A comprehensive study guide covering the ISM Code, Safety Management Systems, SOLAS drills, STCW watchkeeping, Subchapter M, GMDSS, and federal accident reporting — all tested on the USCG captain's license exam.
The International Safety Management (ISM) Code is the international standard for the safe management and operation of ships and for pollution prevention. It forms Chapter IX of the International Convention for the Safety of Life at Sea (SOLAS) and was adopted by the International Maritime Organization (IMO) through Resolution A.741(18) in 1993. The code became mandatory in phases beginning in 1998 for passenger vessels and by 2002 for most cargo vessels.
The core purpose of the ISM Code is to provide an international standard for the safe management and operation of ships and for pollution prevention. It establishes safety management objectives and requires every company and ship to develop, implement, and maintain a Safety Management System (SMS). The overarching principle is that safety at sea, prevention of human injury or loss of life, and avoidance of damage to the environment — especially the marine environment — and to property requires that all persons at all levels, ashore and aboard ships, apply the code's principles.
Under SOLAS Chapter IX, ISM Code compliance is mandatory for:
Domestic vessels not on international voyages are not subject to ISM unless they voluntarily adopt it. However, the USCG has incorporated ISM-equivalent principles into domestic regulations, particularly Subchapter M for towing vessels and various Subchapters covering passenger vessels. Exam candidates should understand that ISM is an international framework while domestic equivalents enforce the same safety culture philosophy under U.S. federal law.
The ISM Code establishes three core objectives that every Safety Management System must address:
Provide for safe practices in ship operation and a safe working environment, preventing human injury or loss of life.
Assess all identified risks to ships, personnel, and the environment and establish appropriate safeguards.
Continuously improve safety management skills of personnel ashore and aboard ships, including preparing for emergencies.
The ISM Code specifies twelve functional requirements that a compliant Safety Management System must address. Each element is separately audited during DOC and SMC verification surveys. The USCG exam frequently tests candidates on identifying which element covers a given safety function.
| Element | Title | Key Requirements |
|---|---|---|
| 1 | General | Objectives, application, and functional requirements of the SMS |
| 2 | Safety and Environmental Policy | Company policy stating safety and environmental protection goals; made known to all personnel |
| 3 | Company Responsibilities and Authority | Define company, designate responsible person, ensure resources and shore-based support |
| 4 | Designated Person Ashore (DPA) | Named individual with direct access to top management; monitors safety and pollution prevention |
| 5 | Master's Responsibility and Authority | Master has overriding authority and responsibility; company does not override safety decisions |
| 6 | Resources and Personnel | Ensure qualified and certificated seafarers; familiarization and training procedures |
| 7 | Development of Plans for Shipboard Operations | Key shipboard operations covered by documented procedures (navigation, cargo, maintenance) |
| 8 | Emergency Preparedness | Identify potential emergencies; establish programs for drills and exercises; respond effectively |
| 9 | Reports and Analysis of Non-Conformities, Accidents, and Hazardous Occurrences | Reporting system; root-cause analysis; corrective and preventive actions |
| 10 | Maintenance of Ship and Equipment | Planned maintenance system; inspections; critical equipment identification and redundancy |
| 11 | Documentation | SMS documents controlled; master copies ashore; relevant documents available on board |
| 12 | Company Verification, Review, and Evaluation | Internal audits; management review; SMS is effective and improving |
ISM Code Element 5 establishes one of the most exam-tested principles: the Master has overriding authority and responsibility to make decisions with respect to safety and prevention of pollution. The company must ensure that the SMS in no way restricts the Master from exercising this authority. This means a company cannot instruct a Master to proceed in conditions the Master believes are unsafe, even for commercial reasons. This principle is reinforced in STCW and in U.S. law under 46 U.S.C. 8501.
Exam Tip: Element 5 — Master's Authority
Questions about who has final authority on safety decisions always have the same answer: the Master. The company, owner, or charterer cannot override the Master's judgment on matters of safety. If an answer choice says "the company may instruct the master to proceed," that is always wrong under ISM.
