National Mariners Association
Captain Joseph Dady, President
14961 Masthead Landing Circle
Winter Garden, FL 34787
Captain Richard A. Block, Historian

The National Mariners Historical Trust

Annotated NMA Index "R"

current as of March 3, 2016

V.J. Gianelloni III, B.S., J.D., Chief Engineer, President/Historian

Captain Richard Block, B.A., M.S. Ed., Secretary/Historian

Captain Joseph D. Dady, Immediate Past President

Captain J. David Miller IT/IS Services


      Introduction:  The National Mariners Association (NMA) was a non-profit mariner advocacy organization founded on April 15, 1999 as the Gulf Coast Mariners Association (GCMA).  The Association became inactive as a dues-collecting membership organization on June 30, 2014.  You can read the Association’s mission statement on the website, 

      The Association, representing the interests of limited-tonnage working mariners, gathered and compiled many documents directly affecting an estimated 126,000 “limited-tonnage” merchant mariners serving on U.S.-Flag commercial vessels such as tugs, towboats, offshore supply vessels, small passenger vessels, and charter boats of less than 1600 gross tons. 

      During the Association’s active period, members and Directors of the Association accepted appointments to serve on three Federal Advisory Committees, testified before Congressional Committees, submitted reports to Congress and the Coast Guard (USCG), attended and spoke at public meetings, submitted comments that appear in many Coast Guard rulemaking dockets, provided detailed information to the Department of Homeland Security’s Inspector General’s Office, attended numerous Federal Advisory Committee MERPAC, TSAC and NOSAC Meetings, observed dozens of Administrative Law Judge hearings, and submitted articles to various newspapers and trade journals on behalf of issues of importance to limited-tonnage mariners.

      The collection, research, and creation of documents took place over many years and covered the time span from 1970 to 2014.  The research and collection was accomplished with the help of many people at considerable expense in money, time and effort under the supervision of our Board of Directors.  We encourage those who find value in our Research Reports and Newsletters to pass the word along to other mariners and help the Trust to maintain the existing website to preserve and enhance these documents, and make the research they represent available to all.

      One of the Association’s first orders of business (in Report #R-201) was to identify the broad area of problems that affected our working mariners in the Gulf Coast Area and eventually beyond.  We brought this initial broad area of concern identified by 58 initial respondents to the attention of the Coast Guard at District and Headquarters level and also to three Coast Guard Federal Advisory Committees.  Many were regulatory issues in the Coast Guard’s purview while others were matters that we presented to Congress.  Still others involved the Corps of Engineers, OSHA, and the Department of Homeland Security.  All reports are now identified as “NMA Report #R-“ followed by a three digit number.  Reports were revised (Rev.) as necessary and related reports were given suffix letters A, B, C etc. wherever possible.  However, each report is dated and should be viewed with the date in mind as to the timeliness of the issues discussed. 

      We offer “Index R” as a work in progress and on an “as is” basis.  Most reports can be downloaded by number directly from the report page on our website.  E-mail: with any questions or problems.


[Editorial note:  NMA Reports that are currently available are listed on our website and are downloadable.  Unless otherwise listed, only the latest revision of each report is available. 

 p.  =   The number of printed pages in a report.

Congress” = When the word “Congress” appears in bold letters in a report title, or is highlighted, it means that the National Mariners Association delivered a copy of this report to the appropriate Congressional Committee and/or Subcommittee or its staff members.


Hours of Service Issues:

£R-200.  June 1, 1999.  National Transportation Safety Board Recommendations on Operator Fatigue[Reply to Hon. Rodney Slater, Secretary, U.S. Dept. of Transportation on NTSB Recommendations #I-99-1 & #89-1.  Also refer to NMA Report #R-322.]  14p.

£R-201.  May 2000.  Mariners Speak Out on Violation of the 12-Hour Work Day.  200p.  [This report is referred to as our Association’s “Yellow Book.”  For follow-up to this introductory report, see NMA reports #R-201-A, #R-253; #R-276-K; R-302, #R-370, Rev.4 and the entire #R-370 Series; #R-408 & #R-408-A] 

£R-201-A. Dec 21, 2012.  Marine Casualties Related to the Grounding of the MODU Kulluk[U.S. Coast Guard Investigation and Report, MISLE Activities #4509675 with comments.  M/V Aiviq.]  155p.


Workplace Safety, Health and Personal Injury Issues.  [Also see #R-205, Issue 7; #R-292, Rev. 1; #R-338; #R-350, Rev. 5, Issue “Y”; #R-429, Rev.1; #R-429-I]

£R-202, Rev. 5.  Nov. 1, 2011.  Deplorable Treatment of Limited Tonnage Mariners[Don’t Count on Corporate Compassion or Coast Guard Concern:  True Stories of Our Dead, Injured & Cheated Mariners.]  66p.

£R-202-B, Rev. 3.  Nov. 8, 2013.  Coast Guard Marine Safety Directorate and OSHA Ignore Important Maritime Workplace Safety and Health Issues[This report contains OSHA Directive CPL 2-1.20, that delineates OSHA/USCG Authority Over Vessels.]  36p. 

£R-202-C, Rev. 2.  July 7, 2010.  OSHA Regulates Uninspected Dry Cargo and Work Barge Safety[Over 18,000 barges remain virtually uninspected.]  18p.

£R-202-D.  Oct. 15, 2012.  Offshore Operation of Unmanned Cargo Barges in the Gulf of Mexico.  72p.  [This report contains NMA comments and prevailing position on an unsafe petition for rulemaking found in Docket USCG-2011-0925 at]  73p.

R-202-E.  Nov. 8. 2013We Ask the Coast Guard Marine Safety Directorate to Address Outstanding Mariner Occupational Safety and Health Issues.  [A Compendium of reports covering the period from 1970 to-2014.  The NMA petition and public comments appear in Docket #USCG-2014-0014 at  This remains an active file awaiting rulemaking.]  360p. 



£R-203, Aug. 1, 2009.  How a “Bill” Becomes a Law. 4p.

£R-203-A, June 11, 2009.  Maritime Workforce Development Act[H.R. 2651, 111th. Congress.  Legislation proposed by Rep. Elijah Cummings offered career development tuition loans for merchant mariners but failed to become law.]  23p.

£R-203-F.  Nov. 4, 2010. Coast Guard Authorization Act of 2010; Important Sections for Our Limited Tonnage Mariners. 7p.  [Reflects major legislative changes sought by NMA from 2004 to 2010 that were enacted by Congress.]

£R-203-G.  Dec. 5, 2012.  Coast Guard Authorization Act of 2012[Government Reprint]  118p.


Coast Guard’s Administrative Law System  [Also see #R-429 Series Reports.]

£R-204, Rev. 4.  March 29, 2012.  The Coast Guard “Injustice” Handbook.  A Guide to the Administrative Law System.  [Contains one of our Association’s longest and most exhaustive studies of the Coast Guard’s Administrative Law system and its effects on targeted merchant mariners.  This report contains 22 chapters.]  419p.

£R-204-A, April 13, 2010.  Administrative Law Judges: An Overview[Reprint of Congressional Research Service Report prepared for members and committees of Congress].  12p.

£R-204-B. July 14, 2010.  U.S. Coast Guard Prevention Programs – A Tale of Mismanagement[Includes reprint of Dep’t of Homeland Security report titled: Independent Evaluation of the U.S. Coast Guard Prevention Program – Marine Safety and Environmental Protection.”]  116p.

£R-204-C, Rev. 6.  April 25, 2011. Insure Your Credential – Protect Your Career.  12p.  [NMA recommended license defense insurance coverage for all limited tonnage officers based on cases we followed in NMA Report #R-204, Rev. 4 above.]  12p.

£R-204-E. The Good Lord Hates A Coward, by Joseph J. Kinneary, Ph.D. ©2005.  [One of the most infamous examples of the Coast Guard’s unjust treatment of merchant mariners is recounted in this book and in NMA Report #R-204, Rev. 4, Chapter 15.]  144p.


Mariner Safety, Health & Welfare Issues  [Also see major NMA Report #R-370, Rev. 4.]

£R-205, Rev. 1.  April 7, 2012.  Report to Congress:  Outstanding Failures to Protect the Safety, Health, and Welfare of 126,000 Limited Tonnage Merchant Mariners  [Editorial note:  This report updated and utilized information from reports in the NMA #R-370 report series and other related reports to present our case to Congress to protect our mariners’ safety, health and welfare.  Following this report to Congress, we formally petitioned the Coast Guard Marine Safety Council in NMA Report #R-202-E to undertake a program of regulatory reform.  Related NMA reports: #R-341; #R341-A;#R-349; #R-349-A; #R-391, Rev.4; #R-429-I; #R-455, Rev. 6..]  39p.


Standards of Training, Certification and Watchkeeping (STCW)

£R-206.  Feb. 22, 2010.  If the Question Concerns STCW – Our Answer Remains “NO”!  20p.

£R-206-A, Rev. 1.  Apr. 6, 2010 “NO” to Further Implementation of STCW-95 Amendments.  7p.

£R-206-B, June 22, 2011.  IMO ECDIS Model Course.  2p.

£R-206-C. Aug. 24, 2011.  International Convention on Standards of Training, Certification, and Watchkeeping, 1978, and       Changes to Domestic Endorsements[NMA Comments on STCW Docket #USCG-2004-17914.].  27p,


Maintaining a Proper Lookout

£R-207, Rev. 1.  Jan. 20, 2010 Training and Posting Lookouts[Also see NMA Report #R-275, Rev. 3.]  15p. 

£R-207-A.  Feb. 6, 2010.  Lookout Training.  [By Paul Driscoll, BMCM, USCG (Ret’d)]  19p.

£R-207-B.  Apr. 14, 2010.  Rule 5 – Maintaining A Proper Lookout[Contains 2010 Decision by ALJ Bruce T. Smith.]  30p.

