What is it?

Subchapter M started as a brief explanation in the Coast Guard Act of 2004, which ordered the regulation of towing vessels. From that point, the Coast Guard started to add standards for the assessment of those vessels. Subchapter M isn’t only an arrangement of standards adjusted from blue-water rules and connected to the towing business. Significant litigation has gone into giving an extensive inspection process, specially crafted for the towing industry.

There are two important aspects to Subchapter M that operators should pay attention to in terms of complying. The main part has to do with seaworthiness and meeting certain standards. The second segment has to do with how operators handle safety management. Subchapter M categorizes towing organizations into one of a few unique choices for characterizing their safety standards, and after that, examining their execution against those principles.

Why does it matter?

Although the actual rules haven’t been published yet, Subchapter M matters since vessels that don’t agree when it becomes effective, won’t be issued Certificates of Inspection (COI) and won’t be permitted to work. It’s not as simple as taking a fine and addressing later, without a COI, the vessel will not be allowed to operate. For those who are not prepared, this could be detrimental to business, and can actually stop all operations if the vessels do not have a COI.

When is it coming?

Even though it began as a simple litigation in 2004, the Department of Homeland Security’s (DHS) Semi Regulatory Agenda set the final rule date for 2015. The delays have lead some people to think it’ll never come around, however, the litigation is coming to an end and could be just around the corner. Operators do not want to be caught flat footed when it does come into effect.

What happens if my vessels don’t comply?

A vessel that complies, receives a Certificate of Inspection (COI). If a vessel does not have a COI, it cannot operate. The coast guard can pull your vessel over and moor it.

Who manages inspection?

There are two regulatory bodies that handle inspection and auditing for Subchapter M. The first one is the Coast Guard. The other is classification societies. There is a difference when choosing who inspects your vessels. With the Coast Guard, any modification of your vessel after you’ve already been inspected will require another inspection in order to keep on working. The Coast guard has to approve the modification in other words. When using classification societies, you’re allowed to make modification as long as they comply with the guidelines of your Towing Safety Management System (TSMS). This allows your vessel to continue to operate, but it can still be audited in order to check if the changes follow your TSMS.

What should you do?

Download our brochure with how to prepare for subchapter M!

Subchapter M Brochure


 


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