 $49,000 $280

Documentation 

and 

Recordkeeping 

Maintenance of vessel log, 

publications, costs 100 N/P N/P $2,500 N/A

Paperwork 12 N/P N/P $300 N/A

Investigations 48 N/P N/P $1,200 N/A Incident 

Reporting Corrective actions 48 N/P N/P $1,200 N/A

Total $2,549,260 $14,490 

N/P indicates the response was not provided. N/A indicates an estimate is not applicable. 

Notes: 

[1] Cost data for ongoing SMS activities are from a single response to the leave-behind questionnaire from a towing 

vessel company of average size, and from personal communication with this company on August 25, 2006. All other 

industry participants who were interviewed did not break down costs into these categories. Costs incurred by UTV 

companies under a future Coast Guard regulation may differ from these costs for two primary reasons: 1) as stated, 

this company is of average size in the towing industry with 24 vessels and between 100 and 200 employees and may 

not be representative of companies in the UTV industry, which may be smaller; and 2) a future Coast Guard 

regulation incorporating SMSs may include more or less activities than those presented in Exhibit 15, leading these 

estimates to understate or overstate actual future costs. 

[2]Per employee costs for ongoing SMS maintenance and activities represent personal protective equipment and 

maintenance, safety program drill performance, safety meetings, emergency drills and exercises, recordkeeping, and 

period refresher training programs for personnel policies; per employee costs for other activities were not estimable 

given the lack of data on the number of employees implementing those activities. To the extent that these activities 

are already conducted in the absence of a future Coast Guard SMS regulation, these costs will overstate potential 

future costs of complying with RWG recommendations.
UTV Industry Preliminary Cost Assessment 58 Abt Associates Inc.  August 30, 2006

5.3 Internal Auditing Programs 

An internal auditing program is the foundation of an oversight system, and serves to assess 

compliance with the requirements of the particular SMS program. The internal audit helps to 

maintain the SMS, including detecting and rectifying problems before an external audit, and 

provides information for SMS updates. Internal auditing procedures are generally companyspecific. They can be conducted by trained company personnel, or outsourced to companies 

such as those who develop the SMS. All of the SMS preparers interviewed were able to provide 

information about internal auditing procedures. 

Internal SMS audits are generally conducted by auditing a representative sample of vessels, 

speaking with crew on these vessels, and examining vessel documentation. One interviewee 

indicated that two or three company personnel from each company department are generally 

interviewed. Interviewees provided estimates for the duration of an internal audit, ranging from 

one to six days; this includes time for both reviewing paperwork and conducting interviews. 

Time required may vary based on the number of vessels, the company’s level of compliance, and 

whether procedures, training and recordkeeping need to be updated. The frequency of internal 

audits is company-specific, and may be based on previous audit results and the desired outcome 

of the system. 

Rather than hiring an outside contractor to complete internal audits, companies may train 

employees. For towing vessel companies seeking training programs instructed by external SMS 

experts, one SMS development professional described a three-day training courses available for 

$1,000 to $2,400 per employee, or $1,700 on average; another described a five- to six-day course 

for $1,500. Many larger companies reportedly train internal auditors, while smaller companies 

tend to hire contractors to perform internal audits. 

Two vessel companies that perform in-house audits reported internal auditing costs ranging from 

$5,000 to $18,000 per year. Costs for training and conducting an internal audit are summarized 

in Exhibit 16. 
UTV Industry Preliminary Cost Assessment 59 Abt Associates Inc.  August 30, 2006

Exhibit 16 

Estimated Costs of Internal Audits

SMS Category Activity Total [1] 

Training for internal audits by vessel 

company $1,700 (per employee trained as auditor) Internal Audits

Conducting in-house internal audits $5,000 to $18,000 (per company) [2] 

Notes: 

[1] Total costs are not additive because training costs are estimated per employee while conducting an in-house 

internal audit is estimated per company. 

[2] The upper-bound estimate of $18,000 includes labor costs of interviewees in the internal audit process. 

5.4 External Auditing Programs 

Once the SMS is prepared and implemented, a qualified external auditor must perform initial and 

periodic external audits in order for the company to obtain and maintain certification under a 

formal certification program. While the external audits discussed with interviewees are 

specifically associated with AWO’s RCP or ISM Code compliance, cost estimates may be 

indicative of costs that could be incurred for companies to undergo an audit to demonstrate 

compliance with potential Coast Guard SMS requirements, such as those proposed by the TSAC 

RWG, if audits are required by personnel outside the company. 

Interviewees consisted of auditors certified to audit under either the AWO’s RCP or the ISM 

Code. They reported auditing both large and small companies, and each perform anywhere from 

two to 100 audits per year. 

The ISM Code requires that a company undergo an initial audit for certification, annual internal 

audits thereafter, and a renewal external audit every five years. The AWO RCP standard 

requires a report of the initial audit by the auditor, including completion of an AWO RCP 

checklist. The AWO RCP will subsequently issue certification, which is valid for three years. 

Interviewees reported that external audits consist of a review of company documentation, and 

interviews with company personnel, both at company headquarters and on the vessels. 

According to one interviewee, auditors typically review the SMS before arriving onsite, which 

requires approximately one day. The auditor will then visit the company headquarters and 

review documentation and files, and attempt to speak with employees at all levels of the 

company. This may take anywhere from four hours to two days, depending on the size of the 

company. The auditor will then visit the company’s vessel(s) with the purpose of completing the 

AWO or ISM checklists and speaking with the vessel’s crewmembers in order to ensure that 

SMS components are being appropriately implemented on the vessel. The time required for a 

vessel audit ranges from two hours for a small vessel to six to twelve hours for a large vessel. 

Exhibit 17 summarizes costs interviewees reported charging for their auditing services. These 

costs generally do not include travel or other expenses. 
UTV Industry Preliminary Cost Assessment 60 Abt Associates Inc.  August 30, 2006

Exhibit 17 

Cost for External SMS Audits, Excluding Travel and Other Expenses 

Company [1] Cost 

I $105 per hour (local audits), or 

$1,000 per day (nonlocal audits, includes travel) 

II $100 per hour 

III $95 per hour 

IV $60 to $65 per hour 

V $1,495 per day (office visit) 

$700 - $1,000 per vessel 

VI $750 flat fee 

VII 

Flat fee, calculated for each individual audit. Approx: 

$6,000 for medium sized company 

$4,000 for small company 

Notes: 

[1] Companies interviewed for the SMS section of this report are different than 

companies interviewed for the dry docking section of this report. 

Exhibit 18 uses cost information provided by AWO and ISM auditors to calculate three estimates 

of annual external audit costs. It is important to note that these costs do not include company 

costs of providing time for employees to serve as interviewees. For this reason, total annual 

costs of external audits summarized in Exhibit 18 may underestimate costs to a towing vessel 

company of having an external audit. 
UTV Industry Preliminary Cost Assessment 61 Abt Associates Inc.  August 30, 2006 

Exhibit 18 

Estimated Costs of External Audits 

Cost Unit $/hr Duration of Audit Frequency Total Annual Cost [1] 

Per hour $60 to $105 

2 to 12 hours for vessel 

inspection 

2 to 4 days for company 

inspection 

Annually 

$120 to $1,260 per vessel 

$960 to $3,360 per company 

$1,080 to $4,620 for audit [2] 

Flat rate N/A N/A Annually $750 to $6,000 per company 

Total Estimated Range of Annual External Audit Costs $750 to $6,000 [3] 

N/A indicates response not applicable. 

Notes: 

[1] Data for external audits is based on interviews with AWO and ISM auditors as summarized in Exhibit 17. Costs 

presented do not include company costs of providing time for employees to serve as interviewees. For this reason, total 

annual costs of external audits summarized here may underestimate costs to a towing vessel company of having an 

external audit. 

[2] The range of total external audit costs assumes that the per vessel costs represent the vessel inspection portion of the 

external audit, while the per company costs represent the company portion of the external audit. The estimate assumes 

one vessel per company. 