£R-207-C.  Nov. 7, 2011. Maintaining a Proper Lookout:  The 2010 “Duck Boat” Accident at Philadelphia.  [Fatal towing accident resulting from a lack of awareness of surroundings, distractions caused by cell phone use, and attending to personal business while alone on watch in a busy waterway.]  29p.

£R-207-D. .July 13, 2014.  Rule 5: A Proper Lookout: Training, Posting, Maintaining & Assessing It.  [This report was written for use in an Apprentice Mate/Steersman Program.]  14p. 


Offshore Supply Vessel (OSV) Issues  [Also see Reports #R-201-A; #R-207, Rev. 1; #R-230, #R-238, Rev. 1, #R-274, #R-299; #R-311; #R-412-A.]

£R-208.  Sept. 30, 2010.  Lessons from Major Offshore Supply Vessel Accidents[Three incidents are discussed in this report – M/V Bass River/C-Captain collision; Cheramie Botruc 26 sinking with 2 fatalities; M/V Seabulk Georgia strikes a Jack-up Rig.]  40p.

£R-209.  Aug. 11, 1999.  Offshore Supply Vessels. [Comments submitted to Docket #USCG-1999-5951 at]. 26p.

£R-209-A.  Apr. 4, 2014.  Kidnapped Off Nigeria – An American Ship Captain Unveils the Truth.  [Capt. Wren Thomas and M/V C-Retriever.]  6p


Mariner Whistleblower Protection  [Also see NMA Reports #R-370-D., Rev. 7 and #R-462.]

£R-210, Rev. 2.  Aug. 17, 2011. Whistleblower Protection for Merchant Marine Officers.  By Stephen Chouest, LLM Admiralty.  12 pgs.

£R-210-A.  Feb.6, 2013.  Whistleblower Protection for Merchant Marine Officers.  Procedures for the Handling of Retaliation Complaints Under the Employee Protection Provision of the Seaman’s Protection Act (SPA) as Amended.  [Reprint of OSHA Interim Final Rule.].  24p.


Mariner Employment Issues.  [Also see Reports #R-276-D and #R-350, Rev. 5, Issue “X”]

£R-211. Rev. 1.  Mar. 19, 2011.  Headhunting – An Illegal Mariner Employment Practice.  8p.

£R-211-A.  Jan 20, 2011.  Background Paper on the Maritime Activities of the International Labour Organization.  By Bjorn Klerck Nilssen, Chief, Maritime Industries Branch, International Labour Office (ILO), Geneva, Switzerland 1998.  13p.


Pilothouse Visibility Issue

£R-212.  June 29, 2011. Report to the 112th. Congress – Pilothouse Visibility Issues on Towing Vessels[Also see NMA Reports #R-275, Rev. 3 and Report #R-207-D]  8p. 


Mariner Appeals to the Public

£R-213, May 10, 2012.  Blood on Brown Water[Report handed out to Members of Congress and their staff by an NMA Director in 2012.]  74p.


Mariner Medical, Public Health, and Welfare Issues

£R-214. Sept. 24, 2012.  Report to Congress on Merchant Mariner Medical Issues[Editorial note:  This report updates and utilizes information from the following reports cited below to present our issues to Congress and to better protect our mariners’ safety, health and welfare.  Also see these related NMA reports: #R-341, Rev.4; #R-349; #R-350-Y, Rev. 1; #R-370, Rev. 4; #R-378; #R-445, Rev. 1; #R-455, Rev. 1.]  14p. 


Federal Issues

£R-215, Rev. 1, Mar. 24, 2011. How to Contact Members of Congress on Maritime Issues.  [Note that pgs. 5 & 6 are outdated.  Committee members change at the beginning of each term of Congress.]  5p.

£R-216.  Oct. 1, 1999.  Defining the Difference Between Lines of Demarcation and Boundary Lines.  2p.

£R-218.  Oct. 21, 2013.  Status Report: Adopting Meaningful Logbook Standards[Congress updated logbook standards for all inspected vessels by 46 USC §11304 in 2010.  However, to date, the Coast Guard has offered no further guidance nor have they followed up the actions required by Congress.  Also see NMA Report #R-234 & #R-429-G for background information.]  15p.  

£R-223, Rev. 6, Aug. 1, 2015.  What the Hell is A CFR[Explains how mariners can access Federal Regulations in the Federal Register and in the Code of Federal Regulations.  Key Word: CFR.]  10p.

£R-224.  Rev. 1, July 4, 2009.  Accident Investigations;  [Waterways Journal Editorial of Nov. 8, 1999, "Who Has the Best Approach to Public Safety?"  Also see #R-429 Series.]  3p


 [Also see Reports #201-A; #R-276-N; #R-390, R-390-A; R-390-B; R-390-C & #R-390-D.]

£R-225-A, Nov. 4, 2013.  Tankship Tintomara – Towing Vessel Mel Oliver Collision Near LMR Mile 99, July 23, 2008 With Major Oil Pollution.  107p. [NMA Introduction and USCG investigative report.]  104p.

£R-225-B, May 25, 2015.  Grounding of the Tank Barge Morris J. Berman at Punta Escambron, Puerto Rico, Jan. 7, 1994 with Major Pollution & No Loss of Life.  [Lack of preventive maintenance on towing gear, inattention to duty while towing, and drug use were cited.]  21 pgs.

£R-225-C, May 25, 2015.  Fire and Grounding of the Tugboat Scandia and Grounding of the Tank Barge North Cape, Off Point Judith, Rhode Island on January 19, 1996 With Major Pollution and no Personal Injuries or Loss of Life112 pgs.


£R-230.  Jan. 17, 2000.  Rescue Boats and Platforms Required on Offshore Supply Vessels.  [Also refer to NMA Report #R-354]  10p.


Outer Continental Shelf (OCS) Activities

£R-233, Rev.1, Sept. 16, 2010.  GCMA Comments on Notice of Proposed Rulemaking for Outer Continental Shelf (OCS) Activities[33 CFR Subchapter N; Docket #USCG-1998-3868.  This rulemaking, which could have brought meaningful safety regulations to protect mariners working on the OCS was put on a back burner for over 10 years by senior Coast Guard officials and sabotaged by the industry.]  20p.


Official Logbooks.

£R-234. Rev. 3, June 22, 2011.  Towing Vessel Official Logbooks[Congress updated logbook standards for all inspected vessels including towing vessels by 46 USC §11304 in 2010.  The logbook described here was designed by towing vessel owners and officers to comply with the Cooperative Towing Vessel Examination Program (CTVEP) that was re-introduced as the Coast Guard’s current “Bridging” program.  Also Refer to NMA Report #R-218.]  9p.


£R-238, Rev. 1.  Nov. 14, 2012.  Information for Our Limited-Tonnage Engineers[The towing industry has failed to adequately prepare its engineering personnel and appears to have succeeded in marginalizing them for the past 45 years.  This report cites these additional NMA Reports #R-370, Rev.4; #401-A; #R-401-P; and #R-428-K, Rev. 8.]  12p.

£R-242.  Apr. 24, 2000.  Gulf Coast Mariners Association’s (GCMA) First Year's Accomplishments[This is an example of the things a mariner membership association can do with sufficient funding and good leadership.]  3p.

£R-247.  Rev.1, Apr. 26, 2004.  Violation of Laws and Regulations[A few of the basic laws and regulations that are frequently abused or violated to the detriment of working mariners.]  2p.

£R-253.  Sept. 3, 2003.  Problems Facing Lower-Level Mariners.  [A follow-up to NMA Report #R-201 concluding with a survey of limited tonnage mariners.]  21p. 

£R-272, Rev. 1.  Jan. 26, 2016.  Bridge Resource Management. 12p.  [Source: Transportation Safety Board of Canada.]

£R-274.  Navigation and Vessel Inspection Circular No. NVIC 1-78  [OSV Engineroom Automation that TSAC Task #15-01 is considering for possible application on towing vessels.]  8p. 

£R-275, Rev.3, Aug. 24, 2004.  Navigation Bridge Visibility[By Captain David C. Whitehurst.]  11p. 


Towing Vessels – Inspection, Manning & Employment [Also See #R-212.]

£R-276, Rev. 9. June 1, 2005. Towing Vessels Must Be Regulated Like Every Other Inspected Vessel.  [This report records our Association’s continuing work through the Towing Safety Advisory Committee (TSAC) that led to NMA recommendations to Congress in Docket #USCG-2004-19977 for USCG consideration in rulemaking leading to Congressionally-mandated inspection of towing vessels.  We encourage limited-tonnage working mariners to measure the final rules for towing vessel inspection against our recommendations in this report.]  45p.

£R-276, Rev. 10.  Oct. 5, 2011.  Report to Congress:  Proposed Towing Vessel Inspection Regulations Missed the Mark.   [You will find the USCG proposed towing vessel inspection regulations in NMA Report #R-276-E and at Docket #USCG-2006-24412 at  This report explains why we were dissatisfied with the proposed rules.]  59p.

£R-276-A.  Nov. 9, 2006.  Towing Vessel Inspection.: Mariner Suggestions & Initiatives Submitted to the TSAC Towing Vessel Inspection & Licensing Work Groups.  [Since they were submitted after the deadline, the USCG was under no obligation to consider these suggestions and initiatives but had sufficient time to do so.]  36p.

£R-276-C, Rev.2.  Jan. 26, 2011.  “Examination” of Towing Vessels is not “Inspection” – The Background of the Towing Vessel “Bridging” Program.  [The “Bridging” program was a successful first step in introducing the inspection process to the towing industry.]  7p.

£R-276-D, Rev. 6.  Mar. 15, 2012.  The Towing Industry is a Poor Career Choice  24p.

£R-276-E.  Aug. 15, 2011. Inspection of Towing Vessels.  [The Notice of Proposed Rulemaking of Aug. 11, 2011 with NMA comments]  77p.