The Designated Person Ashore (DPA) is one of the most frequently tested ISM concepts on the USCG captain's license exam. The DPA is required by ISM Code Element 4 and serves as the critical communication link between the ship and shore-based management.
The DPA must be specifically named in the SMS documentation — the role cannot be assigned generically to a position title. The individual must understand the ISM Code and the company's SMS, must have maritime operational experience or equivalent technical knowledge, and must have the authority to take immediate action on safety matters. In small companies, the DPA may be the company owner or president, but they must still meet the access and authority requirements. Large companies may have deputy DPAs for coverage during absences, but the primary DPA must be identified.
Q: Who must the DPA have direct access to?
A: The highest level of management in the company.
Q: Can the Master also serve as the DPA?
A: No — the DPA must be shore-based to ensure an independent link between ship and company.
Q: What ISM Code element covers the DPA?
A: Element 4 — Designated Person Ashore.
ISM Code compliance is verified through two separate certification documents issued by or on behalf of the flag State. Understanding the distinction between these two documents is essential for the exam.
Key Distinction for the Exam
DOC goes to the company. SMC goes to the ship. A ship cannot have an SMC unless the company has a valid DOC. If the DOC expires or is withdrawn, all SMCs issued to that company's vessels also become invalid.
The ISM Code requires a systematic audit process to verify that the SMS is being implemented effectively. There are two types of audits: internal audits conducted by the company itself, and external audits conducted by the flag State or a recognized organization acting on behalf of the flag State.
ISM Code Element 12 requires the company to carry out internal safety audits to verify whether safety and pollution-prevention activities comply with the SMS. Key requirements:
Frequency
At least annually for each vessel and for the shore office
Auditors
Personnel independent of the area being audited (not the same department)
Documentation
Written audit report identifying non-conformities and corrective actions
Follow-up
Verification that corrective actions were implemented and effective
DPA Role
DPA reviews audit findings and ensures corrective actions are completed
Records
Audit records retained and available for external verification
| Survey Type | Purpose | Timing | Result |
|---|---|---|---|
| Initial Verification | First-time compliance assessment | Before certificate issuance | Issues DOC or SMC |
| Annual Verification (DOC) | Confirm SMS still compliant | Within 3 months of anniversary date | Endorses existing DOC |
| Intermediate Verification (SMC) | Mid-period ship survey | Between 2nd and 3rd anniversary | Endorses existing SMC |
| Renewal Verification | Full re-survey for 5-year renewal | Before expiry of DOC or SMC | Renews certificate for 5 years |
| Additional Verification | Triggered by major non-conformity or casualty | As required by flag State | May suspend or withdraw certificate |
A non-conformity (NC) is an observed situation where objective evidence indicates the non-fulfillment of a specified requirement under the ISM Code or the company's SMS. NCs are the primary output of audits and must be formally tracked through to resolution. The exam tests candidates on the distinction between minor and major non-conformities and the timeframes for corrective action.
A single observed lapse that does not indicate a systematic failure of the SMS. Does not pose an immediate threat to safety or the environment.
Corrective Action Deadline: Before the next annual verification or as agreed with the auditor (typically within 3 months).
An identifiable deviation that poses a serious threat to the safety of personnel or the ship, or a serious risk to the environment requiring immediate corrective action. Also includes the absence of effective and systematic implementation of a requirement of the ISM Code.
Corrective Action Deadline: Immediate action required; may result in suspension of certificate until resolved.
