A Section 25 - Tugs 25-1

SECTION 25

TUGS

Page

A. General..................................................................................................................................................................25- 1
B. Hull Structures .......................................................................................................................................................25- 2
C. Towing Gear / Towing Arrangement ......................................................................................................................25- 3
D. Steering Gear / Steering Arrangement ..................................................................................................................25- 8
E. Anchoring/mooring Equipment ..............................................................................................................................25- 8
F. Weather Tight Integrity and Stability Towing Gear ................................................................................................25- 9
G. Escape Routes and Safety Measures....................................................................................................................25-10

A. General 3. Approval Documents, Documentation

1. Scope, Application 3.1 In addition to the documents listed in the rules

mentioned under 1.2 above, the following design
1.1 The following requirements apply to vessels documentation shall be submitted, in triplicate, for
primarily designed for towing and/or pushing operations approval and/or information:
or assisting other vessels or floating objects in
manoeuvring. Combination with other purposes is - General arrangement of the towing gear including
possible and will be noted accordingly in the Class winch(es), if provided
Certificate, see 2.2.
- Design drawings and material specifications of
1.2 Unless specially mentioned in this Section, the towing hook and accessory towing gear, towrope
requirements of Sections 1-22 apply. guide and/or of the towing winch including winch
drives, brakes and fastening elements,
1.3 Special designs not covered by the following
rules will be considered from case to case. - Slip device(s) including hydraulic/pneumatic
systems and electric circuits, and/or “weak link”
1.4 For instructions regarding towing operations in for towrope on winch drum,
general, see the “Guidelines for Ocean Towage”, VI, 11-
1. - Required bollard pull (design value),

2. Classification, Notations - Towrope specification,

2.1 Ships built in accordance with the requirements - In special cases, intended tow configuration(s),
of this Section will have the notation “TUG” affixed to
their character of classification. - For examination of towing gear with towing
winch, the direction of the towrope has to be
2.2 Where towing services are to be combined with indicated on the drawings.
other duties such as offshore supply or ice breaking,
corresponding additional class notations may be 3.2 The reliable function of the towing gear has to be
assigned if the relevant requirements are met. proven during the initial tests on board.
 25-2 Section 25 - Tugs A,B

3.3 If a bollard pull test has to be carried out and will 3.2 For (harbor) tugs frequently engaged in berthing
be certified by TL, it shall correspond to the procedure operations, the bow shall be suitably protected by
given in “Guidelines for Ocean Towage”. The test result fendering and be structurally strengthened.
shall be documented and kept on board together with
the certificate of bollard pull testing and the 3.3 The bulwark shall be arranged with an inward
classification documents. inclination in order to reduce the probability and
frequency of damages.
3.4 TL material certificates will generally be required for
3.4 The bow structure of pusher tugs for sea service
- Towing hook and attached load transmitting will be specially considered.
elements, including slip device,
4. Stern Frame
- Towing winch: Frame, drum shaft(s), couplings,
brakes, gear(s) The cross sectional area of a solid stern frame is to be
20% greater than required according to Section 13,
- Towrope(s), including certification of breaking C.2.1. For fabricated stern frames, the thickness of the
force. propeller post plating is to be increased by 20%
compared to the requirements of Section 13, C.2.2. The
Material certificates according to DIN 50049-3.1B may section modules WZ of the sole piece is to be increased
be accepted for standard items, if the manufacturer is by 20 % compared to the modules determined
recognized by TL. according to Section 13, C.4.

5. Side Structure
B. Hull Structures
5.1 The side structure of areas frequently subjected
1. Scantlings, General to impact loads shall be reinforced by increasing the
section modules of side frames by 20%. Besides,
For the determination of hull structure scantlings the fendering may be necessary to reduce indenting
draught T is not to be taken less than 0,85 H. damages of the shell plating.

2. Deck Structure 5.2 A continuous and suitable strong fender shall be

arranged along the upper deck.
2.1 On tugs for ocean towage, the deck, particularly
in the forward region, shall be suitably protected or 5.3 For ice strengthening see 8.
strengthened against sea impact.
6. Engine Room Casing, Superstructures and
2.2 Depending on the towrope arrangements, the Deckhouses
deck in the aft region may have to be strengthened
(beams, plate thickness), if considerable chafing and/or 6.1 The plate thickness of the casing walls and
impact is to be expected. See also C.1.5. casing tops is not to be less than 5 mm. The thickness
of the coamings is not to be less than 6 mm. The
3. Fore Body, Bow Structure coamings shall extend to the lower edges of the beams.