£R-276-H. Aug. 20, 2011. Towing Vessel Inspection NPRM – NMA Letter to the Docket.  [Discusses USCG failure to include hours-of service and work performance issues in the proposed rulemaking.]  4p.

£R-276-I. Oct. 26, 2011.  NMA Comments Submitted to Docket #USCG-2006-24412: Inspection of Towing Vessels[Written comments provided to Docket at USCG public meeting held on the proposed towing vessel inspection regulations on Oct. 26, 2011 in Kenner, LA.]  6p.

£R-276-J.  Nov. 16, 2011.  Comments Submitted to Docket #USCG-2006-24412: Inspection of Towing Vessels[Comments by Capt. John R. Sutton, Past President of the American Inland Mariners Association (AIM).]  34p.

£R-276-K, Rev, 4.  Aug. 26, 2013.  Manning of Inspected Towing Vessels: Mariners Respond to Hours of Service Issues on Towing Vessels[A number of working mariners pointed out why “hours of service” issues should have been an integral part of towing vessel inspection regulations – as was intended by Congress when it ordered the inspection of towing vessels in 2004.]  15p.

£R-276-L.  May 11, 2012.  Safe Manning for Uninspected Towing Vessels Engaged on International Voyages[NMA introduces a draft USCG policy letter discussed at a TSAC meeting in Houston and obtained under FOIA.  Proposed policy was significant since many towing vessels engage in international voyages and must comply with unfamiliar international standards.]  102 pgs.

R-276-M.  Nov. 26, 2013.  Towing Vessel Hull Inspection and Repair Standards [Our report supports USCG guidance in NVIC 7-68 as applied to towing vessels coming under inspection.  This issue has been turned over to TSAC as Task #13-07.]  32p.

£ R-276-N.  June 22, 2014.  American Flag Towing Vessel Accident Report: A Report of International Significance.  [Fire and loss of life on the U.S.-flag tug Patrice McAllister and the tug Charlene Hunt’s loss of its tow as reported by Canada TSB.]  20 pgs.


Vessel Manning

£R-279, Rev 8,  Apr. 19, 2008.  Request to Congress:  To Review and Set Safe Manning Standards for Mariners Serving on Towing and Offshore Supply Vessels[NMA reported a number of instances of unsafe manning first to the Coast Guard and then to Congress.  Also refer to NMA Report #R-370, Rev. 4 that is a 179 pg. report on this issue.]  18p.


Towing Officer Assessment Records.  [Latest editions corrected by TSAC Task 8-01 Oct. 20, 2011.]

£R-287-A.  TOAR (Near Coastal/Oceans) Performance Assessment Criteria.  22p.

£R-287-B.  TOAR  (Great Lakes/Inland) Performance Assessment Criteria.  20p.

£R-287-C.  TOAR (Western Rivers) Performance Assessment Criteria.  20p.


Reports to the International Transport Workers Federation (ITF).

£R-290-A.  June 6, 2001.  Report to the International Transport Workers Federation (ITF) Delegation to the Maritime Gulf Project May 31-June 6, 2001 on the issue of Safety on Offshore Vessels.  40p.

£R-290-B  July 31, 2001.  USCG Interaction with Lower-Level Merchant Mariners; A report to the International Transport Workers Federation (ITF).  29p.


Maritime Accidents – Bridge Allisions.

£R-293-A, Rev. 3.  June 1, 2008.  Towboats and Bridges, A Dangerous Mix.,  28p.

£R-293-B, Rev.   17p.

£R-293-C.  Apr. 25, 2005.  Allision Involving the M/V Brownwater V and the Queen Isabella Causeway Bridge, Port Isabel, Texas Sept. 15, 2001.  [Reprint of USCG Investigation Report.  Also refer to NMA Report #R-399.]  37p.


£R-296. Sept. 7, 1998/ Sept. 9, 2015.  Coast Guard Reports on the Capsizing and Sinking of the AHTS Ensco Kodiak II.  [Deck load of anchor chain was not properly secured and watertight closures were left open.]  18 pgs.

£R-300.  Jan. 9, 2002.  Chao, Secretary of Labor vs. Mallard Bay Drilling, Inc[Reprint of U.S. Supreme Court Decision.  Also refer to NMA Reports #R-202-B and #R-338.]  10p.

£R-301. Jan. 13, 2002.  Uninspected Towing Vessel Workplace Safety Considerations.  [Internal correspondence to NMA Board of Directors delineating immediate changes to improve safety on towing vessels in light of the “Mallard Bay” decision clearing the way for OSHA to regulate uninspected towing vessels if the USCG continues to fail to do so.]  5p.

£R-302.  Guide for Investigating for Fatigue.  Reprint of Transportation Safety Board of Canada repo]. 26p.


Coast Guard “Missions” Other Than Marine Safety.

£R-304, Rev.2.  Sept. 14, 2001.  Small Boat Station Search and Rescue Program[Reprint: DOT Audit of this Coast Guard program.]   53p.

Recreational Boat Casualties

£R-305, Rev.1. Oct. 2002.  Betrayed – A Call for Increased Congressional Oversight of the U.S. Coast Guard.  [The report deals with the unrealistic approach permeating USCG official thinking about the number of hours they expect mariners, both their own enlisted active duty personnel as well as commercial mariners, to work on the job on a daily basis.  The botched rescue attempt in the S/B Morning Dew Accident reached Congress.]  6p.  


£R-309.  Mar. 20, 2002.  Stacked Deck: Death on the High Seas[Reprint of an article from National Fishermen on the treatment of death and personal injury at sea.]  3p,

£R-310.  April 5, 2002.  Response to OMSA's Report on Crew Alertness in the Offshore Industry[Report on fatigue, hours of service, and related issues provided to members of the National Offshore Safety Advisory Committee as part of our work with Federal advisory committees.  Also refer to NMA Report #R-322.]  114p. 


Unseaworthy Vessels

£R-311-A, Sept. 18, 2007.  Assigning Responsibility for Sending an Unseaworthy Vessel to Sea[One of our Association’s major concerns was to protect our mariners from the preventable dangers that going to sea presents including greed and stupidity.  However, investigation of complaints and enforcement of existing laws and regulations belongs to the USCG.  The report was triggered in several cases where USCG “enforcement” was less than satisfactory.  Also refer to NMA Report #R-208, Incident 2.]  4p.


R-315 (Series).  Drugs & Alcohol.  [This series concentrates on understanding the D&A testing regulations and their effect on mariners.  For our background on this subject refer to NMA Reports #R-204, Rev. 4 and #R-377, Rev. 3.]

£R-315.  Rev.2.  May 5, 2005.  Drug Testing: Urine Specimen Collection.  13p.

£R-315-A.  Dec. 26, 2004.  Drug Testing Regulations: The Role of the Medical Review Officer (MRO).  13p.

£R-315-B.  Dec. 27, 2004.  Drug Testing: Refusal to Test.  9p.

£R-315-C, Rev. 1.  May 30, 2007.  Mariner Drug Cases[Describes six mariner drug cases that were decided by an Administrative Law Judge.  This report was later superseded in part by NMA Report #R-204, Rev. 4]  29p.

£R-315-D.  Dec. 28, 2005,  Changes in Alcohol and Drug Testing Effective June 20, 2006.  10p.

£R-315-E.  Nov. 2, 2006.  Drug, Alcohol & Other Convictions and How They Affect Your Credential. 15p.

£R-315-F, Rev. 1.  Aug. 2009.  Marine Employers Drug Testing Guidance.  [Reprint of USCG Pamphlet, Aug. 2009.].  62p.

£R-315-G.  Mar. 23, 2012.  What Happens When Your Past “Crimes” Return to Haunt You[Also see #R-436, Rev. 3 & #R-448, Rev. 1.]  16p.


Credentialing. [Also see NMA Reports #R-204-C; #R-324; #R-372; #R-383; #R-393; #R-415, Rev. 2; #R-415-B; #R-428-I; #R-448]

£R-321.  June 2002.  Using U.S. Near-Coastal Licenses in Foreign Waters.  2p.


£R-322. Jun. 30, 2002.  Mariner Fatigue is an Accident Waiting to Happen[Reprint of Houma Courier newspaper article.]  2p.


USCG Assessor’s Manual

£R-324.  Assessor's Manual for Conducting Mariner Assessments[Reprint of USCG manual for assessors. 2000.]  16p.


£R-325.  Dec. 2, 2002.  Maritime Terrorist Threat Assessment for the New Orleans Area[Expert opinion following 9/11 attacks based on years of local experience as a USCG Master Chief.  Also refer to NMA Report #R-355, Rev. 1.]  11p.

£R-326.  Rev. 1, Jan. 14, 2005.  Autopilots, Watchkeeping, and Voyage Planning.  6p.

£R-334, Rev.2.  Dec. 27, 2005.  Foreign Seamen on U.S.-Flag Vessels  11p.

£R-338.  Nov. 11, 2002. Which Agency Regulates Uninspected Towing Vessels[This question arose following the Supreme Court’s “Mallard Bay” decision.  Also refer to NMA Reports #R-202-B and #R-300.]  5p.


Maritime Accidents:  Oversize and Overloaded Tows.

£R-340, Rev. 9.  Feb. 20, 2008.  NMA Report to Congress: Safety Problems With Oversize and Overloaded Tows..  37p.

£R-340-A.  Apr. 5, 2007, Oversize and Overloaded Tow Accident:  The “Elizabeth M” Case[Fatal towing accident during high water on the Ohio R. in western Pennsylvania.]  7p.

£R-340-B.  Feb. 18, 2008. U.S. Court of Appeals, Seventh Circuit.  Larry Gwin v. American River Transportation Co. (ARTCO)  [Federal Court decision with NMA comments.  NMA supported Capt. Gwin, an NMA Director.  Also refer to NMA Report #R-426.]..7p.