[3] The range of total external audit costs uses the lowest figure ($750) and the highest figure ($6,000) estimated in this 

Exhibit. Because the lowest and highest cost estimates were obtained as flat rates, it is unclear whether both the 

company and the vessel portion of the external audit are included. However, because the total cost estimated using the 

per hour rates includes both the company and vessel portions of the external audit and falls within the range suggested by 

the flat rate estimates, it is reasonable to assume that the flat rates represent a comprehensive external SMS audit 

(company and vessel). 

Interviewees described common non-conformities in an SMS that must be corrected. These 

include deficiencies in the training program, document control, missing procedures, delayed 

updates in the plan, staff unfamiliarity with the SMS, and deficiencies in radio and telephone 

logs and recordkeeping. Reportedly, discrepancies also often exist between the policies that are 

written in the SMS plan and those that are actually implemented. Furthermore, some 

interviewees stated that emergency response procedures and maintenance records contain too 

little detail. The time required to correct these non-conformities ranges from two hours to three 

months. Finally, several interviewees stated that vessel crews and management often do not buy 

in to the plan, and this renders an SMS inherently ineffective.
UTV Industry Preliminary Cost Assessment 62 Abt Associates Inc.  August 30, 2006 
UTV Industry Preliminary Cost Assessment 1-1 Abt Associates Inc.  August 28, 2006

Attachment 1 

TSAC Recommended Requirements for a UTV Inspection Regime 
Appendix A

Towing Safety Advisory Committee Document

September 29, 2005

Subchapter M: Towing Vessels

I. Safety Management System: Any company that operates a towing vessel must have 

a Coast Guard-accepted safety management system. To be accepted by the Coast 

Guard, the safety management system must include, at a minimum, the following 

components: 

1) Safety, Security and Environmental Protection Policies

a) Company safety and security policy

b) Company environmental policy 

c) Accountability and commitment at all organizational levels

2) Company Responsibilities

a) Explain or depict company organization and authority and responsibility of 

individuals at different levels

b) Designated Person

c) Vendor safety

3) Master (Captain) Authority & Responsibilities; Crew Responsibilities

a) Master’s authority and responsibilities

b) Explain or depict responsibility of individuals at different levels

i) Authority of crewmembers not to perform a task in the event of an unsafe 

situation

4) Personnel Procedures

a) Hiring 

b) Physical exams and physical standards 

c) Drug, alcohol, and prescription medication 

d) New hire orientation and familiarization

e) Performance evaluations

f) Performance expectations and disciplinary policies

g) Personnel development 

h) Training program (initial and periodic refresher training by crew position)

i) Vessel manning

j) Crew Endurance Management 

5) Vessel and Shoreside Operating Procedures

a) Procedures to ensure compliance with applicable federal laws and regulations 

concerning marine safety, security, and environmental protection

b) Bridge or pilothouse management

c) Operator incapacitation

d) Procedures for making horsepower-to-tow-size decisions

e) Minimum rigging or towing gear requirements according to vessel service

f) Navigation and watchstanding 

g) Voyage or trip planning 
-2- Appendix A

h) Lightering 

i) Procedures for identifying critical stores and supplies

j) Security

6) Safety and Health Procedures

a) Company safety and health rules

b) Personal protective equipment procedures appropriate for vessel operation

i) Use, inspection, maintenance, and replacement

ii) Respiratory protection

iii) Fall arrest

c) Safety program -- training, drills, and meetings

d) Safe use of equipment

i) Deck machinery

ii) Rigging

iii) Welding and cutting

iv) Hand tools

v) Ladders

vi) Abrasive wheel machinery

e) Slip, trip, and fall prevention

f) Fall overboard prevention 

g) Hazard communication and cargo knowledge

h) Confined space entry 

i) Bloodborne pathogens

j) Lock-out/tag-out

k) Hearing conservation

l) Back safety

m) Personal hygiene

n) Sanitation and safe food handling

7) Emergency Preparedness and Response

a) Company emergency preparedness and response procedures, drills and 

training program

b) Vessel specific emergency preparedness and response procedures, drills and 

training program

8) Maintenance of Vessel: Hull, Machinery, and Equipment

a) Hull maintenance and inspection procedures

b) Machinery maintenance and inspection procedures

c) Equipment maintenance and inspection procedures

d) Inspection and replacement program for rigging or towing gear

e) Maintenance recordkeeping 

9) Documentation

a) Procedures to ensure proper and valid documentation carried aboard vessels

b) Document control, updating, and distribution
-3- Appendix A

10) Internal Audits, External Audits and Evaluation of the SMS

a) Internal audit - schedule, topics, and scope

b) External audit - schedule, topics, and scope

c) Annual evaluation of SMS for effectiveness

11) Incident Investigation, Management of Non-conformities & Corrective Action

a) Incident reporting and investigation procedures

b) Communication procedures for disseminating lessons learned

c) Procedures for identifying and reporting safety deficiencies and nonconformities

d) Procedures for determining, implementing, and tracking corrective action

e) Performance measurement procedures 

II. Standards

1) Hull and Machinery

Note: For the items below, failure of a redundant auxiliary system does not make the vessel 

unseaworthy or require the vessel to be moored or anchored; however, the Master shall use all 

available means at his/her disposal to ensure the inoperative equipment is repaired and returned 

to service as soon as practicable. The Master shall consider the condition of the vessel and its 

machinery when making decisions affecting navigation and the safety of onboard personnel. 

a) Design and Construction (new vessels)

Inland towing vessels built after the effective date of the regulations must be designed and 

constructed in accordance with ABS Rules for Building and Classing Steel Vessels for Service 

on Rivers and Intracoastal Waterways (version in effect as of the date the contract was signed), 

or other published, recognized standards. (Other acceptable standards TBD; may include 

comparable standards of other recognized classification societies, American Boat and Yacht 

Council, etc.) Classification by a recognized classification society is not required. 

Coastal/ocean towing vessels built after the effective date of the regulations must be designed 

and constructed in accordance with ABS Rules for Building and Classing Steel Vessels Under 90 

Meters (295 Feet) in Length (version in effect as of the date the contract was signed), or other 

published, recognized standards. (Other acceptable standards TBD; may include comparable 

standards of other recognized classification societies, American Boat and Yacht Council, etc.) 

Classification by a recognized classification society is not required. 

Vessels constructed after the effective date of the regulations that are essentially sister vessels of 

a class or series of previously built vessels may be constructed to the same design as previously 

built vessels in the class or series, provided that 1) the class or series of vessels has a history of 

safe operation and 2) the new vessels meet all of the requirements outlined in items c) through r) 

below, including the provisions for vessels constructed after the effective date of the regulations.
-4- Appendix A

New designs that deviate from applicable ABS Rules for Building and Classing Steel Vessels or 

other published, recognized standards may be permitted if approved by the Coast Guard or a 

recognized classification society.

Vessel plans must be reviewed and approved by a Professional Engineer with marine expertise. 

Builder must certify that vessel was built in accordance with approved plans. Vessel owner must 

retain a copy of the approved plans in the company office. Plan approvals and builder 

certifications must be available for review by Coast Guard or third-party auditor.

Existing vessels that undergo substantial modification may be rebuilt as original or to the 

standards above.

b) Drydocking 

Intervals: Drydocking intervals should be based on time of service in salt water. The most 

restrictive schedule would require inspections twice in five years, with no more than three years 

between inspections. Five-year intervals shall be permitted for vessels in fresh water service. A 

vessel will be deemed to be in fresh water service if it has operated in fresh water for at least six 

months in every 12-month period since the last required drydocking.

Underwater inspections in lieu of drydocking may be permitted for alternating examinations if 

no obvious defects are present and the vessel has a satisfactory operating record.

A drydocking that meets the standards below, conducted within the specified intervals, will 

satisfy this requirement. Drydocking due dates will be based on the last drydocking conducted 

that meets the standards below.

Components/Standards: 

Towing vessels required to have a loadline will be considered to meet the requirements below for 

hull and seachest examinations only. Towing vessels whose hull is classed by a recognized 

classification society will be considered to meet all the drydocking requirements specified below. 

For other towing vessels, a drydocking for regulatory credit must satisfy the following 

requirements: 

The vessel owner or operator shall ensure that all components that affect the safe 

operation and hull integrity of the vessel are inspected. 