3.1 On tugs for ocean towage, strengthening in way 6.2 The stiffeners of the casing are to be connected
of the fore body (stringers, tripping brackets etc.) Shall to the beams of the casing top and are to extend to the
generally conform to the indications given in Section 9. lower edge of the coamings.
The stringers shall be effectively connected to the
collision bulkhead. Depending on the type of service 6.3 Regarding height of casing and closing
expected, additional strengthening may be required. arrangements as well as exits see also F.1.1.
 B,C Section 25 - Tugs 25-3

6.4 The following requirements have to be observed 1.2 With direct-pull (hook-towrope), the towing hook
for superstructures and deckhouses of tugs assigned for and its radial gear are to be designed such as to permit
the restricted services range K and M or for unlimited adjusting to any foreseeable towrope direction, see 3.5.
range of service:

1.3 The attachment point of the towrope shall be

- The plate thickness of the external boundaries of
arranged closely behind the centre of buoyancy.
superstructures and deckhouses is to be
increased by 1 mm. above the thickness as
1.4 On tugs equipped with a towing winch, the
required in Section 16, C.3.2.
arrangement of the equipment shall be such that the
towrope is led to the winch drum in a controlled manner
- The section modules of stiffeners is to be
increased by 50% above the values as required under all foreseeable conditions (directions of the

in Section 16, C.3.1. towrope). Means shall be provided to spool the towrope
effectively on the drum, depending on the winch size
7. Foundations of Towing Gear and towing gear configuration.

7.1 The substructure of the towing hook attachment 1.5 Towrope protection sleeves or other adequate
and the foundations of the towing winch, and of any means shall be provided to prevent the directly pulled
guiding elements such as towing posts or fairleads, towrope from being damaged by chafing/abrasion.
where provided, shall be thoroughly connected to the
ship’s structure, considering all possible directions of
2. Definition of Loads
the towrope, see C.3.5.

2.1 The design force T corresponds to the towrope

7.2 The stresses in the foundations and fastening
pull (or the bollard pull, if the towrope pull is not defined)
elements shall not exceed the permissible streses
stipulated by the owner. The design force may be
shown in Table 25.2, assuming a load equal to the test
verified by a bollard pull test, see A.3.3 and “Guidelines
load of the towing book in case of hook arrangements,
for Ocean Towage”.
and a load of the winch holding capacity in case of
towing winches, see also C.3.5 and C.5.3.
2.2 The test force PL is used for dimensioning as
well as for testing the towing hook and connected
8. Ice Strengthening
elements. The test force is related to the design force as
shown in Table 25.1.
8.1 Ice strengthening, where necessary according to
the intended service, shall be provided according to the
Table 25.1
requirements of Section 15.