£R-341, Rev. 4.  June 22, 2011.  Petition to Congress: To Curb On-Board Smoking to Promote Merchant Mariner Health. 5p.

£R-341-A.  Jun. 29, 2006.  The Health Consequences of Involuntary Exposure to Tobacco Smoke.  Executive Summary of 2006 U.S. Surgeon General’s Report[Reprint of Government report.]  28p.


£R-343.  Dec. 23, 2002.  Forgotten Safety Issues on Small Passenger Vessels[A rash of small passenger vessel accidents triggered this report.]  7p.


Mariner Rights

£R-344, Rev.2.  Oct. 25, 2008.  Mariner Rights.  [A provocative introduction to a subject that should interest all merchant mariners.]  17p.

£R-344-A, Rev. 1.  July 6, 2008.  Mariner Rights: Maintenance and Cure  [By Mark L. Ross, Esq.]  3p.

£R-344-B.  July 3, 2010.  Identifying Jones Act Claims.  [By Lee J. Bloomfield, Esq.]  5p.

£R-346, Rev.3.  Nov. 11, 2004.  Work-Hour Abuse, Whistleblower Protection, and Deadhead Transportation.  (Note: Whistleblower protection for merchant mariners was amended in 2010 and the changes are fully explained in NMA Report #R-210, Rev. 2 and #R-210-A.)  12p

£R-349.  Rev. 2.  Sept. 30, 2015.  Report to Congress – Protecting Mariner Hearing[The Coast Guard failed to protect mariner hearing since the Occupational Safety & Health Act became law in 1970.  NMA asked Congress to take note of this failure on several occasions, the latest being in 2015.]  8p.

£R-349-A.  Dec. 23, 2009.  Supporting Documentation for NMA Report #R-349.  46p.


Mariners Request Congressional Assistance

£R-350. Rev. 3.  July 21, 2007.  Mariners Seek Congressional Help on Maritime Safety, Health and Work-Related Problems.  [Prepared testimony offered at Congressional hearing on Aug. 2, 2007.]  31p.

£R-350. Rev. 7, April 5, 2013.  Limited Tonnage Mariners Seek Congressional Assistance Marine Safety, Health, and Work-Related Issues. [NMA presented a list of issues important to limited-tonnage merchant mariners and called upon the House Coast Guard and Maritime Transportation Subcommittee and the Senate Commerce, Science and Transportation Committee to offer their assistance.  This 2013 report listed the status of each issue and progress or lack of progress to date.]  32p.

£R-350-A. Sept. 16, 2008.  NMA Testimony Before House Subcommittee on Coast Guard and Maritime Transportation RE: Mississippi River Oil Spill, July 23, 2008[Prepared statement to House Subcommittee.  Also refer to NMA Report #R-429-N that dealt directly with the topic under consideration and was distributed to all subcommittee members.]  2p.

£R-350-B.  Mar. 14, 2011.  Meet Our Mariners and Consider Our “Limited Tonnage” Mariners’ Viewpoints[Fourteen viewpoints solicited from our mariners on issues that concern them.]  10p.

Accident & Injury Reporting Requirements

£R-350-Y, Rev. 1.  July 4, 2013  [One of our most important reports submitted to both the USCG and to Congress.  Users should e-mail a request for the full document on disk from NMA]  70p. + 290p. of supporting documentation.


Towing Industry.  [Also see Reports #R-366; #R-401-A; #R-426; #R-427.]

£R-351, Rev.1.  Oct. 24, 2006.  How Safe Is The Towing Industry[Until the USCG greatly improves reporting of personal injuries, we cannot encourage mariners to seek employment in the towing industry.]  23p.

£R-351-A, Rev.1.  Oct. 28, 2010.  Safety Issues on Towing Vessels.  13p.  [Historical background.  Outstanding differences between inspected and uninspected vessels with emphasis on towing vessels.]

£R-352.  Mar. 17, 2003.  Unfair Labor Practices in the River Industry are Documented.  3p.


£R-353.  Rev.2.  July 3, 2006.  Lower-Level Mariners Are a Majority of U.S. Merchant Mariners.  7p.


Lifesaving and Firefighting Issues

£R-354, Rev. 4.  (Series).  Mar. 21, 2009.  An Appeal to the 111th. Congress on Lifesaving Issues that Affect Our Limited Tonnage Mariners.  41p.

£R-354-A.  (Series) Jan. 8, 2008.  Basic Survival:  The Regulatory Struggle for “Out-of-Water” Lifesaving Equipment[Contains detailed Correspondence with NTSB]  42p.

£R-354-C.  Mar. 4, 2010. “Ring Buoys, Regulators and Other Marine Hazards – What You Don’t Know Can Kill You.”  [By Paul Driscoll, Master Chief, USCG (retired), President, Life Safer, Inc. and inventor of the Personal Retriever described in this report.]  7p.


Maritime Security Issues

£R-355.  Rev. 1.  Feb. 17, 2003.  Maritime Security Issues.  [Also refer to NMA Report #R-325].  12p.


£R-361, Rev. 1.  June 1, 2006.  Gulf Intracoastal Waterway, Morgan City – Port Allen Alternate Route, and the Bayou Sorrel Bridge & Lock.  9p.

£R-363.  Apr. 3, 2003.  Report From the Subcommittee on Liftboat Operations to the National Offshore Safety Advisory Committee of the U.S. Coast Guard[Casualties involving liftboats led the USCG to seek recommendations from the National Offshore Safety Advisory Committee.  This is a reprint of the resulting NOSAC Report.]  12p.

£R-364.  Apr. 3, 2003.  Remarks of Captain Roland Rodney to NOSAC[Capt. Rodney, a member of NOSAC, discusses problems that face limited-tonnage mariners working in the offshore oil and towing sectors of the marine industry from a mariner’s viewpoint.]  2p.

£R-366.  May 1, 2003.  The Plight of Towing Vessel Personnel[Licensing, manning, employment issues, and giving the USCG the authority to inspect uninspected towing vessels are among the unresolved issues covered in this report.]  5p.

£R-368.  Rev.1.  June 6, 2006.  Controversial Rulemaking: Fire Suppression Systems and Voyage Planning for Towing Vessels[New regulations, drafted following the Scandia-North Cape fire and grounding, requires extensive fire protection coverage for towing vessels.  However, while the USCG previously proposed voyage planning for all towing vessels, they were misled into require it only for those vessels operating in unprotected offshore waters while neglecting the protection of valuable shoreside infrastructure on rivers and all inland waters.  This serious shortcoming was never corrected.]  15p.


R-370 (Series) – Hours-of-Service & “12-Hour Rule” Violations

£R-370, Rev. 4.  March 2012.  Report to Congress:  Abuse of Mariners Under the Two-Watch System.  [This report updated and utilized information from the remaining reports in the #R-370 series listed below and other reports to present our case for improved hours-of-service legislation from Congress.]   176p.


£R-370-A, Rev. 2.  (Series).  May 19, 2007..  Report to Congress: Fifth Anniversary of the Webbers Falls I-40 Fatal Bridge Accident: Unresolved Issues Revisited.  12p..

£R-370-B, Rev.4.  June 1, 2006.  Violation of the 12-Hour Rules: The Tug Chinook Strikes & Damages The Lake Washington Bridge.  14p.

£.  [Key words: Feemster v. Titan; Garrie v. James L. Gray; Meaige v. Hartley cases.  Winkler case and LA whistleblower statute.]

£R-370-E.  July 6, 2006.  Crew Endurance:  Work-Hour Laws and Regulations Need Review.  8p.

£R-370-F  July 6, 2006.  Crew Endurance Management Systems[Renumbered – formerly #R-362]  9p.

£R-370-G, Rev. 1.  Jan.25, 2012.  Crew Endurance: The Call Watch Cover-up.  [Renumbered from #R-375.]  14p.

£R-370-H.  Mar. 14, 2006. 12-Hour Rule Violations: Harbor Tugs and The “One-Watch” System.  4p.

£R-370-I.  Apr. 19, 2008.  Safe Management of Crew Travel Time. 

£R-370-K.  June 16, 2003. 12-Hour Rule Violations: The Verret Case.  12 p.

£R-370-L, Rev. 1.  Nov. 18, 2009  The National Transportation Safety Board Views on Fatigue and Hours of Service Regulations. 21p.

£R-370-M.  Aug. 12, 2010.  The Miss Amanda Incident: Overworked, Undermanned and Violating the 12-Hour Rule.  2p.

£R-370-N.  Oct. 11, 2012.  CG-CVC Policy Letter #12-05.  Hours of Rest – Implementation of the 2010 Amendments to the International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers, 1978.  9p.


£R-372. Rev.1.  June 25, 2003.  Questions About Towing Vessel Officer Licensing and Manning.  16p. [Questions directed to the USCG National Maritime Center and their answers provide useful but dated (2003) background material and information.]  15 p.

£R-376, Rev. 1, Nov.21, 2009. Prohibiting Job Discrimination – Q&A.[A brief review of Federal Equal Employment Opportunity Laws.]  10p.


Administrative Clemency

£R-377, Rev. 3.  Oct. 16, 2012.  Administrative Clemency[After a mariner runs afoul of the law and surrenders his/her credential, it may be possible to regain it at a future date.  While a number of USCG offices provide information to mariners on this procedure, we found that some mariners misinterpreted or misunderstood this information.  This report attempts to clarify the procedure.]  17p.


£R-378.  Sep. 22, 2003.  Hydrogen Sulfide – A Danger to Mariners[This report describes the dangers of H2S both in the oilfield setting and while handling petroleum cargoes.  Pertinent regulations are prescribed by the U.S. Department of Interior rather than the USCG which made them less accessible by our mariners on OSVs and towing vessels.]  9p.


£R-381.  Nov. 23, 2003.  Extinguishing the Federal Right of Way- A Mariner Issue  [Gassoway Lake Case.]  3p.

