Tug and tow operations—coastal pilotage requirements—advisory note

This advisory note informs coastal pilotage stakeholders about requirements for embarking AMSA-licensed coastal pilots during applicable ‘tug & tow’ operations in coastal pilotage areas.

Tug & tow operations 

A licensed coastal pilot must be embarked for the duration of the ‘tug & tow’ voyage conducted in a coastal pilotage area, if either the towing vessel, or the vessel being towed, is any of the following: 

  • 70m or longer in length overall
  • a loaded* oil tanker (irrespective of length)
  • a loaded* chemical carrier (irrespective of length)
  • a loaded* liquefied gas carrier (irrespective of length).

Relevant definitions

The Navigation Act 2012 (the Act) provides that a vessel is any kind of vessel used in navigation by water, however propelled or moved, including barges, lighters, other floating craft, aircushioned vehicles and other similar craft. 

Accordingly, all barges, whether dumb, or self-propelled, involved in ‘tug & tow’ configurations are considered vessels for the purposes of the coastal pilotage requirements. 

Section 20 of the Act provides that, the length overall of a vessel is 110% of the length as shown on the vessel’s load line certification. If the length overall cannot be determined in this manner, it is taken to be the distance between a vertical line passing through a point that is the foremost part of the bow and a vertical line passing through a point that is the aftermost part of the stern. 

*Please refer to PAN 06/2017 for further information about the definition of a loaded vessel.

Length of tow

The current legislative framework reflects that the length of the tow between the towing vessel and the vessel under tow, however measured, is not taken into consideration when determining the requirement to embark a coastal pilot, or otherwise.


Owners and masters of any vessel required to embark a coastal pilot for an applicable ‘tug & tow’ operation in a coastal pilotage area, who do not embark a pilot as required, are liable to be prosecuted under the Act. 

Significant penalties apply to masters and/or owners of vessels that navigate without a licensed pilot in a compulsory pilotage area. 

Reporting requirements

A vessel engaged in towing or pushing anywhere within the REEFREP area (including all coastal pilotage areas) must report to REEFVTS if: 

  • the length of either the towing vessel or the vessel being towed is 50m or greater, or 
  • the length of tow is 150 metres or greater.

For the purpose of REEFVTS reporting requirements, the length of tow is measured from the stern of the towing vessel to the after end of the towed vessel. The requirements for an applicable vessel engaged in towing or pushing to report to REEFVTS is completely independent of the requirement to embark a coastal pilot, or any other reporting requirement associated with the conduct of coastal pilotage. 

Coastal pilots embarked for ‘tug & tow’ voyages in coastal pilotage areas are to make all necessary reports (e.g. commencing / ceasing duties, incident reports etc.), in accordance with Marine Order 54 (Coastal pilotage), as required. 

Queensland port pilotage requirements

Maritime Safety Queensland (MSQ) regulates the provision of pilotage services in all Queensland ports, however the delivery of pilotage services is provided by the respective port authority. 

‘Tug & tow’ voyages proceeding from a coastal pilotage area to a Queensland port may be subject to compulsory pilotage requirements when proceeding within a Queensland compulsory pilotage area. Coastal pilots should advise masters to consult with the relevant port authority and/or MSQ prior to entry into any Queensland port, as required. 

Keeping AMSA informed 

Pilotage providers in receipt of bookings for extraordinary ‘tug & tow’ operations in coastal pilotage areas are encouraged to advise AMSA accordingly. Depending on the circumstances of the case, AMSA may require additional risk mitigation measures be implemented to ensure navigational safety for the intended voyage.

Last updated: 21 September 2020