Design force Test force

8.2 Tugs with the notation ICE BREAKER must be
T [kN] PL [kN]
specially considered.
up to 500 2·T

500 ÷ 1500 T + 500

C. Towing Gear/Towing Arrangement
above 1500 1,33 · T

1. General Design Requirements

1.1 The towing gear shall be arranged in such a way

2.3 The minimum breaking force of the towrope is
as to minimize the danger of capsizing; the towing
based on the design force, see 4.3.
hook/working point of the towing force is to be placed as
low as practicable, see also F.
 25-4 Section 25 - Tugs
2.4 The winch holding capacity shall be based on the
minimum breaking force, see 5.3, the rated winch force
is the hauling capacity of the winch drive when winding
up the towrope, see 6.1.3.3.
2.5 For forces at the towing hook foundation see 3.5.4.
3. Towing Hook and Slip Device
3.1 The towing hook shall be fitted with an adequate
device guaranteeing slipping (i.e., quick release) of the
towrope in case of an emergency. Slipping shall be
possible from the bridge as well as from at least one
other place in the vicinity of the hook itself, from where
in both cases the hook can be easily seen.
3.2 The towing hook has to be equipment with a
mechanical, hydraulic or pneumatic slip device. The slip
device shall be designed such as to guarantee that
unintentional slipping is avoided.
3.3 A mechanical slip device shall be designed such
that the required release force under test force PL does
not exceed neither 150 N at the towing hook nor 250 N
when activating the device on the bridge. In case of a
mechanical slip device, the releasing rope shall be
guided adequately over sheaves. If necessary, slipping
should be possible by downward pulling, using the
whole body weight.
3.4 Where a pneumatic or hydraulic slip device is
used, a mechanical slip device has to be provided
additionally.
3.5 Dimensioning of towing hook and towing gear
3.5.1 The dimensioning of the towing gear is based on
the test force PL, see 2.2.
3.5.2 The towing hook, the towing hook foundation, the
corresponding substructures and the slip device are to
be designed for the following directions of the towrope:
- For a test force PL up to 500 kN:
- in the horizontal plane, directions from abeam
over astern to abeam
C
- in the vertical plane, from horizontal to 60
degr. upwards
- For a test force PL of more than 500 kN:
- in the horizontal plane, as above
- in the vertical plane, from horizontal to 45
degr. upwards
3.5.3 Assuming the test force PL acting in any of the
directions described in 3.5.2, the permissible stresses in
the towing equipment elements defined above shall not
exceed the values shown in Table 25.2.
3.5.4 For the towing hook foundation it has to be
additionally proven that the permissible stresses given
in Table 25.2 are not exceeded assuming a load equal
to the minimum breaking force Fmin of the towrope.
4. Towropes
4.1 Towrope materials shall correspond to TL Rules
for Materials -Section 11. All wire ropes should have as
far as possible the same lay.
4.2 The length of the towrope shall be chosen according
to the tow formation (masses of tug and towed object),
the water depth and the nautical conditions. Regulations
of flag state authorities have to be observed. For length
of towrope for bollard pull test, see “Guidelines for
Ocean Towage”
4.3 The required minimum breaking force Fmin of the
towrope is to be calculated on the basis of the design
force T and a utility factor K, as follows:
Fmin = K · T
where;
K = 2,5 for T ≤ 200 kN and
K = 2,0 for T ≥ 100 kN
For T between 200 and 1000 kN, K may be interpolated
linearly.
 C Section 25 - Tugs 25-5

Table 25.2 Permissible stresses

Type of stress Permissible stress

Axial and bending tension and axial and bending compression with box
σ = 0,83 · ReH
type girders and tubes

Axial and bending compression with girders of open cross sections or with
σ = 0,72 · ReH
girders consisting of several members

Shear τ = 0,48 · ReH

Equivalent stress σeq = 0,85 · ReH

ReH= Yield strength or 0,2% - proof stress

4.4 For ocean towages, at least one spare towrope with
attachment shall be available on board.
4.5 The required minimum breaking force Fmin of the
tricing rope is to be calculated on the basis of the
holding capacity of the tricing winch and a utility factor
K=2,5.
5.1.4 Operating levers shall, when released, return into
the stop position automatically. They shall be capable of
being secured in the stop position.
5.1.5 It is recommended that, on vessels for ocean
towage, the winch is fitted with equipment for measuring
the pulling force in the towrope.

5. Towing Winches
5.1 Arrangement and control
5.1.1 The towing winch, including towrope guiding
equipment, has to be arranged such as to guarantee
safe guiding of the towrope in all directions according to
3.5.2.
5.1.2 The winch must be capable of being safety
operated from all control stands. Apart from the control
stand on the bridge, at least additional control stand has
to be provided on deck. From each control stand the
winch drum shall be freely visible; where this is not
ensured, the winch shall be provided with a self-
rendering device.
5.1.6 If, during normal operating conditions, the power
for the towing winch is supplied by a main engine shaft
generator, another generator shall be available to
provide power for the towing winch in case of main
engine or shaft generator failure.
5.2 Winch drum
5.2.1 The towrope shall be fastened on the winch drum
by a breaking link.
5.2.2 The winch drum shall be capable of being
declutched from the drive.
5.2.3 The diameter of the winch drum is to be not less
than 14 times the towrope diameter.