£R-382.  Dec. 8, 2003.  Why Our Mariners Don’t Get the Message,  4p.

£R-383, Rev.3.  Nov 18, 2006.  Designated Examiner Qualifications; The Good, The Bad, and The Ugly.  [This report discusses the responsibilities, liabilities, and compensation for any person who volunteers to become a Designated Examiner and takes part in evaluating the proficiency of a new Apprentice Mate/Steersman who applies for a Mate/Pilot of owing vessels endorsement.]  14p.

£R-386.  Jan. 18, 2004.  Comparative Report: Towboats in Canada and the United States.  3p.

£R-389.  Jan. 18, 2004.  The Notice of Violation (NOV) Program[In 1995 the USCG introduced a process where a simple NOV can be issued in the field to permit early resolution of apparent small oil spill and pollution prevention violations.   This process saved time, reduced the cost of unnecessary internal review, improved deterrence, and enabled earlier corrective action. The responsible party (RP) was given an option to pay a proposed penalty or to pursue his right to a full hearing.]  4p.


Major Accidents Affecting Towing Vessels  [Also see Reports #R-201-A; #R-225-A; #R-225-B; #R-225-C; #R-340-A; #R-429-D; #R-433; #R-433-A]

£R-390.  Feb. 14, 2004.  Loss of the Tug Thomas Hebert off the New Jersey Coast Fails to Bring Needed Changes[Dereliction of duty by watchstanders and failure of the steering system led to the “tripping” incident that sank the tug with multiple fatalities.]  7p.

£R-390-A.  Mar. 5, 2010.  Sinking of the M/V Elizabeth M and 6 Barges with Four Fatalities on Jan. 9, 2005 at the Montgomery Locks & Dam, Ohio River Mile Marker 31.7[A very careful USCG investigation illuminates the causes of this accident with three fatalities.  Also refer to NMA Report #R-340-A, a preliminary report of this accident.]  60p.

£R-390-B.  .Jan. 2004.  Industry /CG Team Issues Report on Downstreaming.  [By Bill Evans, The Waterways Journal]  2p.

£R-390-C.  Jan. 16, 2006 (Sept. 10, 2015).  Towing Vessel “Valour” Sinks with 3 Fatalities.  [Tug sank in storm after experiencing ballasting problems that could have been avoided.  USCG investigation and recommendations highlight these issues.  Includes 28 pages from 230 page USCG report.  Complete report in NMA file #M-619.]  39p.

£R-390-D.  Nov. 2, 1969 (Sept. 10, 2012)  Loss of the Motor Towing Vessel “Marjorie McAllister”, in the Atlantic Ocean on Nov. 2, 1969 (with 6 fatalities).  [The tug, without a tow, sank in 20 to 30-foot seas en route from New York to Jacksonville, FL, with no survivors after proceeding south of the Chesapeake apparently ignoring severe weather warnings  Report includes the formal USCG investigation.]  34p.

£R-393.  March 11, 2004.  USCG Licensing Procedures: An Affront to Lower-Level Mariners.  8p.


Potable Water and Food Service.

£R-395, Rev. 4.  Sept. 24, 2012.  Report to Congress – Providing Safe Potable Water for Merchant Vessels[One of NMA’s most important projects to provide clean potable water for all limited-tonnage mariners as part of the vessel inspection process was encouraged by Congress but sabotaged by Coast Guard obstruction from the outset.]  14p.

£R-395-A, Rev. 1, Dec. 23, 2009.  Supporting Documentation for NMA Report #R-395 (Food Service).  [Also refer to NMA Report #R-455, Rev. 6 .]  133p.

£R-395-B, Dec. 23, 2009.  Supporting Documentation for NMA Report #R-395 (Potable Water).  64p.


£R-396.  May 1, 2004.  How Western Rivers Mariners Lost Their Administrative Law Judge[Part of the background of the scandal involving USCG Administrative Law Judges that finally gained the attention of Congress in 2007.  Also refer to NMA Report #R-429-K that covers the 2007 Congressional hearing.]  4p.

£R-397.  May 8, 2004.  Father Sinclair Oubre Speaks for All Mariners on Elimination of Crew List Visa.  3p.

£R-398, Rev.2,  Dec. 1, 2005.  Crew Van – Death Van[By Captain David C. Whitehurst.]  5p.


Maritime Accident – Oversize and Overloaded Tows.  [Also refer to NMA Reports #R-390-A; #R-427.]

£R-399.  Jun. 14, 2004.  Danger on the Illinois Waterway: Towboat Pilot Loses License After He Accepts High Risk Assignment.  10p.

£R-400, Rev. 8.  Aug. 12, 2004.  Oversize and Overloaded Tows: Towing Vessel Horsepower[This report was compiled by the GCMA Towing Vessel Horsepower Committee, all experienced river pilots and engineers.]  18p.  


Historical Documents (Series).  [Also Refer to NMA Reports #R-428-A; #R-428-C; #R-429-B; #429-F; #428-A; #428-B; #428-C.]

£R-401, Rev. 1.  Mar. 8, 2005. Crew Endurance and the Towing Vessel Engineers – A Direct Appeal to Congress.  30p.

£R-401-A.  Uninspected Towing Vessels; An Analysis of the Historical and Contemporary Issue of Their Regulation.  July 1980  [By Thomas Alegretti.  History of the legislative attempts to inspect and regulate diesel-powered towing vessels culminating in the Pilothouse Licensing Act of 1972.  However, the inspection of towing vessels will have to wait until Final Rules appear in 2016.]  86p.

£R-401-B.  Jan. 8, 2007.  Finally Answered: How Bureaucracy Wrecked the Coast Guard Merchant Marine Licensing and Documentation Computer System.   [Information from a 1998 FOIA request describing how initial attempts to computerize the USCG Merchant Vessel Personnel Division failed.]  4p.

£R-401-C.  Dec. 2005.  Acquisition of the National Security Cutter[This report contains a reprint of Department of Homeland Security, Office of the Inspector General, Report #OIG-07-23, a transcript of a CBS “60 Minutes” program titled “USCG Deepwater Trouble”, an OIG “Deepwater: 120-day update from July 12, 2007, and GAO Report #08-531T.  179p.]

£R-401-D. Mar. 21, 2006. U.S. Coast Guard. Report on Demonstration Project: Implementing the Crew Endurance Management System (CEMS) on Towing Vessels[Congress also ordered a “Demonstration Project” of Crew Endurance Management Systems (CEMS) be conducted before prescribing any new regulations.  The Department of Homeland Security delivered the Report on the Demonstration Project to Congress on Mar. 29, 2006]  140p.

£R-401-E.  Feb. 12, 2008.  Marine Safety: Where the Coast Guard Went Wrong.  [Reprint of a report by VADM James C. Card (USCG, Ret’d) titled Coast Guard Marine Safety Analysis: An Independent Assessment and Suggestions for Improvement dated 16 Nov. 2007 with an introduction by NMA.  Also refer to NMA Report #R-442, a Congressional hearing on the same subject preceding the completion of Admiral Card’s Report.]  36p.

£R-401-F.  Feb. 2007.  110’/123’ Maritime Patrol Boat Modernization Project[Reprint of Department of Homeland Security, Office of the Inspector General, Report #OIG-07-27, on failed attempt to lengthen USCG 110-ft patrol boats.]  34p.

£R-401-G.  Feb. 29, 2008. Renewed Efforts in the Marine Safety Program[Engaging with the Coast Guard following the release of VADM Card’s report (#R-401-E) and includes a reprint of ALCOAST messages from the Commandant and Assistant Commandant for Marine Safety, Security, and Stewardship ]  7p.

£R-401-H.  Jan. 6, 2009. Coast Guard Issues Marine Safety Performance Plan (2009-2014).  45p.

£R-401-I.  Dec. 5, 2009. The Posse Comitatus Act and Homeland Security,  [By John R. Brinkerhoff (Feb. 2002)  “Whoever, except in cases and under circumstances expressly authorized by the Constitution or Act of Congress, willfully uses any part of the Army or the Air Force as a posse comitatus or otherwise to execute the laws shall be fined under this title or imprisoned not more than two years, or both.” -Title 18, U.S. Code, Section 1385.]  6p.

£R-401-J.  Sept. 2000.  Offshore Accountability Watch[GCMA Campaign for Corporate Responsibility, 2000.] 16p.

£R-401-K.  May 16, 2011.  HR-1288 – World War II Merchant Marine Service Act..  [By Don Horton, Coastwise Merchant Seaman’s Association.]  20p

£R-401-L.  July 7, 2011. Problems in Coast Guard Licensing: 1986-1999.  11p. 

£R-401-M.  Apr. 15, 1999.  Review of Working Conditions in the Offshore Oil Industry – 1999[Also refer to NMA Reports #R-201; #R-290-A; #R-290-B that were prepared during the same time period.]  10p.

£R-401-N.  Jan. 19, 1999.  The 12/24-Hour Rule  [By LCDR Tom Beistle.]   18p.

£R-401-P.  Nov. 7, 2012.  A Report to Congress Concerning the Need for Engineers on Uninspected Towing Vessels[Reprint, U.S. Department of Transportation, May 1973.]  58p

£R-401-Q.  March 2013.  Prevention of Towing Vessel Crew Member Falls Overboard: Best Management Practices[By Capt. Steven Huttman, Chairman, Towing Safety Advisory Committee.  TSAC Task #12-01.]  12p.


£R-402.  July 14, 2004.  Ballast Water Management.  20p.

£R-403.  Sept. 19, 2004.  Stress and the Licensed Mariner.  20p.  [Also refer to NMA Reports #R-200; #R-201]

£R-404.  Oct. 19, 2004.  Substance Abuse: Employee Assistance Programs.  4p.