Identify
Non-conformity is observed during internal or external audit and formally recorded
Root Cause Analysis
Determine why the NC occurred — the SMS requires understanding underlying cause, not just symptoms
Corrective Action Plan
Develop a specific plan to address root cause with assigned responsibility and target date
Implementation
Execute the corrective action as planned; update procedures if necessary
Verification
Confirm the corrective action was implemented and is effective
Close Out
Document closure and share lessons learned with other vessels in the fleet if applicable
SOLAS Chapter III (Life-Saving Appliances and Arrangements) establishes mandatory drill requirements for all covered vessels. Drill frequencies are among the most frequently tested facts on the USCG captain's license exam. Candidates must know not just what drills are required, but how often they must occur and what they must include.
| Drill Type | Cargo Ships | Passenger Ships | Key Requirements |
|---|---|---|---|
| Abandon Ship | Monthly (each crew member) | Within 24 hrs of departure if 25%+ crew change | Launch lifeboat or rescue boat, start engine, demonstrate don PFD |
| Fire | Monthly (each crew member) | Weekly | Muster at stations, check firefighting equipment, operate pumps and hoses |
| Rescue Boat / MOB | Monthly | Monthly | Lower rescue boat to water, maneuver, recover simulated MOB casualty |
| On-Board Training | Familiarity within 2 weeks of joining | Before departure | LSA instruction, onboard training program per SOLAS III/19.4 |
Abandon Ship Signal — Memorize This
6 or more short blasts + 1 prolonged blast
This signal on the ship's whistle and general alarm system is the internationally recognized signal for crew and passengers to muster at abandon-ship stations. It is also used during drills. Every crew member must know this signal and their assigned muster station.
Fire Alarm Signal
Continuous sounding of the general alarm
The general alarm is sounded continuously for a fire emergency. Crew muster at their designated fire stations with their assigned equipment. Firefighting drills must verify that crew know how to isolate ventilation to the fire zone, operate fixed firefighting systems, and use portable extinguishers.
All drills must be recorded in the ship's official logbook. The log entry must include the date and time of the drill, the type of drill, a description of what was done, and identification of any deficiencies discovered. USCG port state control officers routinely inspect drill logs during vessel examinations. A pattern of missing or irregular drill records is a major non-conformity that can result in detention of the vessel.
The muster list is a critical safety document required by SOLAS Chapter III and 46 CFR for all inspected vessels. It assigns every person on board — both crew and sometimes passengers — to specific emergency stations and details their duties during each type of emergency.
Muster lists must be posted in conspicuous locations throughout the vessel before the vessel sails. Required posting locations include the bridge, engine room, and crew spaces. Each crew member's cabin must have a card showing their personal muster station, fire station, and the meaning of the general alarm. Muster lists must be updated whenever there is a change in personnel, voyages, or emergency assignments, and the updated list must be posted before the next voyage.
Each officer and crew member must have a specific role in every type of emergency. Typical assignments include: officer of the watch coordinates bridge response, chief mate supervises abandon-ship operations at boat deck, chief engineer ensures engine room is secured and emergency generator is online, boatswain supervises forward emergency party, cook and stewards account for passengers and provide first aid. The key principle is that no emergency role can be left unassigned — if a vessel has minimum manning, every person must cover multiple roles and the muster list must reflect this.
For uninspected passenger vessels (UPVs) — vessels carrying 1–6 passengers for hire — 46 CFR Part 26 governs safety equipment and operational requirements. Section 26.03-3 specifically requires operators to brief passengers before or immediately after getting underway.
For inspected passenger vessels carrying more than 6 passengers, the requirements are more comprehensive under 46 CFR 185.506 (Subchapter T) and parallel provisions in Subchapters K and H. The safety orientation must include:
Exam Tip: Timing of Passenger Briefings
The exam often tests when the briefing must occur. The answer for UPVs (Part 26) is "before or immediately after getting underway." For SOLAS vessels, passenger muster must occur within 24 hours of embarkation on voyages of more than 24 hours' duration. On shorter voyages or day trips, the muster must occur before or immediately after departure.
ISM Code Element 6 requires that the company ensure seafarers receive proper familiarization with the vessel, its equipment, and its SMS before taking up duties. This is reinforced by STCW Section A-VI/1 and by domestic USCG regulations. Familiarization is distinct from drill participation — it is the initial orientation that ensures a new crew member can perform their duties safely from day one.