5.1.3 Each control stand has to be equipped with 5.2.4 The length of the winch drum is to be such that at
suitable operating and control elements. The least 50 m. of the towrope can be wound up in the first
arrangement and the working direction of the operating layer.
elements have to be analogous to the direction of
motion of the towrope.
 25-6 Section 25 - Tugs
5.2.5 To ensure security of the rope and fastening, at
least 3 dead turns must remain on the drum.
5.2.6 At the ends, drums must have disc sheaves
whose outer edges must surmount the top layer of the
rope at least by 2,5 rope diameters, if no other means is
provided to prevent the rope from slipping off the drum.
5.2.7 If a multi-drum winch is used, then each winch
drum shall be capable of independent operation.
5.2.8 Each towing winch drum shall have sufficient
capacity to stow the length of the provided towrope.
5.3 Holding capacity/dimensioning
5.3.1 The holding capacity of the towing winch
(towrope in the first layer) shall correspond to 80% of
the minimum breaking load Fmin of the towrope.
5.3.2 When dimensioning the towing winch
components, which - with the brake engaged- are
exposed to the pull of the towage (rope drum, drum
shaft brakes, foundation frame and its fastening to the
deck), a design tractive force equal to the holding
capacity is to be assumed. When calculating the drum
shaft the dynamic stopping forces of the brakes have to
be considered. The drum brake shall not give way under
this load.
5.4 Brakes
5.4.1 If the drum brakes are power-operated, manual
operation of the brake shall be provided additionally.
5.4.2 Drum brakes shall be capable of being quickly
released from the control stand on the bridge, as well as
from any other control stand. The quick release shall be
possible under all working conditions, including failure of
the power drive.
5.4.3 The operating levers for the brakes are to be
secured against unintentional operation.
5.4.4 Following operation of the quick release device,
normal operation of the brakes must be restore
immediately.
C
5.4.5 Following operation of the quick release device,
the winch driving motor must not start again
automatically.
5.4.6 Towing winch brakes shall be capable of
preventing the towrope from paying out when the vessel
is towing at the design force T and shall not be released
automatically in case of power failure.
5.5 Tricing winches
5.5.1 Control stands for the tricing winches have to be
located at safe distance off the sweep area of the
towing gear. Apart from the control stands on deck, at
least one other control stand shall be available on the
bridge,
5.5.2 Tricing winches have to be suitably dimensioned
depending on Fmin of the tricing rope. For operation of
the tricing winch, perfect transmission of orders has to
be safeguarded. For tricing ropes, see 4.5
6. Testing
6.1 Workshop testing
6.1.1 Towing hook and slip device
6.1.1.1 Towing hooks with a mechanical slip device, the
movable towing arm and other load transmitting
elements have to be subjected to a test force PL with
the aid of an approved testing facility. In connection with
this test, the slip device shall be tested likewise; the
release force has to be measured and shall not exceed
150 N, see 3.3.
6.1.1.2 When towing hooks are provided with a
pneumatic slip device, both the pneumatic and the
mechanical slip device required by 3.4 have to be tested
according to 6.1.1.1.
6.1.1.3 Also towing hooks with a hydraulic slip
device have to be tested according to 6.1.1.1, but the
slip device itself need not be subjected to the test load.
If a cylinder tested and approved by TL is employed as
a loaded gear component, during the load test the
cylinder may be replaced by a load transmitting member
not pertaining to the gear, the operability of the gear
 C Section 25 - Tugs
being restored subsequently. The operability of the slip
device has to be proved with the towrope loosely resting
on the hook.
6.1.2 Certification and stamping of towing hook
Following each satisfactory testing at manufacturer’s, a
Certificate will be issued by the attending surveyor and
shall be handed on board, together with the towing
hook.
6.1.3 Towing winches
6.1.3.1 The winch power unit has to be subjected to a
test bed trial at the manufacturer’s. A works test
certificate has to be presented on the occasion of the
final inspection of the winch, see 6.2.4.
6.1.3.2 Components exposed to pressure are to be
pressure-tested to a test pressure PD of
PD = 1,5 · p
where;
p = Admissible working pressure [b]
= Opening pressure of the safety valves
However, with working pressure exceeding 200 [b], the
test pressure need not be higher than p+100 [b].
Tightness tests are to be carried out at the relevant
components.
6.1.3.3 Upon completion, towing winches have to be
subjected to a final inspection and an operational test to
the rated load. The hauling speed has to be determined
during an endurance test under the rated tractive force.
During these trials, in particular the braking and safety
equipment shall be tested and adjusted. The brake has
to be tested to a test load equal to the rated holding
capacity, but at least equal to the bollard pull.
If manufacturers do not have at their disposal the
equipment required, a test confirming the design winch
capacity, and including adjustment of the overload
protection device, may be carried out after installation
25-7
on board, see 6.2.5. In that case only the operational
trials without applying the prescribed loads will be
carried out at the manufacturers.
6.1.4 Accessory towing gear components, towrope
6.1.4.1 Accessories subjected to towing loads, where
not already covered by 6.1.1.1, shall generally be tested
to test force PL at the manufacturer.
6.1.4.2 For all accessories and for the towrope, test
certificates have to be submitted.
6.1.4.3 TL reserve the right of stipulating an endurance
test to be performed at towing gear components, where
considered necessary for assessment of their
operability.
6.2 Initial testing of towing gear on board and
bollard pull test
6.2.1 The installed towing gear has to be tested on the
tug using the bollard pull test to simulate the towrope
pull.
6.2.2 Bollard pull test
In general a bollard pull test will be carried out before
entering into service of the vessel. The test can be
witnessed and certified by TL, see “Guidelines for
Ocean Towage”.
6.2.3 For all towing hooks (independent of the
magnitude of the test force PL), the slip device has to
be tested with a towrope direction of 60 degrees
towards above against the horizontal line, under the
towrope pull T.
6.2.4 The surveyor certifies the initial board test by an
entry into the Test Certificate for Towing Hooks.
6.2.5 Board test of towing winches
After installation on board, the safe operation of the
winch(es) from all control stands has to be checked; it
has to be proved that in both cases, with the drum
braked and during hauling and releasing, the respective
quick-release mechanism for the drum operates well.
These checks may be combined with the Bollard Pull
 25-8 Section 25 - Tugs C,D,E