£R-405, Rev. 1, June 13, 2013.  Relinquishing Control of Your Vessel[It is always the Master's responsibility to set a watch schedule that complies with law and regulation.  It is the owner's responsibility to provide a properly credentialed crew that is adequate to do the job, whatever that job may be.  The events that led to this ALJ hearing should discourage an officer from turning over control of his vessel to a deckhand or other crewmember who is not properly endorsed.  This is an example of what can happen to your credential if you don’t follow the rules and something goes wrong.]  8p.


Fatigue.  [Also refer to NMA Reports #R-322 and #R-403]

£R-408, 2004.  MAIB Bridge Watchkeeping Safety Study[Even when opportunities to rest arise, there is no guarantee that a bridge watchkeeping officer wants to, or is able to, sleep.  Personal as well as job-related tasks still have to be completed, and the noise and motion of the ship, as well as ambient levels of temperature and light, will all affect an individual’s ability to sleep.  These and other factors are discussed in this U.K. government report.]  52p.

£R-408-A.  Oct. 24, 2008.  Seafarer Fatigue: Wake Up to the Dangers[Reprint of a report on the problem of fatigue as collected from a global sampling of 2,500 merchant mariners by the International Transport Workers Federation (ITF).   9p.

£R-409.  Feb. 13, 2005.  What is a Safety Management System for Towing Vessels[Federal regulations in 33 CFR Part 96 already apply to a number of towing vessels engaged on international voyages.  This and other proposals are being considered by USCG officials for introduction during the towing vessel inspection rulemaking that will be announced in 2016.  This report looks at the existing Federal regulations.]  10p.

Vessel Engineers Injuries & Fatalities.

£R-412, Rev. 1  March 21, 2013  Report to Congress:  Towboat Engineer’s Death Points to Vessel Manning Issues.  21p.

      [For other fatalities involving ACBL vessels refer to NMA Reports #R-293-C, #R-433, #R-433-A.]

£R-412-A, Rev. 1. Mar. 14, 2012.  In Search of Justice for Chief Engineer Leon Manderson.  36p.


£R-413, Rev. 1.  Feb. 11, 2006.  A Direct Appeal to Congress to Reform the Two-Watch System.  21p.


Coast Guard Mismanagement of Limited Tonnage Mariners.  [Also see #R-324; #372; #R-383; #R-393]

£R-415, Rev. 2.  (Series)  Nov. 25, 2006.  Coast Guard Mismanagement of Lower Level Merchant Marine Personnel: Training and Licensing Problems for Towing Vessel Officers.  12p.

£R-415-B, Rev. 1.  (Series)  Nov. 27, 2006.  Medical & Physical Evaluation Guidelines for Merchant Mariner Credentials.  [Although this report provides background information to NVIC 04-08, working mariners should consult the latest change to this NVIC available on the internet.  To date, this is Change 1 to Medical and Physical Evaluation Guidelines for Merchant Mariner Credentials, NVIC 04-08, COMDTPUB 16700.4.]  62p.

£R-415-C.  Jan. 1, 2009.  Our Association Petitions the Coast Guard to Relax Restrictions on 100-Ton Towing Officer Licenses and Endorsements.  10p.


Towing Safety Advisory Committee.  [Also see #R-384, Rev. 1; #R-417, Rev. 2; #R-421]

£R-417, Rev. 1,  Feb. 25, 2007.  Report to the 110th Congress: Request for Congressional Oversight on the Towing Safety Advisory Committee. (TSAC).   11p.

£R-417, Rev. 2,  Oct. 10, 2011.  Report to the 112th. Congress: Request for Continued Congressional Oversight on the Towing Safety Advisory Committee (TSAC).  10p.

£R-417-A. Rev. 1, Aug. 27, 2008.  Comments on Revising NVIC 4-01, “Licensing and Manning for Officers of Towing Vessels” to the Towing Safety Advisory Committee. 9p.

£R-417-B. June 16, 2011.  NMA Comments to the Towing Safety Advisory Committee Meeting, June 16, 2011.  Docket #USCG-2011-0144,  [NMA is concerned about the quality leadership provided by the USCG as industry regulators and how it affects our working mariners.  We are also concerned about industry trends in cutting vessel manning to the bone along with the absence of a daily work-hour limit for unlicensed crewmembers.  We are also express concern with reported violations of the statutory 12-hour rules for officers that are not investigated by Coast Guard officials.12p.


Charts and Publications:

£R-420, Rev. 1.  Nov. 24, 2005.  Correcting and Maintaining Your Nautical Charts and Publications.  8p.

£R-420-A.  June 25, 2008.  Nautical Charts and Coast Guard Inspections.  5p.


£R-421.  Nov. 22, 2005.  GCMA Suggestions for an Apprentice Mate/Steersman Model Training Course[NMA suggestions presented to the Towing Safety Advisory Committee (TSAC).].  4p.

£R-426, Rev. 1.  Aug. 27, 2007.  Report to Congress: Challenges Facing the Coast Guard’s Marine Safety Program – Effectively Regulating the Towing Industry[Over 17,000 dry cargo barges, construction barges, and other uninspected non-self-propelled commercial vessels are not required to be inspected by the USCG.  OSHA is supposed to be responsible for workplace safety on these barges but lacks the personnel and access to regulate them properly.  Although OSHA’s actions in investigating casualties like the Athena construction barge accident show that they can act in exceptional cases,  our mariners who work on towing vessels remain at risk when boarding and working on many of the 17,000 barges that are not properly maintained and that OSHA never visits.]  14p.

£R-427.  Mar. 24, 2005.  ARTCO-Six Mariners Stand Up Against Intimidation to Move Oversize & Overloaded Tows[A landmark Federal case brought by mariners against a major towing company operating on western rivers and inland waters.  Also refer to NMA Report #R-340.]  16p.


Maritime Education and Training.  [Also see #R-415-A; #R-415-B]

£R-428, Rev.1.  Oct. 23, 2006.  Report to Congress: The Forgotten Mariners. Maritime Education & Training for Entry-Level Deck & Engine Personnel.  30p. 

£R-428-A.  Oct. 28, 2006.  Maritime Education & Training for Lower-Level Mariners.  The Newman Report.  [Includes complete reprint of 1973 USCG report on the status of maritime education and training in the Gulf Coast area that led to major licensing changes.]  115p.

£R-428-B, Rev. 1.  Dec. 30, 1996.  Report of the Coast Guard-AWO Quality Action Team on Towing Vessel Crew Fatalities.   [Reprint of 1996 AWO/Coast Guard Report on crew fatalities.]  78p.  .

£R-428-C.  Oct. 29, 2006.  Maritime Education and Training: Functional Job Analysis (FJA) of Maritime Personnel.,   [Includes reprint of 1982 USCG report on vessels serving in the offshore oil industry.]  55p.

£R-428-D.  Feb. 13, 2007.  Report to the 110th Congress: Substandard Coast Guard Merchant Marine Personnel Services.   55p.  

£R-428-D, Rev. 1.  May 1, 2009.  Report to the 111th Congress: Substandard Coast Guard Merchant Mariner Personnel Services[Both the original NMA Report #R-428-D (above) and this revision were provided to each member of the House Subcommittee on Coast Guard and Maritime Transportation on the day of the first hearing that dealt with the serious problems that mariners reported occurred at the National Maritime Center that caused months of delays in issuing credentials.  Refer to NMA Report #R-428-I.]  21p.

£R-428-H.  Apr. 15, 2007.  Maritime Education & Training: Lower-Level Engineering Programs[The engineroom is a dangerous place.  The USCG does not require and certain sectors of maritime industry do not offer meaningful safety and job specific training programs for mariners who work in enginerooms and machinery spaces of America’s 6,500 inspected small passenger vessels, 6,200 soon-to-be inspected tugs and towboats, and 1,500 oilfield vessels or our large fleet of uninspected fishing vessels.  The safety record of the industry suffers, valuable machinery is neglected, mistreated, or damaged and hundreds of mariners suffer preventable injuries.  NMA encourages formal and recordable basic safety training for every mariner whose duties take them into a working engineroom at any time.  We encourage advanced training for those assigned duties in any machinery space.]  23p.

£R-428-I.  July 9, 2009.  Congressional Hearing Testimony on the National Maritime Center and Mariner Credentialing.  Subcommittee on Coast Guard and Maritime Transportation.  [Full hearing testimony including prepared testimony of NMA.]  55p.

£R-428-K, Rev. 8.  Feb. 25, 2014.  Report to Congress and Maritime Advisory Committees: Requests for Audit to Define and Reaffirm the Public’s Right to Access to the Coast Guard’s Professional Examination Question & Answer Database.  [NMA and its officers have fought the USCG since 1986 for public access to all questions, answers, and illustrations used on USCG professional examinations.  These Q&A were removed from the internet for two years but were restored as the result of our appeals.]  65p.

£R-428-L.  Mar. 7, 2011.  Milner v. Department of the Navy.  36p.  [This U.S. Supreme Court decision on the meaning of the Freedom of Information Act was cited by the USCG for finally restoring exam questions, answers, and illustrations to the internet.  Refer to NMA Report #R-429-K, Enclosure #19.]  36p.


R-429 (Series) Coast Guard Investigations and Administrative Law. [Also see Report #R-389; #R-396; #R-204, Rev.1 ]

£R-429, Rev. 1,  Sept. 5, 2010.  NMA Report to Congress: Shortcomings in Marine Safety Investigations[In this report, we examine the actual accidents and personal injuries aboard thousands of vessels served by our mariners.  We assert that properly investigating these accidents should be a much higher priority item than it is today because of the dangerous nature of the towing, offshore oil, and small passenger vessel sectors of the maritime industry.]  51p.

£R-429-A, Rev 1.  Mar. 20, 2007.  U.S. Coast Guard Marine Casualty Investigations and Reporting: Analysis and Recommendations for Improvement  [By James G. Byers, Susan G. Hill, & Anita Rothblum.  This is a partial reprint of an obscure 1994 USCG document that we mentioned in a number of documents sent to the USCG officials and to Members of Congress.  After receiving serious complaints from our mariners, we questioned the quality, consistency, and focus of some investigations that focused upon mariners while downplaying the culpability of the employer.]  66p. 