The vessel owner or operator must maintain documentation of: 1) the condition of the 

hull, underwater propulsion, and steering system as inspected; and 2) all repairs and 

alterations to the hull, underwater propulsion, and steering systems. Documentation must 

be retained for review by the Coast Guard or approved third-party auditor.

At a minimum, the following inspections shall be performed and documented:
-5- Appendix A

Hull: Inspect on drydock the hull bottom, sides, headlog and stern for indentations, 

fractures, holes, and other deficiencies that may affect the watertight integrity of the 

vessel. Assess by appropriate means the condition of the hull for watertight and 

structural integrity. Any steel replacement must be done to original construction or 

better. Hull fractures in any plating except an oil tank may be covered with an 

appropriately sized doubler plate, installed using good marine practice, if the hull 

thickness and condition is suitable.

Tailshafts: Inspect for bends, cracks, and damage from rope, wires or other foreign 

objects. Tailshaft need not be removed for inspection if these items can be properly 

evaluated without doing so. Repair or replace as necessary to ensure safe operation and 

avoid excessive vibration. Inspect the sleeve (or other bearing contact surface) on the 

tailshaft for wear. Repair or replace as necessary for safe operation.

Rudders: Inspect for skin or plate damage or fractures, upper and lower bearing wear, 

and bent rudder stock. Rudders need not be removed for inspection if these items can be 

properly evaluated without doing so. Repair or replace as necessary in accordance with 

good marine practice.

Propellers: Inspect for cracks and damage from foreign objects. Propellers need not be 

removed for inspection if these items can be properly evaluated without doing so. Repair 

or replace as necessary in accordance with good marine practice.

Coolers: Inspect the exterior components of the machinery cooling system for leaks or 

damage. Repair or replace as necessary to ensure proper operation of the system.

Seachest and Through-Hull Fitting: Inspect condition of seachest and through-hull 

fittings. Repair or replace as necessary in accordance with good marine practice. Ensure 

proper operation of associated valves. 

c) Watertight integrity and watertight fixtures

For each towing vessel that has watertight bulkheads in the hull and/or watertight fixtures on the 

exterior deck and deckhouse, these watertight closures must be maintained in serviceable 

condition. 

d) Miscellaneous exterior openings 

For each towing vessel that has cabin or hull penetrations open to the exterior of the vessel that 

may allow water to enter the vessel in the expected area of operation, the closure devices for 

these exterior openings must be maintained in satisfactory weather-resistant condition. 
-6- Appendix A

e) Handrails and bulwarks

Rails or equivalent protection must be installed near the periphery of all decks accessible to 

crew. Equivalent protection may include lifelines, wire rope, chains, and bulwarks that provide 

strength and support equivalent to fixed rails. Where space limitations make deck rails 

impractical, such as at narrow catwalks in way of deckhouse sides, hand grabs may be 

substituted.

f) Emergency egress

A towing vessel constructed after the effective date of the regulations must have at least two 

means of egress from the engine room and the overall crew accommodations area. (This does 

not mean individual spaces, such as staterooms, within the overall accommodations area.) Doors

and escape hatches must be operable from either side. The lower section of the engine room 

must be provided with at least two means of egress to the upper engine room or the exterior of 

the vessel.

g) Freeing ports and scuppers

For each towing vessel that is fitted with installed bulwarks around the exterior of the main deck, 

sufficient freeing ports and/or scuppers must be provided and maintained to allow water to run 

off the deck quickly without adversely affecting the stability of the vessel. 

h) Piping systems and tanks

All vessel piping and tanks that have exposure to the outside of the hull must be made of metal 

and must be maintained in leak-free condition. Valves at the origination and termination of a 

pipe and tank vents must be marked by labeling or color-coding. 

i) Guards for exposed hazards

An exposed hazard, such as gears or rotating machinery, must be properly protected by a cover, 

guard, or rail.

j) Alarms/monitoring

Each towing vessel must be equipped with an alarm system that includes main engine 

lubricating oil pressure, main engine cooling water temperature, auxiliary generator engine 

lubricating oil pressure, auxiliary generator engine cooling water temperature, hydraulic steering 

fluid levels, and bilge levels. Alarms must be audible and visible at the primary operating 

station.
-7- Appendix A

k) Gauges

Each towing vessel must be equipped with gauges for the following: main engine lubricating oil 

pressure, main engine cooling water temperature, auxiliary generator engine lubricating oil 

pressure, auxiliary generator engine cooling water temperature, and hydraulic steering fluid 

pressure if equipped with hydraulic steering systems. Gauges must be accessible to 

crewmembers for monitoring.

l) Steering

A towing vessel constructed after the effective date of the regulations must be equipped with two 

independently operating sources of power (e.g., two steering pumps and two fluid reservoirs) for 

the steering system. Each source of power must be capable of operating the entire steering 

system. 

An existing towing vessel that has only one source of power for the steering system must have an 

emergency backup system or process that will allow the vessel to be moved to a safe location in 

the event of a steering failure. 

m) Electrical

A towing vessel constructed after the effective date of the regulations must have electrical 

equipment and wiring that meets the standards of 46 CFR Subchapter L or appropriate equivalent 

standard. 

For existing towing vessels, all electrical equipment and wiring must be maintained in good 

operating condition such that no fire hazards or other hazards to personnel are present. All 

wiring terminations must be made in junction boxes or other electrical fixtures suitable for the 

purpose intended. All machinery switches, energizers, and circuit breakers must be labeled and 

maintained in good operating condition. When electrical equipment or wiring on an existing 

towing vessel is retrofitted or replaced, the new equipment or wiring must meet UL Marine 

standards or an appropriate equivalent standard.

n) Propulsion

All propulsion machinery, including main engines, reduction gears, shafting, and bearings, must 

be maintained in good operating condition. 

o) Control systems

All control systems must be maintained in good operating condition.
-8- Appendix A

p) Fuel systems 

Vessels whose construction was contracted for after January 18, 2000, must comply with the 

requirements for fuel systems at 46 CFR 27.211. 

For all towing vessels, fuel systems for the vessel and for main engine propulsion and auxiliary 

generator systems must be maintained in good operating condition. Each towing vessel must be 

able to supply clean fuel to the main engines and auxiliary generator engines via a filtering 

system that may include filters, a centrifuge, and/or a day tank. A towing vessel equipped with a 

day tank must be equipped with a low fuel level alarm.

q) Electrical generating systems 

A towing vessel constructed after the effective date of the regulations must be equipped with two 

electrical generating systems. Each electrical generating system, regardless of type, must be 

capable of carrying the essential electrical load of the vessel under normal operating conditions. 

Electrical generating systems on existing towing vessels must be maintained in good operating 

condition.

r) Lighting

A towing vessel must be equipped with appropriate illumination in crew work areas.

2) Firefighting

a) Fire detection system to detect engine room fires (46 CFR 27.203)

b) General alarm (46 CFR 27.201)

c) Internal communication system (46 CFR 27.205)

d) Hand-portable fire extinguishers (46 CFR 25.30, 27.303, 27.305)

e) Semi-portable fire extinguishing systems (as applicable) (46 CFR 27.303 and 27.305)

f) Fixed fire extinguishing systems (as applicable) (46 CFR 27.303 and 27.305)

g) Fixed fire pump and fire main, with hoses and nozzles (46 CFR 27.301)

h) Portable fire pump with hose and nozzle (46 CFR 27.301(e))

i) Remote engine fuel shutoff valve (46 CFR 27.207)

j) Remote starter for fire pump (46 CFR 27.301(a)(2))

k) Fire axe

Each towing vessel must be equipped with at least one fire axe that is readily accessible for use 

from the exterior of the vessel.
-9- Appendix A

l) Smoke alarms to protect all sleeping spaces 

Each towing vessel must be equipped with a means to detect smoke in the sleeping spaces and 

lounges that will alert individuals in those spaces. This can be accomplished via an installed 

detection system or by using individual battery operated detectors. Detection systems or 

individual detectors must be kept in operational condition at all times.

m) Heat or flame detector in galley

Each towing vessel constructed after the effective date of the regulations and equipped with a 

galley must have a heat or flame detector with an audible alarm at the primary operating station. 

