James A. Elliot

As an ex-tug boat captain, I would like to weigh in on the issue of mandated sleep requirements. As I see the research has been done, so we all know the consequences, as well we know that manning requirements are not subject to change right now due to the unavailability of Merchant Mariners, and the cost associated with hiring more people. The best we could possibly hope for then is to augment the watches. There is a schedule, though somewhat a little skewed, that can work to get the maximum hours of rest, and maintaining the same amoutn of crew. It is an 8 hour on 4 hour off, then 4 hour on 8 hour off schedule. As far as mandating such a requirement on board, that is another question to deal with. But this schedule is not too difficult and addresses the main problems. This should alleviate sleep deprivation across the board. Giving way to a 7 hour rest period in a 24 hour period and still doing 12 hours of watch in a 24 hour period. Just my .02¢.