Before a seafarer is assigned any shipboard duties, the master or a designated officer must ensure the seafarer has been familiarized with:
A vessel safety committee is an ISM best practice and is required by many flag State implementations and company SMS documents. The safety committee provides a formal forum for crew to raise safety concerns, discuss near-misses, review accident reports, and recommend improvements to the SMS. On U.S. vessels, OSHA regulations under 29 CFR Part 1915 (shipyard employment) and Coast Guard safety guidance also encourage safety committee structures.
| Position | Role |
|---|---|
| Master | Chair — final authority and drives safety culture from the top |
| Chief Mate | Vice-chair — coordinates deck department safety activities |
| Chief Engineer | Represents engine department; reports on machinery safety |
| Safety Officer | Designated crew member responsible for SMS compliance on board |
| Crew Representatives | Rotating representatives from deck, engine, and steward departments |
Federal law requires the master or person in charge of a vessel involved in a marine casualty to immediately notify the nearest Coast Guard Sector or Marine Safety Office and then submit a written report. Failure to report is a federal criminal offense under 46 U.S.C. 6101. The regulations at 46 CFR Part 4 define what constitutes a reportable marine casualty and the procedures for reporting.
| Casualty Type | Reporting Threshold |
|---|---|
| Death | Any death of a person on a vessel or in connection with vessel operations |
| Injury | Any injury requiring professional medical treatment beyond first aid |
| Person Overboard | Any person who disappears from a vessel under any circumstances |
| Property Damage | Damage to property (not the vessel) exceeding 25,000 dollars |
| Vessel Damage | Damage to the vessel affecting seaworthiness or fitness for service |
| Constructive Total Loss | Any inspected vessel materially or constructively total-loss |
| Grounding, Stranding, Flooding, or Sinking | Any of these events to a vessel |
| Significant Harm to Environment | Any spill or discharge causing significant environmental harm |
Immediately
Verbal Notice
Notify nearest USCG Sector or Marine Safety Office by radio, telephone, or other means as soon as practicable after the casualty.
Within 5 Days
Written Report
Submit USCG Form CG-2692 (Report of Marine Accident, Injury, or Death) to the USCG Marine Safety Office.
Within 5 Days
Drug Testing
If casualty involves a serious marine incident as defined in 46 CFR 4.03-2, mandatory chemical testing of involved personnel must occur within 2 hours (alcohol) and 32 hours (drugs).
A Serious Marine Incident (SMI) as defined in 46 CFR 4.03-2 triggers mandatory drug and alcohol testing of involved crew members. The definition includes death, injury requiring medical treatment beyond first aid, damage to property or the environment exceeding 100,000 dollars, and a vessel being materially damaged. The operator must ensure personnel involved in a SMI do not consume alcohol for at least 8 hours following the incident or until a blood alcohol test is administered, whichever is sooner.
A near-miss (also called a near-hit or close call) is an unplanned event that did not result in injury or damage but had the potential to do so. Maritime safety research, particularly through the Heinrich Triangle model, shows that for every serious accident there are dozens of near-misses and hundreds of unsafe conditions. Capturing and correcting near-misses before they escalate to accidents is the cornerstone of an effective safety culture.
Problem: Fear of Blame
SMS must be non-punitive — reporting a near-miss should never result in discipline absent willful misconduct
Problem: "Nothing Happened" Attitude
Train crew that near-misses are free lessons; accidents are expensive lessons
Problem: Paperwork Burden
Keep near-miss forms simple and fast to complete; verbal reports to the DPA are acceptable initially
Problem: No Feedback
Close the loop — tell reporters what action was taken; post lessons learned on the safety bulletin board
ISM Code Element 9 specifically requires the SMS to include procedures for reporting and analyzing accidents and "hazardous occurrences" — which includes near-misses. The company must investigate these events, determine root causes, and implement corrective and preventive actions. Findings from near-miss investigations must be shared with all vessels in the fleet where applicable. This "lessons learned" distribution is a key ISM audit criterion.
