🔍 Key Concepts

• 46 CFR Part 35 – specifically fire prevention and smoking regulations for tank vessels and barges • Who has immediate operational control during cargo transfer operations • The difference between the regulatory authority (OCMI), the vessel owner, and the person in charge of the transfer

💭 Think About

• Which person is legally designated to control and supervise the loading operation itself on a tank barge? • Who is in the best position, by regulation, to ensure safe practices (including smoking control) are followed in real time during cargo transfer? • Does the regulation say smoking is absolutely prohibited at all times, or does it say smoking may be allowed only under certain controls and by whose permission?

✅ Before You Answer

• Verify in 46 CFR 35.30 (Firefighting and fire prevention on tank vessels) who is responsible for designating smoking areas during cargo handling. • Check which role is defined as the “person in charge” of cargo transfer and what authority that role has over safety measures. • Confirm whether the rule is an absolute ban on smoking during loading, or a conditional allowance under a specific person’s control.