This article from Oct, 2010 Feds' Foggy Reply to Tug Crewing Questions. (found via the post Why TC does not comment at The Monitor ) is about confusion at Transport Canada regarding tug manning regulations for tugs doing ship assist work in Vancouver Port. The article is worth a quick read, this caught my eye:
what about the assertion from Transport Canada that it is up the vessel master to ensure safe crewing requirements?Vessel manning is up to the vessel's master? Is that supposed to be a joke? How many vessel masters have any say about manning? None that I know of.
Regulators making critical decisions may or may not have an accurate understanding of the industry they are regulating and to avoid making unwarranted assumptions and so forth, regulators require advice from people with expertise - which leads me to link to Towmaster post: TSAC Reformed?: Mariners Get Official Seats At The Table, Maybe regarding the USCG's Towing Safety Advisory Committee (TSAC) which is supposed to
"advise the Secretary of Transportation, via the Commandant, U.S. Coast Guard, on matters relating to shallow-draft inland and coastal waterway navigation and towing safety.It's no secret among mariners that Coast Guard regulation philosophy tends to lean heavily towards management in writing and applying regulations. I doubt that a mariner with a seat on the TSAC will be able to tilt things much towards the working mariner but at least the right person might keep things a little more realistic then our friends in Vancouver Port