🔍 Key Concepts

• 46 CFR Subchapter M requirements for towing vessel safety orientation and drills • Difference between initial safety orientation and periodic drills • Regulatory intent: how quickly new personnel must be prepared for emergencies

💭 Think About

• Think about why the Coast Guard wants new crewmembers on a towing vessel to be ready for emergencies—how soon would that reasonably need to happen? • Consider whether the rule is written to allow a long familiarization period, or to ensure people know emergency procedures almost immediately. • Ask yourself: does the regulation focus on the calendar time aboard, or on being fit to respond to an emergency while on duty?

✅ Before You Answer

• Check 46 CFR Part 140 (Operations) for the specific wording about when safety orientation must be given. • Verify whether the rule applies to before they begin duty, or after reporting aboard but within a certain time. • Confirm whether the requirement talks about "each crewmember who has not participated in drills" and what time limit is attached to that phrase.