The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), adopted in 1978 and substantially revised in 1995 and again in 2010 (Manila Amendments), establishes minimum qualification standards for masters, officers, ratings, and certain other personnel serving on seagoing merchant ships.
10 hrs
Minimum rest in any 24-hour period
77 hrs
Minimum rest in any 7-day period
2 max
Maximum periods the 10-hour minimum may be split into
If the 10-hour rest is divided into two periods, one of those periods must be at least 6 consecutive hours. Rest hours may be interrupted for emergencies, drills, or overriding operational necessity, but must be compensated. Masters must maintain official rest hour records for each watch officer and make them available for USCG inspection.
STCW requires that watch officers not stand watch for more than 6 consecutive hours without a break, with exceptions only for safety or operational necessity. Watch scheduling must account for the total work/rest cycle, not just watch hours. Officers must be fit for duty at the commencement of each watch — the Master has the authority to require a crew member to stand down if impaired by fatigue, illness, or any other cause.
STCW requires all seafarers serving on seagoing vessels to hold a Basic Safety Training (BST) certificate covering the following four elements:
STCW A-VI/1-1
Personal Survival Techniques
Survival craft, immersion suits, lifejackets, abandoning ship, staying alive in water
STCW A-VI/1-2
Fire Prevention and Firefighting
Fire classes, extinguishing agents, breathing apparatus, fire-fighting principles
STCW A-VI/1-3
Elementary First Aid
Immediate first aid, CPR, control of bleeding, fractures, hypothermia
STCW A-VI/1-4
Personal Safety and Social Responsibilities
Safety attitudes, working conditions, environmental protection, drug/alcohol policy
The 2010 Manila Amendments to STCW introduced significant new requirements that the USCG exam may test on. Key changes include:
Fatigue is recognized by the USCG, IMO, and maritime safety organizations worldwide as one of the leading contributing factors in vessel casualties. The USCG estimates that fatigue contributes to approximately 16% of all marine casualties. Understanding fatigue management is tested on the captain's license exam through questions about STCW rest hours, watch scheduling, and the master's responsibility to ensure crew fitness for duty.
The master has a direct legal and professional obligation to manage crew fatigue. This includes scheduling watches to comply with STCW rest hour requirements, maintaining accurate rest hour records, refusing to allow fatigued crew to stand watch, and reporting to the company when operational demands prevent compliance with rest hour requirements. Under 46 CFR 15.1111, a licensed officer must not perform duties when impaired by fatigue and the master must relieve that officer.
Exam Scenario: Fatigue vs. Commercial Pressure
If an exam question presents a scenario where the owner or company wants the vessel to depart immediately, but the officer of the watch has not had the required rest hours, the correct answer is always: the master must delay departure until crew rest requirements are met, regardless of commercial pressure. The master's overriding authority under ISM Element 5 and STCW supports this decision.
Subchapter M of Title 46, Code of Federal Regulations (Parts 136–144) represents the most significant expansion of USCG authority over towing vessels in U.S. maritime history. Effective April 19, 2016, with compliance phased in through 2021, Subchapter M requires towing vessels operating on U.S. navigable waters to obtain Certificates of Inspection for the first time in the industry's history.
Traditional USCG inspection by a marine inspector. The inspector verifies the vessel meets all applicable construction, equipment, and operational requirements and issues a Certificate of Inspection directly.