£R-429-B, Rev. 1.  July 26, 1996.  Report of the USCG Quality Action Team on Marine Safety Investigations.  [Reprint of a joint AWO/USCG Report.]  78p.

£R-429-C, Rev. 1.  Aug. 30, 2010.  Coast Guard Marine Casualty Investigations[Our questions about marine casualty investigations were answered by pertinent passages from Volume V of the Marine Safety Manual (MSM) – the resource book for all such questions.]  12p.

£R-429-D.  (Series)  Oct. 8, 2006.  Coast Guard Investigations: Buzzard’s Bay Tank Barge Grounding and Oil Spill, April 27, 2003.  12p. 

£R-429-E.  Nov. 20, 2006.  Accident Investigations: If You Are Involved in an Accident, Don’t Expect to be Read Your Rights[Excellent advice to mariners by Capt. Tuuli Messer.  Reprint from Professional Mariner.].  2p.  

£R-429-G. Rev. 2.  Feb. 24, 2007.  Report to Congress: Sharpening Accident Investigation Tools By Establishing Logbook Standards for Lower-Level Mariners.  [Refer to NMA Report #R-218 where Congress acted to improve logbook standards for all commercial vessels and NMA Report #R-234, Rev. 3.]  11p.

£R-429-I, Rev.2.  Mar. 24, 2007.  Investigations: Enforcement of Existing Personal Injury Reporting Requirements.  [Also refer to NMA Report #R-370, Rev. 4.]  7p.

£R-429-J.  July 4, 2007.  Investigations: Report to Congress – Coast Guard Abuses of the Administrative Law System.  28p.

£R-429-K.  Aug. 8, 2007.  Congressional Subcommittee Hears About Coast Guard Abuse of the Administrative Law System.   [Report on Congressional Hearing on the USCG Administrative Law system held July 31, 2007]  52p.

R-429-M, Rev.1.  Oct. 18, 2013.  Coast Guard’s Management of the Marine Casualty Investigations.  [Contains NMA introduction accompanied by reprints of Department of Homeland Security Report #OIG-08-51]  72p.

£R-429-N.  July 28, 2008. Report to the 110th Congress: Maritime Towing Accidents Involving Apprentice Mates/Steersmen[A comprehensive review of accidents involving Apprentice Mates and steersmen with NMA recommendations.]  24p.

£R-429-O  Aug. 11, 2008..NMA Petitions the Coast Guard to Change the ALJ System[NMA’s concern is that USCG Investigating Officers will abuse their discretion to appeal cases where the ALJ ruled against the Coast Guard.  That concern remains today.]  10p.

£R-429-P, Rev. 1.  Jan. 1, 2010.  Mariners Drown When “Justice Capsizes”– The Murray Rogers Case[Also Refer to NMA Report #R-429-X.]  9p.

£R-429-Q.  Mar. 21, 2009.  U.S. Coast Guard versus Lt. Eric N. Shine.  [Also refer to NMA Reports #R-204, Rev. 4),34p.

£R-429-S  June 26, 2009  NMA Letter to Congressional Requesters on the Government Accountability Office (GAO) Report #09-498 on the Coast Guard’s Administrative Law System[NMA letter to concerned Congressmen that a report published by the Government Accountability Office (i.e., GAO Report #09-498) dealing with the Coast Guard’s “ALJ System” was a “whitewash” of the Coast Guard Administrative Law and investigative functions and that those functions deserved much closer scrutiny by Congress.]  12p.

£R-429-T.  Apr. 30, 2010.  Geneva Conventions Re-defined by Eric N. Shine.  12p.  [A paper by an NMA member.]

£R-429-V.  Aug.20, 2010.  NMA Report to Congress on DHS “Recommendations to Improve the Coast Guard’s System for Adjudicating Suspension and Revocation Matters.”.  [Historically, S&R and class II civil penalties represent only a very small portion of the USCGs mission-related activities.  In general, the these Administrative proceedings are intended to be more informal, less expensive, and faster than regular court proceedings, while still providing fundamental due process to respondents.  S&R proceedings are designed so that neither the Coast Guard nor the respondent needs legal representation to resolve matters in dispute.  We believe the goal is a worthy one and that the included DHS report #OIG-10-107 helps to outline a path by which the goal may be attained.]  50p.

£R-429-W.  Oct. 5, 2010.  Allegations of Misconduct Within the Coast Guard Administrative Law Judge Program.  [This report addresses certain allegations made against the USCG's ALJ program, including but not limited to allegations that the program is biased in favor of the USCG and that the Chief ALJ either controls or attempts to control the outcome of cases decided by his subordinate judges.  It is based on interviews with employees and officials of relevant agencies and institutions, direct observations, and a review of applicable documents.  Includes reprint of DHS OIG Report #R-OIG-10-108]  54 p.

£R-429-X., Rev 1.  Mar. 10, 2011.  The Coast Guard Abused Captain Rogers Just Because They Could[By Capt. Murray Rogers.]  8p.  

Tonnage Issues

£R-430.  Rev.2.  June 25, 2006.  What is an OSV?   [An explanation of ITC Tonnage vs GRT tonnage]  3p.


Small Passenger Vessel Casualties.  [Also see #R-441]

£R-432.  Aug. 15, 2006.  Coast Guard Inspection SNAFU Leaves Four Dead and Many Injured and Hundreds of Boat Owners Affected.   [Lady D pontoon small passenger vessel accident in Baltimore Harbor Mar. 6, 2004.]  47p.


Towing Vessel Fatalities

£R-433.  Sept. 17, 2006.  Towing Vessel Fatalities.  GCMA Coverage of Two Accidents on TSAC Sept. 2006 Agenda[Fatal accidents, Crushing death of Joseph Hulen on M/V Wally Roller and the M/V A.V. Kastner accident at Elk River, MD, that drowned 4 mariners.]  12p.

£R-433-A.  March 22, 2010.  Another ACL Towboat Deckhand Falls Overboard and is Crushed to Death.  3p. [Estate of Brian Edward Messinger, Jr. v. ACL]

£R-433-B.  Dec. 17, 2011.  The Preventable Death of Deckhand Christopher Mink.  [Employer knowingly assigned deckhand to perform work that he had never performed at this mining loadout facility before with a shore-based manager who was filling in as a relief pilot on a job with which he also was unfamiliar.  No adequate safety briefing, safety procedures, or supervision were provided.  The winch operator admitted to tightening the cable while deckhand was still trying to release the cable.  Work records showed crew worked  excessive hours leading up to the tragedy.]  6p.


£R-436, Rev. 3, Mar. 5, 2009.  The Coast Guard Appeals ProcessWhich “Appeal” Regulations Should Our Mariners be Aware of?  10p.

£R-437.  Nov. 28, 2006.  Ways to Retain New Crewmembers and Keep Seasoned Crews[By Capt. David C. Whitehurst.  A clear statement of goals sought by our Association.]  2p.

£R-438, Rev. 1.  Mar. 12, 2008.  Criminalization of Mariners.  [By Mike Rodriguez, Executive Assistant to the President, International Organization of Masters, Mates and Pilots.] .10p.


Mariner Health & Medical Issues:

£R-440-A, Rev. 1.  Sept 30, 2008.  Mariner Health and the New Medical NVIC[NMA introduction and reprint of the NVIC.]  79p.

£R-440-B.  April 13, 2009.  Abuses of the Medical NVIC: An Assault on Our Mariners. 16p.  [Key Words: Body Mass Index]

£R-440-C. Rev. 1.  Jan. 25, 2012.  Obstructive Sleep Apnea. [By: Dr. Pedro J Cuartas, DDS, South Louisiana Medical Update + NTSB Safety Recommendation]  9p.

£R-440-D.  Sept. 11, 2012.  Merchant Mariner Medical Issues[This report served to introduce NMA to the newly-formed Merchant Marine Medical Advisory Committee (MMMAC) and contained specific requests for consideration of mariner medical, public health, and safety issues.  New medical evaluation requirements put in place by the USCG shattered the career paths for many mariners.  The USCG Marine Safety Directorate personnel did this without a full knowledge of the industry or of the human beings whose plans and careers they discouraged, damaged, or destroyed.  Their interpretation did not serve the interests of most of our limited-tonnage mariners in inland or coastwise service within the U.S.]  11p.


£R-441, July 21, 2007,  Coast Guard Obstructs Preventive Maintenance – NTSB.  [Excerpts from report NTSB/MAR-06/02.]  4p.

£R-442, Aug. 2, 2007,  Hearing on Challenges Facing the Coast Guard’s Marine Safety Program.  [Report on the full hearing and related reports.  GCMA testified in the hearing on Aug. 2, 2007.  Refer to NMA Report #R-350, Rev. 3 for our prepared testimony offered at this Congressional hearing.]  105p.

£R-443. Aug. 13, 2004.  Black Listing and the Fair Credit Reporting Act (FCRA) [Black List (aka “Blackball”) is a list of persons under suspicion, disfavor, censure, etc. privately exchanged among employers to bar those individuals from employment because of perceived untrustworthiness or for holding opinions considered undesirable.  While NMA strongly condemns this widespread practice we were unable to curb it.]  8p.


Pollution Prevention & Environmental Crimes:

£R-444, Rev.2   Jan. 20, 2006.  Bilge Water Processing Equipment: Comments to the Docket[This report reflects problems experienced with oily water separators (OWS) and the need for formal training on their proper use and regulatory requirements for our mariners required to use this equipment in light of extreme penalties for “magic pipes” used to bypassing faulty equipment and related inaccurate logbook entries.]  31p. 