(Galley=a space containing appliances with cooking surfaces that may exceed 250 degrees 

Fahrenheit).

n) Remote manual engine shutdown

Each towing vessel constructed after the effective date of the regulations must have a remote 

manual main engine shutdown for each main engine and auxiliary generator engine, which can 

be operated from a location outside the machinery space where the engines are located. The 

required fuel shutoff may serve as this shutdown if each engine is fitted independently. 

o) Placarded storage area appropriate for flammable products

A towing vessel that has paints, coatings, or other flammable products on board must have a 

designated storage area for unopened containers of flammable products. Previously opened 

containers of flammable products must be kept in a steel storage locker that is marked as 

containing flammable products, located away from ignition sources, and protected by a nearby

fire extinguisher.

3) Lifesaving

a) Coast Guard-approved life preservers (46 CFR 25.25-5(b) & (c)) 

b) Coast Guard-approved ring buoy (46 CFR 25.25-5(d))

c) Coast Guard-approved work vests (46 CFR 26.30)

d) Emergency Position Indicating Radio Beacon (EPIRB) (46 CFR 25.26)

e) Visual Distress Signals 

Each towing vessel operating on oceans, near coastal, or Great Lakes routes must carry six red 

flares and six smoke distress signals. Each towing vessel operating on lakes, bays, and sounds 

must carry three red flares and three smoke distress signals. 
-10- Appendix A

f) First aid kit/trauma kit

Each towing vessel must be equipped with an industrial type first aid cabinet/kit appropriate to 

size of the crew. A vessel operating on oceans, near coastal, or Great Lakes routes must have a 

means to take blood pressure readings, splints for broken bones, and large bandages for serious 

wounds. 

g) Emergency lighting

Each towing vessel must be equipped with sufficient lighting to illuminate escape routes in the 

event of a power loss. Emergency lighting may be automatic, battery-operated with a duration 

sufficient to allow the crew to escape, or non-electric, phosphorescent adhesive lighting strips 

that mark escape routes to the exits. 

h) Immersion suits 

Each towing vessel operating on oceans, near coastal, or Great Lakes routes whose voyage takes 

it above Latitude 32 degrees North must carry an appropriately sized immersion (survival) suit 

for each person onboard. 

i) Inflatable life raft 

Each towing vessel operating on oceans, near coastal, or Great Lakes routes more than one mile 

from shore must carry an inflatable life raft appropriate for the number of persons onboard. 

4) Pollution Prevention

a) Fuel oil and bulk lubricating oil containment (33 CFR 155.320)

b) Oily Mixtures (Bilge slop) retention (33 CFR 155.330, 155.350, 155.360, 155.370)

c) Bilge pumps or other dewatering capability

All towing vessels must have either an installed bilge pump or another method for emergency 

dewatering, such as a portable pump with hoses.

d) Oil transfer hoses (33 CFR 154.500)

e) Oily water separator equipment (where applicable) (33 CFR 155.350, 155.360, 155.370, 

155.380)

f) Placard prohibiting discharge of oil (33 CFR 155.450)

g) Garbage (MARPOL) placard (33 CFR 151.59)

h) Garbage disposal requirements/procedures/documentation (including Waste Management 

Plan where applicable) (33 CFR 151.57, 33 CFR 151.63; 151.66; 151.67; and 46 CFR 

25.50-1)

i) Marine Sanitation Devices (MSD) (33 CFR Part 159)

j) Oil transfer procedures (33 CFR 155.720, 33CFR155.750)

k) Declaration of Inspection (33 CFR 156.150, 33 CFR 156.120)
-11- Appendix A

l) Pumping systems for oily mixtures (33 CFR 155.410, and 155.420)

m) Spill kit 

During fueling operations, each towing vessel must have ready for immediate use equipment and 

supplies to clean up and remove an on-deck oil spill of at least one barrel. The equipment and 

supplies must include sorbents; non-sparking hand scoops, shovels, and buckets; containers 

suitable for holding recovered waste; emulsifiers for deck cleaning; and protective clothing. 

n) Closable scuppers or other containment method 

Each towing vessel must be capable of preventing spills to the deck during oil or fuel transfers 

from reaching the water, either by 1) pre-closing off the scuppers/freeing ports, if the vessel is so 

equipped, or 2) pre-deploying absorbent booming/pads on the deck around vents and fills.

5) Navigation and Communication Equipment

a) VHF radio (33 CFR 164.72(a)(3), 33 CFR 26.03)

b) Second marine VHF radio (33 CFR 164.72(a)(3), 33 CFR 26.03(e) and (f))

c) Capability of connecting a VHF to battery backup

At least one VHF radio required under 33 CFR 164.72(a)(3) must be installed at the operating 

station in the pilothouse and connected to a properly operating battery backup.

d) Handheld VHF radio

Each towing vessel must have at least one properly operating handheld VHF radio. 

e) Navigation lights (COLREGS, 33 CFR Part 84) 

Each towing vessel must have navigation lights in accordance with the Navigation Rules for its 

area of operation, including compliance with Annex I, Positioning and Technical Details for 

lights and shapes (33 CFR 84).

f) Whistle and bell (COLREGS Rule 33) (33 CFR Part 86)

Each towing vessel must have a whistle and bell in accordance with the Navigation Rules for its 

area of operation, including compliance with Annex III, Technical Details of Sound Signal 

Appliances (33 CFR 86).

g) Radar (33 CFR 164.72(a)(1))
-12- Appendix A

h) Second radar 

Each towing vessel that operates on oceans, near coastal, or Great Lakes routes more than 12 

miles from shore must be equipped with a second radar. The second radar must meet the 

requirements of the Federal Communications Commission (FCC) specified by 47 CFR part 80, 

and RTCM Standard for Marine Radar Equipment Installed on Ships of Less Than 300 Tons 

Gross Tonnage, RTCM Paper 71-95/SC112-STD, Version 1.1, display Category II and 

stabilization Category Bravo.

i) Fathometer (except Western Rivers) (33 CFR 164.72(a)(5))

j) Search light (33 CFR 164.72(a)(2))

k) GPS (satellite navigation receiver) or LORAN (33 CFR 164.72(a)(6))

l) Magnetic compass (33 CFR 164.72(a)(4))

m) Swing meter (Western Rivers only) (33 CFR 164.72(a)(4))

n) Alternative means of determining course and direction (33 CFR 164.72(a)(1)(ii)(B))

o) AIS (33 CFR 164.46)

p) Rudder angle indicator or means to visually indicate rudder position

Each towing vessel must be equipped with a rudder angle indicator if it is fitted with non-followup steering gear. Towing vessels fitted with follow-up type steering are not required to have a 

separate rudder angle indicator as long as the position of the towing vessel’s rudders is 

appropriately indicated by the relative position of the steering levers.

q) Onboard crew communications 

Each towing vessel must have an internal communication system or other means of 

communication that allows the vessel operator to communicate with crewmembers on watch.

r) Means of ensuring visibility through pilothouse windows

Each towing vessel must have a means of ensuring that the windows immediately forward of the 

steering station in the wheelhouse allow for adequate visibility to ensure safe navigation.

s) Emergency communications capability

Each towing vessel must maintain an emergency communications capability appropriate for the 

vessel’s area of operation. 

t) Maintenance and failure of navigation equipment 

The requirements for maintenance and failure of navigation equipment at 33 CFR 164.82 shall 

apply to all of the navigation and communication equipment required under items a) through s) 

above.
-13- Appendix A

6) Towing Gear/Rigging 

a) Face wires, spring lines, and push gear used for towing vessels when pushing ahead or 

towing alongside (includes all rigging used to make up towing vessel to its tow and all 

rigging used to wire up the tow, itself) (33 CFR 164.76)

b) Towline for towing astern (wire or hawser) (33 CFR 164.74(a))

c) Terminal gear for towing astern (e.g., bridles, surge chain, shackles, flounder/fish plate, 

shock hawser, pennant) (33 CFR 164.74(b))