Test, see 6.2.2. D. Steering Gear/ Steering Arrangement

The towing winch has to be subjected to a trial during 1. Steering Stability

the bollard pull test to a test load corresponding to the
holding power of the winch.
6.3 Recurrent tests of towing gear
The following tests will be applied to all tugs classed by
TL unless otherwise required by the Administration.
The Surveyor certifies the satisfactory recurrent test.
6.3.1 Towing hooks
6.3.1.1 The functional safety of towing hook and slip
device shall be checked by the ship’s master at least
once a month.
6.3.1.2 Following initial testing on board, towing hooks
with mechanical and/or pneumatic slip devices have to
be removed every 2,5 years, thoroughly examined and
exposed to test force PL on a recognized testing facility.
Upon reinstallation of the hook on the tug, the slip
device has to be subjected to an operational trial by
releasing the hook without load. The release forces at
the hook and at the bridge have to be measured.
For avoiding dismounting of these towing hooks, the
test force PL can also be produced by fastening in front
of the first tug towed to the bollard, the hook of which is
intended to be tested, another tug with a design force T
which is sufficient to jointly reach the required test force
PL according to Table 25.1. Slipping has to be effected
whilst both tugs are pulling with full test force.
6.3.1.3 Following initial testing on board, towing hooks
with hydraulic slip device are to be subjected to a
functional test on board every 2,5 years. They are ready
for operation with the towrope loosely resting on the
hook. The release forces required at the hook and at the
bridge have to be measured. Additionally all
components are to be thoroughly examined. Finally the
towing hook has to be pulled against a bollard.
6.3.1.4 Particular attention has to be paid to the proper
functioning of all gear components.
Steering stability, i.e. stable course maintaining
capability of the tug, shall be ensured under all normally
occurring towing conditions. Rudder size and rudder
force shall be suitable in relation to the envisaged
towing conditions and speed.
2. Rudder Movement
Regarding the time to put the rudder from one extreme
position to the other, the requirements of TL Machinery
Rules, Section 14, A. shall be observed for tugs
exceeding 500 gross tons. Special rudder arrangements
may be considered in the particular case, see also 4.
3. Tugs Operating as Pusher Units
For tugs operating as pusher units, the steering gear is
to be designed so as to guarantee satisfying steering
characteristics in both cases, tug alone and tug with
pushed object.
4. Special Steering Arrangements
Steering units and arrangements not explicitly covered
by the Rules mentioned above, and combinations of
such units with conventional rudders, will be considered
from case to case.
E. Anchoring/ Mooring Equipment
1. Equipment numeral
The equipment with anchors and chains as well as the
recommended towrope of tugs for unrestricted service is
to be determined according to Section 18, B. However,
for the determination of the equipment numeral the term
2 · h · B may be substituted by the term
2 (a · B + Σhi · bi)
where ;
bi is the breadth of the superstructure tier “i”,
considering only tiers with a breadth greater than B/4.
 E,F Section 25 - Tugs
2. General Requirements
2.1 The equipment of tugs for restricted range of
service is to be determined as for vessels in the K(20)
or K(50) (Coastal Service) range, see Section 18, A.3.
The equipment for tugs in L (Harbour Service) may be
reduced according to TL’s approval.
2.2 For tugs engaged only in berthing operations,
one anchor is sufficient, if a spare anchor is readily
available on land.
2.3 The stream anchor specified in Section 18,