The operator develops a Towing Safety Management System (TSMS) verified by a USCG- approved third-party organization (TPO). The TPO audits the TSMS and recommends issuance of a COI to the USCG.
| Part | Subject | Key Provisions |
|---|---|---|
| Part 136 | General Provisions | Applicability, definitions, Certificate of Inspection requirements |
| Part 137 | TSMS | Requirements for a Towing Safety Management System and third-party organization |
| Part 138 | Towing Vessel Inspections | USCG inspection pathway, frequency, scope |
| Part 139 | Design and Equipment | Structural requirements, stability, electrical systems |
| Part 140 | Operations | Manning, watch requirements, navigation equipment, logs |
| Part 141 | Firefighting Equipment | Portable extinguishers, fixed systems, fire detection |
| Part 142 | Lifesaving Appliances | PFDs, ring buoys, survival craft requirements |
| Part 143 | Machinery and Electrical | Engine room safety, fuel systems, emergency stop |
| Part 144 | Stability | Stability requirements, load line, freeboard |
The USCG licenses officers and operators of commercial vessels under 46 CFR Parts 10–16 (now reorganized under 46 CFR Part 11 for deck officers and Part 15 for watchstanding requirements). Understanding the basic structure of USCG licensing is frequently tested.
| License | Tonnage | Waters | Typical Use |
|---|---|---|---|
| OUPV (Six-Pack) | Up to 6 passengers for hire | Near Coastal, Inland, Great Lakes | Charter fishing, dive boats, water taxis |
| Master — 25 GT | Up to 25 GRT | Near Coastal, Inland | Small passenger vessels, tour boats |
| Master — 50 GT | Up to 50 GRT | Near Coastal, Inland | Ferry operations, larger charter vessels |
| Master — 100 GT | Up to 100 GRT | Near Coastal, Inland, Offshore | Passenger vessels, offshore supply |
| Master — 200 GT | Up to 200 GRT | Near Coastal, Inland | Mid-size commercial operations |
| Master — Oceans (Unlimited) | Unlimited tonnage | Oceans (worldwide) | Large commercial vessels, international trade |
All USCG deck officer licenses require documented sea service. Key sea service requirements:
OUPV
360 days total, at least 90 on ocean or near coastal waters
Master 25/50 GT
360 days total, 90 on appropriate waters
Master 100 GT
360 days total, 90 on near coastal or higher
Chief Mate / Master (Unlimited)
3 years as officer in charge of navigational watch
USCG merchant mariner credentials (MMC) are valid for 5 years. Renewal requires: proof of continued sea service (at least 1 year within the prior 5 years for most licenses), updated STCW endorsements, drug testing compliance, physical examination (NVIC 04-08), and payment of applicable fees. Licenses that lapse require reexamination if they have been expired for more than 1 year.
The Global Maritime Distress and Safety System (GMDSS) was implemented under SOLAS Chapter IV to replace the traditional Morse code distress watch with a system of automated digital distress alerting. GMDSS uses four defined Sea Areas that determine the required complement of radio and distress equipment. Understanding the equipment requirements for each sea area is directly tested on the USCG exam.
Sea Area A1
Within range of at least one VHF coast station with DSC — typically 20–30 nm from shore
Sea Area A2
Within range of at least one MF coast station with DSC (outside A1) — typically 30–400 nm from shore
Sea Area A3
Within coverage of an Inmarsat geostationary satellite (outside A1 and A2) — approximately 70°N to 70°S
Sea Area A4
Polar regions outside A1, A2, and A3 — north of 70°N or south of 70°S
| Equipment | A1 | A2 | A3 | A4 |
|---|---|---|---|---|
| VHF DSC Radio | ✓ | ✓ | ✓ | ✓ |
| MF DSC Radio (2182 kHz watch) | — | ✓ | ✓ | ✓ |
| HF DSC Radio or Inmarsat | — | — | ✓ (either) | ✓ |
| HF DSC Radio (all bands) | — | — | — | ✓ |
| NAVTEX Receiver | ✓ (if available) | ✓ | ✓ | ✓ |
| EGC Receiver (Inmarsat C) | — | — | ✓ (if no NAVTEX) | ✓ |
| EPIRB (Category I) | ✓ | ✓ | ✓ | ✓ |
| SART or AIS-SART | ✓ (x2) | ✓ (x2) | ✓ (x2) | ✓ (x2) |
| Two-way VHF Portable (x3) | ✓ | ✓ | ✓ | ✓ |
| Reserve Power Source (batteries) | ✓ | ✓ | ✓ | ✓ |
Under FCC and USCG regulations, all vessels fitted with GMDSS equipment must have at least one person who holds a GMDSS Radio Operator License (GOL) or a GMDSS Radio Maintainer License (GML). The GOL authorizes operation of all GMDSS equipment. The GML authorizes maintenance in addition to operation. On compulsory vessels, the operator of GMDSS equipment while the vessel is at sea must hold the GOL at minimum.
