Douglas Kirk Chapman

46CFR143.280 Fuel Shutoff requirements I’m uncomfortable with 46CFR143.280 (d) where it says “must be operable outside the space where the valve is located” In most tow boats the fuel oil shut off valves are outside the Main engine room. (weather deck) The proposed rule will work fine with these vessels. I believe the following words (must be operable from a weather deck) better meets the intent of the regulation writers, to protect the crew member tasked with closing the valve during a main space fire. I believe some tow boats have generators prime movers located in a room within the main engine room. The generators prime mover has a shut off valve inside this interior room. The proposed rules current wording would allow for the shut off valve to be located outside the interior room and be operable in the middle of the main engine room. (it meets the exact wording of located outside the room where the valve is located but I believe against the intent of keeping the crewmember safely outside on the weather deck) Please consider removing the words “Outside the space where the valve is located” And substitute “must be operable on a weather deck” or “must be operable on exterior deck” Also I believe 46CFR143.280 (e) says “should be marked” I believe it need to read “shall be marked” similar to 46CFR78.47-38(a) I believe there is a difference in the meaning between “should” and “shall” when interpreting the meaning of a regulation.