Advancing the safe operation of small tugs

Location: National

Issue/Source: Advancing the safe operation of small tugs

Date: November 29, 2022

Suggested responses

  • Transport Canada is committed to the promotion of a safe, secure, efficient, and environmentally responsible marine transportation system in Canada, including the safe operation of all vessels.
  • Improving safety in the tug and workboat industry is a priority for Transport Canada.
  • Small tugs are subject to risk-based monitoring inspections by Transport Canada to verify compliance with the requirements under the Canada Shipping Act, 2001.
  • To strengthen the safety of the tug and barge industry, Transport Canada is making updates to Canada’s marine safety regulatory regime, reinforcing compliance, and promoting a culture of safety.

If pressed on how Transport Canada is Advancing Safety

  • In January 2022, Transport Canada launched a new component for the existing Small Vessel Compliance Program that is specific to tugs. This component provides owners and operators an easy-to-use tool to better understand and meet the requirements and legal obligations for small vessels.
  • TC has directly contacted all small tug owners to inform them about this new component for the compliance program and to encourage their participation. To date 77 vessels have submitted their applications to enroll in the program.
  • Additionally, the Pacific Regional Tow and Workboat Safety Advisory Group was established in January 2022 providing a forum to promote best practices and awareness of authorities, as well as discuss issues of mutual concern.

If pressed on tugboat Ingenika

  • TC is committed to safety on all small vessels including tugs in Canada. The sinking of the tugboat Ingenika is still under investigation by the Transportation Safety Board.
  • Transport Canada has launched the Small Vessel Compliance Program for tugs and monitoring inspections on the West Coast of British Columbia to assess the safety conditions of the tug fleet overall.
  • The department has also put in place a new vessel oversight program for small vessels under 15 gross tonnage including tugs. A total of 248 tugs inspections have been carried out since April 1, 2022, of which 61 have been performed on tugs of less than 15 gross tonnage.

Background Information

  • Over the past years, incidents with tugs have continued to raise attention, particularly on the west coast, where the use of tugs and barges is common and essential to the regional supply chain.
  • There is a perception that there is a lack of regulatory compliance with the operation of tugs that are smaller than 15 gross tonnage (approx. 12 meters), as vessels below 15 gross tonnage are not subject to mandatory inspection by Transport Canada. Small tugs are subject to risk-based monitoring inspections by Transport Canada to verify compliance with the requirement of relevant regulations under the Canada Shipping Act, 2001.
  • The Canada Shipping Act, 2001 requires all vessel owners to implement procedures for the safe operation of the vessel and for dealing with emergencies, and compliance with applicable regulations is mandatory for all vessels, whether the vessel is inspected or not.
  • In an effort to provide a cohesive reference document to the multiple regulatory requirements and standards that are applicable to smaller tugs, including tugs of less than 15 gross tonnage, Transport Canada has published the Guidelines for the Construction, Inspection, Certification, and Operation of Tugs < 24 Metres in Length - TP 15180 E.
  • The Department is committed to continue to review and improve these existing guidelines for tugs. For tugs below 15 gross tonnage, Transport Canada published an additional set of guidelines with the launch of the Small Vessel Compliance Program for Tugs (SVCP-T).
  • In terms of transparency, guidelines are public, and must be considered in the company’s Safety Management System development. If there are clear guidelines for a subject (e.g., minimum bollard pull determination for a tug), it is expected that it will be implemented in the Safety Management System. The proposed Marine Safety Management Regulations will be subject to administrative penalties up to $250,000.
  • Departmental officials are working with the provincial WorkSafe BC to expand the scope of an existing Memorandum of Understanding respecting worker safety on fishing vessels to also include tugs.
  • The Department is also working on a multi-pronged action plan to mitigate risk tied to seafarer fatigue. This includes regulatory amendments to the Marine Personnel Regulations, such as specifically defining what is not to be included in hours of rest.
  • A targeted monitoring inspection campaign to verify compliance of small tugs operating in the Pacific Region, where more than 75% of these vessels are operating, was implemented between mid-November 2021 and March 2022. A verbal update of the results of this campaign was provided at the national Canadian Marine Advisory Council on November 9, 2022. The region leveraged this targeted campaign to promote the enrollment into the Small Vessel Compliance Program for tugs.