One of the unintended consequences of Subchapter M is the triggering of 33 CFR 155.710(e)(1) which requires the PIC onboard an inspected vessel transfering fuel oil requiring a Declaration of Inspection (DOI) hold an MMC authorizing service as a master, mate, pilot, engineer, or operator as per 46 CFR Part 11 OR a valid MMC endorsed as Tankerman PIC as per 46 CFR Part 13.
A towing vessel’s transition to inspected status triggers the above requirement.
On 03/10/2017 the Coast Guard issued a policy letter providing guidance for issuing Merchant Mariner Credential (MMC) endorsements of Tankerman Person In Charge (PIC) Restricted to Fuel Transfers on Towing Vessels.