7) Documents and Publications 

a) Certificate of Inspection (46 CFR Subchapter M)

b) Certificate of Documentation (46 CFR 67.313)

c) Vessel log or other record (paper or electronic)

Each towing vessel must employ a vessel log or other means, either paper or electronic, which 

documents daily operational events.

d) Copy of Navigation Rules (33 CFR 88.05)

e) Navigation charts/maps (33 CFR 164.72(b)(1))

f) Tide and Current Tables (33 CFR 164.72(b)(2)

g) Coast Pilot (33 CFR 164.72(b)(2))

h) Light List (33 CFR 164.72(b)(2))

i) Notice to Mariners (33 CFR 164.72(b)(2))

j) VTS Manual (33 CFR 161.4)

k) FCC radio station license posted in pilothouse (33 CFR 164.72(a)(3)(47 CFR 80.405)

l) Radiotelephone log (47 CFR 80.409)

m) Certificate of Financial Responsibility (33 CFR 138.12)

n) Copy of demise charter (33 CFR 138.100)

o) Station bill

The Master of each towing vessel must post a station bill in one or more conspicuous locations 

onboard the towing vessel. Locations of station bills must be such that all towing vessel 

crewmembers and other persons onboard the towing vessel are adequately informed of their 

emergency response stations and primary duties for emergency situations such as fire, manoverboard, collision/allisions, and sinkings. The towing vessel’s station bill must be coordinated 

with the towing vessel’s emergency response procedures contained in the Company’s Safety 

Management System.

p) Employee Assistance Program – display of informational material, hotline telephone 

number and employer’s drug and alcohol policy (46 CFR 16.401(a))

q) ITC tonnage certificate (46 CFR 69.69)
-14- Appendix A

r) IMO documents, e.g., SOLAS, ISM, ISSC (Vessels over 500 GT on Int’l voyages (varies 

by build date), see NVIC 11-93 Change 3)

8) Manning and Watchstanding

a) Minimum watch complement

Each towing vessel engaged in towing operations shall have a licensed master. If operations 

exceed 12 hours, an additional licensed officer (master, mate, or pilot) must be added or an 

alternate relief crew provided. One licensed officer and one additional crewmember must be on 

duty at all times while the vessel is underway. These requirements shall be posted on the 

vessel’s Certificate of Inspection. 

Additional manning shall be provided as specified in the vessel’s safety management system, 

taking into account the following factors: applicable law and regulation; number, size, and type 

of barges to be towed; towing route; safety of personnel, equipment, and environment; service in 

which the tow is engaged; functional duties required of crew in addition to standard navigation; 

configuration of vessel superstructure, deck, and engine room; extent of automation; size and 

power of equipment used; prevailing environmental/climatic conditions; and, experience of crew. 

b) Working hours 

Existing work hour requirements for persons operating towing vessels (46 USC 8104(h), or 46 

USC 8104(c) for Great Lakes towing vessels) remain in effect.

Except as provided under 46 USC 8104(h) or 46 USC 8104(c), no crewmember on a towing 

vessel may work more than 15 hours in any 24-hour period or more than 42 hours in a 72-hour 

period, except in an emergency or drill.1

c) Watches (46 CFR 15.705)

d) Vessel operator(s) properly licensed and endorsed for vessel route (46 CFR 15.610)

e) Discharges and shipping articles (46 CFR Part 14)

f) Vessel crew properly documented (46 CFR 12.02-7)

g) Drug and alcohol testing (46 CFR Part 16)

h) Operating a vessel while intoxicated (33 CFR 95.015 and 95.020)

i) Navigation underway (33 CFR 164.78)

j) Tests, inspections, and voyage planning (33 CFR 164.80)

9) Training

a) Fire fighting (46 CFR 27.209)

b) PIC for oil transfers (33 CFR 155.710(e))

 

1

 The working group considered, but did not adopt, a recommendation that all crewmembers receive a 

minimum of six hours of uninterrupted rest in every 24-hour period. Ten working group members supported 

including such a recommendation in the working group report to TSAC.
-15- Appendix A

c) Fire fighting certificate for oceans towing license (46 CFR 10.205(g)(3))

d) First Aid and CPR certificates for towing license (46 CFR 10.205(h))

e) Radar Observer (46 CFR 10.480)

10) Safety and Health

a) Posted safety notices/placards/warning signs

b) Cargo knowledge based on barge service (e.g., Subchapters N, D, O)

c) Benzene (where applicable based on barge service)
UTV Industry Preliminary Cost Assessment 2-1 Abt Associates Inc.  August 28, 2006 

Attachment 2 

The Towing Assistance Industry 

The TSAC RWG recommends exempting vessels in the towing assistance industry from future 

Coast Guard regulations for the UTVs. In general, towing assistance vessels are generally small, 

open vessels. This attachment discusses the towing assistance industry and provides estimated 

costs of bringing towing assistance vessels into compliance with the Conference of Private 

Operators for Response Towing’s (C-PORT) accreditation (ACAPT) program, which is a 

voluntary program requiring marine assistance vessels to meet certain service, training, and 

equipment standards. 

Background 

The towing assistance industry arose in 1983 with the privatization of the U.S. Coast Guard’s 

non-emergency towing and salvage operations. In that year, Representative Gerry Studds (DMA) passed a law prohibiting the Coast Guard from competing with private towing companies; 

the towing assistance industry has since grown from 10 to over 300 companies offering 24-hour 

towing assistance services throughout the year. The industry comprises numerous small 

operators, as well as a number of large operators that offer towing service memberships similar 

to the American Automobile Association (AAA) for automobiles, such as Boat/U.S. 

(www.boatus.com) and Sea Tow (www.seatow.com). 

Conversations with Boat/U.S. indicate that they do not require training or certifications, beyond a 

captain’s license with a towing endorsement, for boat operators in their association. Required 

equipment lists are available from the company when one requests a candidate package.1

 

Information from Sea Tow’s Web site indicates that Sea Tow boats are typically equipped with 

multiple Digital Selective Calling (DSC)-capable VHF radios, Global Positioning System (GPS) 

chart plotters, radar, VHF-based directional finders, depth sounders, and other electronics. 

The Conference of Private Operators for Response Towing (C-PORT) is the national marine 

assistance and salvage industry association, and has a membership of over 230 independent and 

network-affiliated marine assistance operators across the country. C-PORT administers the 

ACAPT (Accredited for Commercial Assistance and Professional Towing) accreditation 

program, a voluntary program requiring marine assistance vessels to meet certain service, 

training, and equipment standards. 

Accredited surveyors for the ACAPT program and C-PORT have agreed on a $65.00 per vessel 

survey fee for simple, streamlined surveys.2

 Equipment costs are expected to be minimal 

because most C-PORT members and ACAPT-certified companies already meet ACAPT 

standards. While ACAPT companies must pay for the first inspection of their vessels, C-PORT 

will pay for random vessel inspections of 10 percent of marine assistance vessels annually. 

 

1

 Personal communication with Anne Sooby, Boat U.S., on February 28, 2006. 

2

 There is also an ACAPT fee of $35.00 per vessel for C-PORT members and $60.00 per vessel 

for non-members. 
UTV Industry Preliminary Cost Assessment 2-2 Abt Associates Inc.  August 28, 2006 

ACAPT recognizes three tiers of vessels: utility, coastal, and ocean.3 ACAPT requires 

compliance with certain standards for all three tiers in addition to tier-specific standards. Exhibit 

2-1 summarizes standards required for ACAPT certification, including U.S. Coast Guard safety 

equipment standards required of all vessels.