Table 18.2 is not required for tugs.
3. Tugs Operating as Pusher Units
The anchoring equipment for tugs operating as pusher
units will be considered according to the particular
service. Normally, the equipment is intended to be used
for anchoring the tug alone, the pushed unit being
provided with its own anchoring equipment.
F. Weather Tight Integrity and Stability
1. Weather Deck Openings
1.1 Openings (skylights) above the machinery space
shall be arranged with coamings not less than 900 mm.
high, measured from the upper deck. Where the height
of the coaming is less than 1,8 m. the casing covers are
to be of specially strong construction, see also G.1.
1.2 The head openings of ventilators and air pipes
are to be arranged as high as possible above the deck.
1.3 For companion ways to spaces below deck to be
used while at sea, sills with a height not less than 600
mm. shall be provided. Watertight steel doors are to be
provided which can be opened/closed from either side.
1.4 Deck openings shall be avoided in the sweep
area of the towing gear, or else be suitably protected.
2. Stability
2.1 The intact stability must comply with the following
requirements:
25-9
- The intact stability requirement of IMO Res.
A.749(18), Chapter 3.1, as amended by MSC
Res. 75(69)
- Alternatively, if applicable, the intact stability
requirement of IMO Res. A.749(18), Chapter 4.5,
as amended by MSC Res. 75(69)
2.2 Additionally, the intact stability must comply
with one of the following requirements:
- The residual area between a righting lever
curve and a heeling lever curve developed
from 70 % of the maximum bollard pull force
acting in 90° to the ship-length direction should
not be less than 0,09 mrad. The area has to be
determined between the first interception of the
two curves and the second interception or the
angle of down flooding whichever is less.
- Alternatively, the area under a righting lever
curve should not be less than 1,4 times the
area under a heeling lever curve developed
from 70 % of the maximum bollard pull force
acting in 90° to ship-length direction. The areas
to be determined between 0° and the 2nd
interception or the angle of down flooding
whichever is less.
2.3 The heeling lever curve should be derived by
using the following formula:
0,071 ⋅ T ⋅ z h ⋅ cosθ
bh = [m]
D
bh = Heeling arm [m]
T = Maximum bollard pull [kN]
zh = Vertical distance [m] between the working point
of the towrope and the centre of buoyancy
D = Loading condition displacement [t]
θ = Heeling angle [°]
 25-10 Section 25 - Tugs
G. Escape Routes and Safety Measures
1. Engine Room Exit
In the engine room an emergency exit is to be provided
on or near the centerline of the vessel, which can be
used at any inclination of the ship. The cover shall be
weather tight and is to be capable of being opened
easily from outside and inside. The axis of the cover is
to run in athwart ship direction.
2. Companionways
Companionways to spaces below deck see F.1.3.
3. Rudder Compartment
Where, for larger ocean going tugs, an emergency exit
is provided from the rudder compartment to the upper
deck, the arrangement, sill height and further details
shall be designed according to the requirements of F.1,
particularly F.1.4.
G
4. Access to Bridge
Safe access to the bridge is to be ensured for all
anticipated operating and heeling conditions, also in
heavy weather during ocean towage.
5. Safe Handling of Towing Gear
See requirements under C.1, C.3 and C.5.
6. Fire Safety
6.1 Structural fire protection measures shall be as
outlined in Section 22, as applicable according to the
size of the vessel. The fire fighting equipment shall
conform to TL Machinery Rules Section 12, as
applicable.
6.2 Additional or deviating regulations of the
competent Administration may have to be observed.