Emergency Position-Indicating Radio Beacons (EPIRBs) must be registered with NOAA (in the U.S.) and programmed with the vessel's MMSI and owner contact information. Category I EPIRBs automatically activate when submerged and float free of a sinking vessel. Category II EPIRBs require manual activation. Under SOLAS and 46 CFR Part 25, vessels operating beyond 3 miles offshore (inspected vessels) must carry a Category I 406 MHz EPIRB. EPIRBs must be inspected annually and batteries and hydrostatic releases replaced per manufacturer requirements.
The ISM Code (International Safety Management Code) is Chapter IX of SOLAS, requiring shipping companies to develop and implement a Safety Management System (SMS). It applies to passenger ships of all sizes on international voyages, and to tankers, bulk carriers, chemical tankers, gas carriers, and cargo high-speed craft of 500 GT and over. Domestic vessels not on international voyages are generally not subject to ISM, though the USCG has adopted equivalent principles in domestic regulations.
The DPA is a shore-based individual required by ISM Code Element 4 who serves as the communication link between the ship and the company. The DPA monitors safety and pollution-prevention operations, ensures adequate resources are provided, and has direct access to top management. The DPA cannot be the Master, must be specifically named in the SMS, and is responsible for overseeing non-conformity investigations and corrective actions.
On cargo ships, fire drills and abandon-ship drills must be conducted at least once a month for each crew member. On passenger ships, a drill must be held within 24 hours of departure when more than 25% of the crew has changed since the last drill. Rescue boat and MOB drills must also be held monthly. All drills must be recorded in the official logbook.
STCW requires a minimum of 10 hours of rest in any 24-hour period and 77 hours in any 7-day period. The 10-hour rest may be divided into no more than two periods, one of which must be at least 6 consecutive hours. Exceptions for emergencies or drills must be compensated. The USCG enforces STCW rest requirements under 46 CFR Part 15 and masters must maintain rest-hour records.
Under 46 CFR Part 4, a written CG-2692 report must be submitted within 5 days whenever: a person dies or disappears from a vessel, a person is injured requiring professional medical treatment, property damage exceeds 25,000 dollars, an inspected vessel is materially or constructively total-loss, a vessel is involved in significant environmental harm, or a vessel grounds, sinks, or founders. Immediate verbal notice to the USCG is also required as soon as possible after the incident.
Vessels operating exclusively in Sea Area A1 (within VHF DSC range of a coast station) must carry: a VHF radio with DSC capability, a Category I EPIRB (406 MHz), at least two SART or AIS-SART devices, three two-way VHF portable radios, and a NAVTEX receiver where available. All equipment must be tested before departure and records maintained. GMDSS operators must hold an FCC GMDSS Radio Operator License (GOL).
Subchapter M (46 CFR Parts 136-144), phased in between 2016 and 2021, requires all towing vessels operating on U.S. navigable waters to hold a Certificate of Inspection. Operators choose between direct USCG inspection or compliance through a Towing Safety Management System (TSMS) audited by an approved third-party organization. Subchapter M covers vessel construction, equipment, firefighting, lifesaving appliances, operations, and manning.
Practice with USCG-style exam questions on commercial vessel safety management, ISM Code, STCW, SOLAS drills, and all the topics covered in this guide.