 

3

 Utility vessels are small, travel short distances, and carry minimum equipment. Coastal vessels are mid-size, are 

limited to a maximum response distance of 30 miles from the nearest safe harbor, and carry more equipment than 

utility vessels. Ocean vessels are larger, are not limited to maximum response distances, and carry the highest level 

of equipment. The ACAPT committee expects that the largest number of marine assistance vessels will fall into the 

“coastal” tier. Information from C-PORT Web site, accessed at http://www.c-port.org/acapt/three_tier.html on 

February 27, 2006. 
UTV Industry Preliminary Cost Assessment 2-3 Abt Associates Inc.  August 28, 2006 

Exhibit 2-1 

ACAPT Accredited Applicant Company Standards 

U.S. Coast Guard Safety 

Equipment 

Requirements 

Fuel tank installation 

Backfire flame arrester 

Engine compartment ventilation appropriate for engine type 

Navigation lights 

Sound producing device and/or bell 

Fire extinguishers required by regulations 

Distress signals (at least 3 day/night flares within expiration date) 

Garbage disposal placard 

Oil pollution placard 

Additional ACAPT 

Requirements 

Copy aboard of USCG Operators License with towing endorsement (masters>200t are exempt) 

Copy aboard of base station license 

Copy aboard of vessel CG documentation (if>26 feet unless exemption for vessel exists) 

Company Service 

Standards 

(Copies sent to C-PORT 

for verification) 

All operators/crew enrolled in random drug testing program 

Towing liability insurance ($300,000 minimum coverage) 

24 hr response available during local boating season 

Service price list established and publicly available 

Backup vessel arrangement if firm only has one vessel 

Company has at least one year of experience in towing/salvage or search and rescue 

Utility Tier Standards 

Operational limit – does not travel farther than 10 miles from the nearest safe harbor 

Minimum crew – one 

Boat length – minimum 15 feet 

Power – minimum 35 hp outboard 

Crew PFD – Type 3 or better 

PFDs – Type 2 or better, two adult 

Lifesaving – throwable device 

Communications – one VHF 

Depth Sounder 

Tow line – minimum 100 feet of 1⁄2 inch 

Tow post or reinforced towing cleats or transom eyes that have been strength inspected 

De-watering capacity (any type) 

Appropriate COLREGS lights 

Tools onboard – knife to cut towline, boat hook, compass, fenders or equivalent 

Anchor 

Coastal Tier Standards 

Operational limit – does not travel farther than 30 miles from nearest safe harbor 

Minimum crew – one 

Boat length – minimum 21 feet 

Power – minimum 150 hp gas or 90 hp diesel 

Crew PFD – Type 3 or better 

PFDs – Type 2 or better, 2 adult and 4 children 

Lifesaving – one exposure suit recommended, but not required 

Communications – Two VHF and alternate communications device 

Depth sounder or lead line 

Tow line – minimum 300 feet of 5/8”, 600 feet recommended 

Tow post or reinforced towing cleats or transom eyes that have been strength inspected 

De-watering capacity – minimum 25 gpm from any power source 

Lighting – appropriate COLREGS lights, 50,000 candle power spotlight 

Tools onboard – knife to cult towline, boat hook, compass, fenders or equivalent, binoculars 

recommended, tools to change own plugs, belts, and filters, jump start system 

Anchor and chain sized to vessel and appropriate for area of response 

Radar if over 26 feet 

Loran or GPS 
UTV Industry Preliminary Cost Assessment 2-4 Abt Associates Inc.  August 28, 2006 

Loud hailer (recommended) 

Charts (paper or electronic) 

Damage control – material for stuffing into and stopping leaks 

Spare belts and filters for vessel 

Red/yellow safety lights authorized to meet USCG requirements 

Ocean Tier Standards 

Operational limit – boat’s endurance assuming proper crew 

Minimum crew – 2 when past 40 miles 

Boat length – minimum 26 feet 

Power – minimum 150 hp, twin outboards acceptable 

Crew PFD 

PFDs – Type 2 or better, 6 adult, 2 child 

Lifesaving – 2 exposure suits recommended or life raft 

Communications – 2 VHFs, alternate communications device & SSB recommended when out of local 

VHF range 

Depth sounder 

Radar & reflector 

Loran or GPS 

Loud hailer 

ADF 

EPIRB – 406 required 

Charts – paper required 

Tow line – minimum 600 feet of 3⁄4” 

Tow post 

De-watering capacity – minimum 100 gpm from any power source 

Lighting – appropriate COLREGS lights, 50,000 candle power spotlight, deck lights & underwater 

flashlight 

Tools – knife to cut towline, boat hook, compass, binoculars, tools to change own plugs, belts, filters, 

jump start system, wrenches, pliers, screwdrivers and fenders or equivalent 

Anchor with chain sized to vessel (minimum 125 feet rode) 

Damage control – material for stuffing into and stopping leaks 

Spare belts and filters for vessel and 200 feet extra line 

Red/Yellow safety lights authorized to meet USCG requirements 

Drogue 

ACAPT Professional 

and Ethical Standards 

Applicant company and representatives 

Will conduct business practices in full compliance with all applicable federal and state laws and 

regulations 

Will not use deceptive or misleading statements relating to estimated time of arrival on scene 

Will not unlawfully transmit by radiotelephone for the purpose of disrupting or interfering with the 

radio telephone communications of others, key the mike or step on transmissions of boaters or 

other providers, or intervene in communication between boaters and another towing company 

specifically contacted by the boater 

Will endeavor to communicate rates and any grounding surcharges prior to commencing work, and 

obtain customer’s signature on final invoice 

Will not post-date invoices for towing or salvage services 

Will not use advertising language and methods that are deceptive or misleading 

Will conduct all business dealings with members of the public in a fair, consistent, professional, and 

ethical manner 

Will apply all standards and business practices without regard to a customer’s insurance practices 

Will use his or her best efforts to cooperate with all available resources to prevent damage or loss to 

life or property 

Source: C-PORT, Year 2005 ACAPT Accreditation Application, accessed at http://www.c-port.org on February 27, 2006. 
UTV Industry Preliminary Cost Assessment 2-5 Abt Associates Inc.  August 28, 2006 

Estimated Costs of Complying with C-PORT ACAPT 

In 2005, C-PORT conducted a survey to determine the composition of member and nonmember companies operating in the assistance towing industry. Nearly 120 companies 

nationwide completed and returned the survey, representing approximately one third of 

the industry. The survey asked participants to quantify the cases they handled in the 2005 

calendar year, and to describe their operations and safety equipment. Overall, the survey 

found that respondents responded to more than 120,000 assistance-towing incidents in 

2005. The survey also reported that the industry generated approximately $72 million in 

total revenue, and provided employment for more than 800 full-time captains and more 

than 1,000 part-time captains, as well as technicians needed to maintain an estimated fleet 

of over 1,000 towing vessels.4

 The survey also revealed that all respondents reported 

compliance with USCG requirements for safety equipment and, in most cases, exceeded 

those requirements.5

Exhibit 2-2 summarizes the findings of the survey with respect to the number of towing 

companies that require vessels to abide by C-PORT-selected criteria related to operations 

and safety equipment, and the average cost of achieving these criteria. The cost of 

wearing a personal flotation device (PFD) and the cost of a vessel/equipment daily 

checklist were not requested in the survey and are thus not included in the Exhibit 2-2. 

Exhibit 2-2 

Average Costs of Selected C-PORT Criteria 

Operations and Safety

Equipment Criteria 

Criteria is Required by 

Towing Companies 

Criteria is Not Required 

by Towing Companies 

Average 

Reported 

Cost 

Surveyed Vessels 101 12 $327 

Wearing of PFD 74 45 NR 

Ref/SOP Manual 39 80 $1,276 

Daily Checklist 82 37 NR 

Training Program 110 10 $1,002 

NR = Not Reported

 

4

 From C-PORT Assistance Towing Industry Survey Results, 2005, Captain Terry Hill, Chairman of CPORT. 

5

 Ibid. 

UTV Industry Preliminary Cost Assessment 3-1 Abt Asso

Attachment 3 

Contact Information for Telephone Interviews and Surveys 

Exhibit 3-1 

Contact Information for Telephone Interviews and Surveys 

Name of Company Interviewee Position Location Da

Equipment Standards Robert Allen Ltd. Vancouver, BC 2Timothy Graul Marine Design Mark Pudlow Sturgeon Bay, WI 2Jensen Marine Consultants Seattle, WA 5Elliot Bay Design Group Jim Cole Seattle, WA 5Genoa Design International Darren Liddle Conception Bay South, 

Newfoundland 

5

Guido Perla & Associates Alex Louden Seattle, WA 5Moran Towing Paul Swensen Vice President General 

Manager 

Baltimore, MD 

Potomac Marine Mike Cahill Woodbridge, VA Excom Marine Paul Stroop Flint, MI ComNav Marine Ltd. Satish Narayn Richmond, BC CANADA Paxton Marine Bill Siddle Marine Distributor Norfolk, VA Bollinger Shipyards Travis Aucoin New Construction 

Estimator 

St. Rose, LA 

Recovered Energy Gary Chandler Oak Brook, IL Coffin World Water Systems Jeff Belotti Irvine, CA Village Marine Andy Kennett Sales Gardena, CA Sawyer and Whitten Marine Electronics Sam Serappa Sales Protland, ME Englund Marine and Industrial Supply Co. Inc. 