£R-444-A, Rev. 1.  Feb. 21, 2008.  Coast Guard Environmental Crime Disclosure Policy[Report includes an NMA introduction and an article by Dennis L. Bryant, Senior Counsel, Holland & Knight LLP.  Concludes with excerpt from USCG Law Enforcement Manual, Appendix V.]  12p.

£R-444-B. National Pollutant Discharge Elimination System (NPDES)   [Vessel General Permit Regulations Eff. Feb. 6, 2008.]  6p. 

£R-444-C.  May 24, 2010.  Investigative Report on Minerals Management Service by the Department of the Interior Inspector General[Government report of investigation of allegations of agency wrongdoing.]  12p.

£R-445, Rev.1.  Mar. 8, 2012.  Report to Congress: Coast Guard Failed to Protect Mariners from Asbestos[Apparently all USCG units that have asbestos- containing materials within its facility have trained asbestos abatement personnel to remove it.   Similar OSHA regulations apply to landside workers.  Why, then, must our mariners grind, disassemble and remove asbestos-containing materials from workboats?]  10p. 


£R-446. Rev.1.  Feb. 25,  2008  Proposed Rule Changes Affect Towing Vessel Officers.  [Examples of why we believe our mariners must become much more familiar with and responsive to the rulemaking process.]   19p.

£R-448. Rev. 1, July 9, 2011 Reconsider the Use of Assessment Periods in Merchant Mariner Credentialing.  [Our Association explains why the continued use of “Assessment Periods” as required in 46 CFR Tables 10.211(g) – Guidelines for Evaluating Applicants for Merchant Mariner Credentials Who Have Criminal Convictions and Table 10.201(h) are harmful to the retention of trained and experienced mariners.]  10p.

£R-450. July 15, 2008.  Maritime Confined Space Fatalities.  [Includes MAIB report on M/V Viking Islay fatalities in OSV Chain Locker.]

£R-451. Rev. 1 Aug. 20, 2013.  Towing Vessel Officers Need Practical Stability Training[Examples of why towing vessel officers need practical stability training now and before any additional credentialing takes place.]  20p.

£R-452. Dec. 9, 2008.  Towing Industry Statistics.  7p.

£R-453. Oct. 9, 2009.  Seafarer Shoreside Access. 5p.


International Labour Organisation:

£R-454.  July 2, 2006.  International Labour Organisation (ILO) Maritime Labour Convention, 2006.  [Introductory articles by AFL-CIO Maritime Trades Department and the Seafarers International Union followed by reprint of the IMO Convention.]  78p.

R-454-A.  April 1, 2013.  Guidance Implementing the Maritime Labour Convention, 2006  [USCG Draft NVIC.]  47p.


£R-455, Rev. 6.  Mar. 28, 2013.  Food Service Aboard Limited Tonnage Commercial Vessels[In NMA Report #R-395, Rev. 4 we asked Congress to direct the USCG to ensure that potable water systems on all merchant vessels are properly constructed and the water is regularly tested to provide clean and sanitary fresh water for drinking, cooking, laundry, and bathing.  The USCG opened docket USCG-2006-20062 on July 11, 2005 and solicited input from the public and thereafter stonewalled the issueSince Congress provided additional billets for USCG inspectors and investigators, we ask those officers to revisit and attend to this issue for all working mariners.  In addition, one of the most persistent mariner complaints is when an employer removes a cook from a workboat in 24-hour service to cut expenses.  We summarized the results of removing the cook to the disadvantage of our mariners health.]  8p.


Commercial Vessel Theft

£R-456, Rev. 1.  Dec. 1, 2010.  The Krutko Case:  Commercial Boat Theft, Government Corruption, and False Imprisonment In the Sunshine State.  [This case continues to evolve five years later.]  20p.


£R-457.  Dec. 8, 2010.  Information on the EPA Marine Engine Remanufacture Program.  15p.

£R-458.  June 30, 2011.  Federal Advisory Committees: An Overview[By Wendy S. Ginsberg, Analyst in American National Government, Congressional Research Service.]  23 pgs.

£R-459.  April 2011. Report and Recommendation of the Special Master Concerning NOAA Enforcement Action of Certain Designated Cases.  [By Hon. Charles B. Swartwood, III (ret.), Special Master, JAMS, and Assistants Petia I. Loukova Iannicelli, Esq. and Tony K. Lu, Esq.  This report is now included in NMA Report #R-204, Rev. 4.]  240 p.

£R-460.  Nov. 10, 2011.  New Focus on Regulating Offshore Drilling and Production[Address by BSEE Director Bromwich to IADC]  6p.

£R-461.  Mar. 7, 2013.  Problems With Limited Tonnage/Horsepower Engineer Examinations Electrical Questions, Answers & Illustrations – A Report to Our Mariners.  [NMA received reports that mariners sitting for limited engineer licenses were stumped by Electrical questions, answers and illustrations far in excess of what they had prepared for.  This report outlined preliminary findings that confirmed these reports.  The problems resulted when the National Maritime Center removed all exam questions, answers and illustration from the public domain on July 12, 2010 as explained in NMA Report #R-428-K, Rev. 8 posted on our website.  The problem continued to develop for the next two years until new questions, answers, and some illustrations were posted in response to public comment and appeals.]  21p.


£R-462, Rev. 3.  May 15, 2013.  The Coast Guard’s War on Whistleblowers: The Eric Shine Story. 19pgs.  [Also refer to NMA Reports #R-210, Rev. 2,  #R-429-Q, #429-T.]




R-200.  [Renumbered as R-370-L, 11/18/09.]

£R-202-A [Renumbered as #R-276-K, Rev.3.  Contents used in #R-370, Rev. 4, Chapter 15.]

£R-203-B. /£R-203-D/£R-203-E. Withdrawn.

£R-204. Renumbered as R-405, Rev. 1.

£R-204-D. Withdrawn.

£R-223-A, Rev. 1, Re-numbered as R-215

£R-231, Rev. 1, [Renumbered as R-401-A]

£R-239.  [Replaced by Report #R-279, Rev. 8]

£R-254.  [Revised, re-numbered and replaced by #R-276-D.]

£R-258.  [Revised and Renumbered as #R-370, Rev. 4, Mar. 14, 2012.  Contained USCG Policy Letter #G-MOC 04-00, Change 1]

£R-261.  [Renumbered as #R-401-J]

£R-267.  [Revised and renumbered as NMA Report #R-351-A, Rev. 1.]

£R-272.  [Canceled. 6/2/11]

£R-276-B.  [Canceled 10/24/11]

£R-281.  [Renumbered as #R-290-A] 

£R-282, Rev. 1, [Renumbered and replaced by #R-276-C, Rev. 2.

£R-291, Rev. 1, [Replaced by #R-429-I[

£R-292, Rev. 1, [Replaced by #R-350-YI

£R-294.  [Renumbered and revised as R-207, Rev. 1]

£R-299, Rev. 1 [Moved to #R-202, Rev. 5 as Case #12]

R-308. [Moved to #R-370, Rev. 4 as Chapter 13, Example 6]

£R-311, Rev.2.  Replaced with NMA Report #R-208.

£R-328.  Replaced by NMA Report #R-208.  

£R-332, Rev. 3,  [Withdrawn.  Replaced by #R-350, Rev. 5]

£R-333, Rev. 3,  [Renumbered as R-202, Rev. 4.]

£R-342  [Refer to #R-204-C, Rev. 6]

£R-347, Rev. 1.  [Cancelled.  Revised, updated & renumbered as #R-202-B.] 

£R-348. [Revised, updated, & re-numbered as Report #R-211.].

£R-350. Rev. 5, “Issue LRenumbered as #R-210, Rev. 1

£R-354-B. [Reserved]

£R-356. [Withdrawn]

£R-357. [Withdrawn]

£R-370 (Series) Information in most of this series was updated and consolidated into #R-370, Rev. 4 (3/20/12)

£R-370-C Rev. 2.  [Withdrawn 6/09; Content merged with #R-370-D, Rev.6]

£R-370-K. [Merged into R-202, Rev. 5, Case #1]

£R-370-J.  [Renumbered as #R-401-N as a document of possible “Historical” interest.]

£R-372, Rev. 1 [Withdrawn]

£R-375. [Revised and renumbered R-370-G, Rev. 1]

£R-377-A & B-B [Withdrawn. 10/16/12. See R-377, Rev-3.]

£R-380. [Canceled.]

£R-384, Rev. 1.   [Withdrawn.  See Newsletter #78]

£R-388.  [Withdrawn].

£R-407.  [Withdrawn. N/L #82]

£R-410.  [Withdrawn]

£R-411.  [Revised and re-numbered as #R-293-B, Rev. 8]

£R-415-A.  [Revised, updated, and re-numbered as Report #R-211].

£R-416.  [Replaced by R-276-A].

£R-418.  [Renumbered as R-315-G.]

£R-419.  [Replaced by R-276-A].

£R-422.  [Renumbered as #R-223, Rev. 1]  

£R-428-E.  [Withdrawn and replaced with R#-203-A].

£R-428-J.  [Withdrawn. Replaced by $R-428-K, Rev. 1.]

£R-429-F.  [Replaced by R-428-B, Rev. 1.]

£R-429-G.  [Replaced by R-218.]

R-429-L.  [Replaced by R-462, Rev. 3.]

£R-429-R.  [Replaced by R-429-P, Rev. 1]
£R-433-A, Merged into R-202, Rev. 5 as Case #14]

£R-439.  [Canceled – Outdated.] [For TWIC information go to]

£R-447 Report withdrawn 10/12/15.

£R-449, Rev. 1.  Replaced by R-202-C, Rev. 2.

£R-429-U.  Canceled. Replaced by R-459.  See File #GCM-304.

£R-440, Rev. 1.  Moved to #R-202, Rev. 5 as Cases #2 &10 .]

R-440-D.  Rev. 2.  Revised and updated edition was renumbered as #R-214]

£R-459.  This report is also used in NMA Report #R-204, Rev. 4.

£R-462-A [Withdrawn]