John Humpage

The proposed regulatory language offers no definition of the termed "manned." There is a large population of seagoing barges that are "permissively manned." These barges do not require manning to operate or navigate the barge, but OCMIs allow personnel onboard so that they can prepare the barges for transfer and off-load. Admittedly, most of these barges are inspected tank barges, but without a clear definition of the term "manned" the proposed regulations are ineffective.