 Sales Astoria, OR 

Life Raft and Survival Equipment, Inc. Dan O'Conner Portsmouth, RI 10Atlantic Marine Chuck Nugent Estimator Jacksonville, FL 
UTV Industry Preliminary Cost Assessment 3-2 Abt Asso

Lyon Shipyard Danny Davis Estimator Norfolk, VA 

Drydocking A&B Industries Morgan City, LA 17BAE Systems Ira Maybaum General Manager San Francisco, CA 1Bay Ship and Yacht Company Alameda, CA 2Diversified Marine, Inc. Portland, OR 2Elmwood Drydock and Repair Wayne Thibodeaux Sales/New Construction 

Manager 

St. Rose, LA 1

Seward Ship's Drydock, Inc. Seward, AK 2Safety Management System Auditors American Bureau of Shipping Pat Farwell ABS Auditor Houston, TX 1American Bureau of Shipping Martin Hruska Manager Houston, TX 1Teicheira Maritime Surveyors Dana Teicheira Company founder Petaluma, CA 2Maritime Compliance International LLC Kevin Gilheany President New Orleans, LA 22Rushing Marine Service, LLC Mike Rushing Marine Consultant and 

Safety Program Manager

Jackson, MO 22

M&P Enterprises Mike Bowen Auditor The Woodlands, TX 17MRR Management Consultants Michael Reynolds Auditor Springfield, MA 2SQE Marine Consultants Ron Borison President St. Bernard, LA 2WH Padie Associates Inc. W.H. Padie Auditor Mercer Island, WA 2Vessel Companies Kirby John Baker Corp Quality Manager Houston, TX 10Seabulk Towing Doug Carlson Safety and QA Manager Tampa, FL 3Tidewater Barge Lines Inc John Pigott General Manager Vancouver, WA 10
UTV Industry Preliminary Cost Assessment 4-1 Abt Associates Inc. ▪ August 28, 2006

Attachment 4 

Copy of the Leave-Behind Questionnaire (Full and Abbreviated Versions) 
Abt Associates Inc. January 6, 2006 1

Questionnaire for Collection of Burden and Expense Information 

From Towing Companies and Vessels 

Note: Responding to any portion of this questionnaire is completely voluntary. You are not required to 

respond to any collection of information unless it displays a currently valid OMB control number.

INSTRUCTIONS 

Please provide estimates for each of the four categories below, as they apply to a towing vessel at your 

company. 

• For categories that relate to capital expenses, please estimate an average annual amount spent 

in US $. (An estimate for calendar year 2005 or your most recent fiscal year should be sufficient.) 

• For categories that relate to hours or time spent, please provide burden estimates in total personhours. This refers to the number of hours of paid staff time expended for each activity. 

• For categories that include periodic or repeating events/expenses, please estimate the frequency 

(e.g., annual, monthly, etc.). 

BASIC INFORMATION 

Company Name/Affiliation: __________________________________________________________ 

Job Title: __________________________________________________________ 

Phone Number: __________________________________________________________ 

E-mail Address: __________________________________________________________ 

City and State: _____________________________, ______ 
Abt Associates Inc. January 6, 2006 2

1. SAFETY MANAGEMENT SYSTEM (SMS)

An SMS may consist of multiple components including operating procedures, personnel policies and 

procedures, emergency preparedness and response procedures, and training. Please provide an 

estimate of the number of hours or dollars associated with each SMS component that you currently 

implement and/or maintain. 

If you do not maintain a formal safety management system, please check the box below, but still provide 

responses for each type of procedures/policies below that you may implement and/or maintain 

independently of an SMS. 

 I do not maintain an SMS. 

SAFETY MANAGEMENT SYSTEM COMPONENTS COST HOURS FREQU

-ENCY

1. DEVELOPING AND IMPLEMENTING THE SMS 

A. Hours required for initial development of the entire SMS? 

B. Hours required for periodic update of the SMS? 

C. Hours required for staff training on overall SMS? 

D. Hours required for internal audits of SMS? 

E. Do you outsource SMS development?  YES  NO 

What is the cost of outsourcing? 

What is the cost of developing an SMS internally? 

$ 

$ 

F. Does each vessel at your company have an individual SMS or is a company-wide 

SMS in place?  Individual  Company 

G. Has there been an improvement in your overall safety record due to implementation of an SMS? 

 NO  N/A 

 YES If yes, please explain: 

 

2. EMERGENCY PREPAREDNESS AND RESPONSE PROCEDURES

A. Hours required to develop procedures to identify, describe and respond to 

potential emergency shipboard situations? 

 

B. Hours required to training staff on emergency preparedness and response 

procedures? 

 

C. Hours required to conduct drills and exercises to prepare for emergency actions? 

D. Hours required for recordkeeping related to emergency preparedness and 

response? 

 
Abt Associates Inc. January 6, 2006 3

SAFETY MANAGEMENT SYSTEM COMPONENTS COST HOURS FREQU

-ENCY

E. Has your average incident response time decreased due to implementation of emergency preparedness and response 

procedures? 

 NO  N/A 

 YES If yes, please explain: 

 

3. INCIDENT REPORTING

A. What is the job title of the person responsible for incident reporting? 

B. Hours associated with reporting an incident (e.g., non-conformities, accidents and 

hazardous situations) including completing paperwork? 

 

C. Hours required to investigate incidents? 

D. Hours required to undertake corrective actions? 

 

4. VESSEL OPERATING AND MAINTENANCE PROCEDURES

A. What is the job title of the person responsible for carrying out operating and 

maintenance procedures? 

B. Hours required for inspection and maintenance/repair of superstructure? 

C. Hours required for inspection and maintenance/repair of hull? 

D. Hours required for inspection and maintenance/repair of equipment, appliances, 

and propulsion machinery? 

 

E. Hours required for inspection and maintenance/repair of auxiliary machinery? 

F. Hours required for inspection and maintenance/repair of piping? 

G. Hours required for inspection and maintenance/repair of rigging or towing gear? 

H. Hours required for recordkeeping for inspection and maintenance/repair? 

I. Have there been fewer equipment failures and related incidents due to implementation of operating and maintenance 

procedures? 

 NO  N/A 

 YES If yes, please explain: 

5. PERSONNEL POLICIES, PROCEDURES AND RESPONSIBILITIES

A. What is the job title of the person responsible for overseeing personnel policies 

and procedures? 

 

B. How many hours are required for initial training programs such that workers are 

given proper familiarization with their duties and have an adequate understanding of 

relevant rules, regulations, codes, and guidelines. 

 

C. How many hours are required periodic refreshers training programs such that 

workers are given proper familiarization with their duties and have an adequate 

understanding of relevant rules, regulations, codes, and guidelines. 

 
Abt Associates Inc. January 6, 2006 4

SAFETY MANAGEMENT SYSTEM COMPONENTS COST HOURS FREQU

-ENCY

6. SAFETY AND HEALTH POLICIES/PROCEDURES

A. Cost of personal protective equipment: initial purchase? $ 

B. Hours of training required for personal protective equipment use? 

C. Hours required for personal protective equipment inspection and maintenance? 

D. Hours required for hazard communication and cargo knowledge? 

E. Cost of posting safety notices/placard/warning signs? $ 

F. Hours required to develop safety training program? 

G. Hours required to perform safety program drills? 

H. Hours required for safety meetings? 

I. On average, how many work days per year are lost due to safety and health policy 

and procedure-related issues? 

K. Have there been fewer accidents/injuries and/or safety and health-related worker absences due to implementation of 

safety and health policies and procedures? 

 NO  N/A 

 YES If yes, please explain: 

7. OTHER DOCUMENTATION/ RECORDKEEPING

A. Hours required to maintain vessel log, documents, or publications including but 

not limited to Certification Documentation, Navigation charts/maps, or 

Radiotelephone log? Total cost may be reported in hours or broken down by 

documentation. 

 
Abt Associates Inc. January 6, 2006 5

SAFETY MANAGEMENT SYSTEM COMPONENTS COST HOURS FREQU

-ENCY

ADDITIONAL NOTES
Abt Associates Inc. January 6, 2006 6

2. DRYDOCKING AND UNDERWATER INSPECTIONS

Below is a list of costs associated with drydocking and underwater inspections. To the extent possible, 

please provide an estimate for each cost in hours and or dollars. 

DRYDOCKING AND UNDERWATER INSPECTIONS COMPONENTS COST

HOURS 

PER 

YEAR

FREQU

-ENCY

 

1. TIME IN PORT AND ASSOCIATED LOST PRODUCTIVITY, DELAY COSTS, AND LOST PROFITS

A. How many hours are associated with arriving at port for inspection? 

B. What is the cost of productivity lost to time required for inspections? [Example: 

Delay costs can be estimated by multiplying average hourly or daily productivity by 

time in port.] 

$ 

C. How often do you conduct a drydock inspection? 

 

2. INSPECTION OF ITEMS SUCH AS HULL; TAIL SHAFTS; RUDDERS; PROPELLERS; COOLERS; SEA CHESTS AND THROUGH-HULL FITTINGS

A. On average, how many hours are required for inspection? 

B. What is the cost of training inspectors for drydock inspection? $ 

 

3. INTERNAL STRUCTURE EXAMS: COSTS ASSOCIATED WITH ACCESSING CONFINED SPACES FOR EXAM

A. What is the cost and time required to remove hazardous wastes (e.g. oil), clean 

the tanks, and certify/maintain a gas free atmosphere? 

$ 

 

4. DOCUMENTATION OF INSPECTIONS [FOR REVIEW BY COAST GUARD OR APPROVED THIRD-PARTY AUDITOR] 

A. How is paperwork maintained? Is there a cost of storing documentation? 

 

5. UNDERWATER INSPECTIONS

A. How many hours are required to prepare for the inspection – including time 

associated with positioning vessel for proper inspection, or linking up with 

inspector? 

 

 
Abt Associates Inc. January 6, 2006 7

3. AUDITING PROGRAMS

Below is a list of costs associated with auditing programs. To the extent possible, please provide an 

estimate for each cost in hours and or dollars. 

AUDITING PROGRAMS COST

HOURS 

PER 

YEAR

FREQUENCY

 

1. COST OF AUDITING PROGRAMS AND COMPONENTS 

A. How many hours are required to develop an internal auditing program? 

B. What is the cost of third-party five-year audits (hours of work lost to allow 

audit)? 

$ 

C. What is the cost of external auditor(s)? $ 

D. How many productive hours are lost as a result of external audits? 

ADDITIONAL NOTES
Abt Associates Inc. January 6, 2006 1

Questionnaire for Collection of Burden and Expense Information 

From Towing Companies and Vessels 

Note: Responding to any portion of this questionnaire is completely voluntary. You are not required to 

respond to any collection of information unless it displays a currently valid OMB control number.

INSTRUCTIONS 

Please provide estimates for each of the four categories below, as they apply to a towing vessel at your 

company. 

• For categories that relate to capital expenses, please estimate an average annual amount spent 

in US $. (An estimate for calendar year 2005 or your most recent fiscal year should be sufficient.) 

BASIC INFORMATION 

Company Name/Affiliation: __________________________________________________________ 

Job Title: __________________________________________________________ 

Phone Number: __________________________________________________________ 

E-mail Address: __________________________________________________________ 

City and State: _____________________________, ______ 

1. SAFETY MANAGEMENT SYSTEM (SMS)

An SMS may consist of multiple components including operating procedures, personnel policies and 

procedures, emergency preparedness and response procedures, and training. Please provide an 

estimate of the number of hours or dollars associated with each SMS component that you currently 

implement and/or maintain. 

If you do not maintain a formal safety management system, please check the box below, but still provide 

responses for each type of procedures/policies below that you may implement and/or maintain 

independently of an SMS. 

 I do not maintain an SMS. 

SAFETY MANAGEMENT SYSTEM COMPONENTS COST TIME FREQU

-ENCY

1. DEVELOPING AND IMPLEMENTING THE SMS 

A. Time required for development of the SMS? 

B. Time required for periodic update of the SMS? (Best guess or ignore) 
Abt Associates Inc. January 6, 2006 2

SAFETY MANAGEMENT SYSTEM COMPONENTS COST TIME FREQU

-ENCY

C. Time and cost required for staff training on overall SMS? 

E. Do you outsource SMS development?  YES  NO 

What is the cost of outsourcing? $ 

F. Does each vessel at your company have an individual SMS or is a companywide SMS in place?  Individual  Company 

G. What is the most time intensive component of developing an SMS? 

H. Has there been an improvement in your overall safety record due to implementation of an SMS? 

 NO  N/A 

 YES 

 

3. INCIDENT REPORTING

B. Time associated with reporting an incident (e.g., non-conformities, accidents 

and hazardous situations) including completing paperwork? 

D. Time required to undertake corrective actions? 

7. OTHER DOCUMENTATION/ RECORDKEEPING

A. Time required to maintain vessel log, documents, or publications including but 

not limited to Certification Documentation, Navigation charts/maps, or 

Radiotelephone log? You may report this as one total cost. 

ADDITIONAL NOTES

2. DRYDOCKING AND UNDERWATER INSPECTIONS

Below is a list of costs associated with drydocking and underwater inspections. To the extent possible, 

please provide an estimate for each cost in hours and or dollars. 

DRYDOCKING AND UNDERWATER INSPECTIONS COMPONENTS COST TIME

FREQU

-ENCY

 

1. TIME IN PORT AND ASSOCIATED LOST PRODUCTIVITY, DELAY COSTS, AND LOST PROFITS

A. How long does it take to arrive at port for inspection? 

B. What is the cost of renting space for a drydock? $ 
Abt Associates Inc. January 6, 2006 3

DRYDOCKING AND UNDERWATER INSPECTIONS COMPONENTS COST TIME

FREQU

-ENCY

C. How often do you conduct a drydock inspection? 

 

2. INSPECTION OF ITEMS SUCH AS HULL; TAIL SHAFTS; RUDDERS; PROPELLERS; COOLERS; SEA CHESTS AND THROUGH-HULL FITTINGS

A. On average, how many hours are required for inspection? 

B. What is the cost of training inspectors for drydock inspection? $ 

 

3. INTERNAL STRUCTURE EXAMS: COSTS ASSOCIATED WITH ACCESSING CONFINED SPACES FOR EXAM

A. How long does it take to conduct internal inspections? 

 

4. DOCUMENTATION OF INSPECTIONS [FOR REVIEW BY COAST GUARD OR APPROVED THIRD-PARTY AUDITOR] 

A. How is paperwork maintained? Is there a cost of storing documentation? 

 

5. UNDERWATER INSPECTIONS

A. How many hours are required to prepare for the inspection – including time 

associated with positioning vessel for proper inspection, or linking up with 

inspector? 

 

 

3. AUDITING PROGRAMS

Below is a list of costs associated with auditing programs. To the extent possible, please provide an 

estimate for each cost in hours and or dollars. 

AUDITING PROGRAMS COST

HOURS 

PER 

YEAR

FREQUENCY

 

1. COST OF AUDITING PROGRAMS AND COMPONENTS 

A. How many hours are required to develop an internal auditing program? 

B. What is the cost of an internal audit $ 

C. What is the cost of a third-party audit? $ 
Abt Associates Inc. January 6, 2006 4

AUDITING PROGRAMS COST

HOURS 

PER 

YEAR

FREQUENCY

D. How long is a third party audit? 

ADDITIONAL NOTES