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Safe Harbor Updates

What Is Subchapter M?

Posted: Aug 7, 2018 10:52:00 AM

The towing sector plays an extremely important role in the marine industry, but it does come with its fair share of safety concerns. In 2016 alone, there were 1,231 towing incidents involving employee injuries, oil spills, damaged property, and more. 

In light of such dangers, the U.S. Coast Guard (USCG) set out to help make the towing industry safer for workers, property, and the environment with the introduction of Subchapter M, which outlined new safety regulations. 

Below, we’ll discuss this fairly new set of standards and how it impacts the towing community. 

History of Subchapter M

On July 20, 2016, the U.S. Coast Guard published Subchapter M, which established inspection standards for towing vessels. Most towing vessel operators were required to obtain certificates of compliance under Subchapter M’s new mandates by July 20, 2018. 

Though the new safety framework was published in 2016, discussions around this topic date back to 2003 when a Coast Guard-American Waterways Operators (AWO) Safety Partnership first recommended creating towing vessel safety procedures. For more than 10 years, AWO and the USCG met with various committees to develop requirements and rules for compliance. 

Subchapter M In Brief

Subchapter M outlines towing vessel safety regulations for inspections and standards and options for safety management systems. These regulations are applicable to all U.S.-flag towing vessels that push, pull, or haul alongside. There are some exceptions, though. For instance, assistance towing vessels, workboats operating in work zones, and boats under 26 feet long that are not towing hazardous materials or oil do not need to comply with these regulations. 

Operators are required to obtain or renew a Certificate of Inspection (COI) from the USCG:

  • New vessels with keel laid after July 20th, 2017 are required to comply with all requirements.
  • Existing vessels were required to gain compliance by July 20th, 2018.

How to Prepare for Inspection 

Before undergoing inspection, it’s recommended to do the following: 

  • Develop a Healthy and Safety plan
  • Establish a training manual that aligns with Subchapter M requirements
  • Be ready to demonstrate safety training procedures 
  • Create and follow a record-keeping system 
  • Inspect your fleet
  • Make a worklist of repairs and updates needed 
  • Determine any shortcomings and how you plan to become compliant 

The Inspection

The inspection is designed to be a systematic, independent, and documented examination. 

As outlined by the Government Publishing Office, the inspection will include “the structure, pressure vessels and their appurtenances, piping, main and auxiliary machinery, electrical installations, lifesaving appliances, fire detecting and extinguishing equipment, pilot boarding equipment, and other equipment.” It also includes any necessary FCC documentation, lights, signals, and pollution prevention systems and procedures.

Two Options For Compliance

Subchapter M gives towing vessel operators two options to achieve compliance and obtain a COI:

  1. Operators can get certified through the USCG.
  2. Operators can adopt a Towing Safety Management System (TSMS). This allows USCG-approved Third-Party Organizations (TPOs) to inspect and certify compliance.

If you decide to become certified through the USCG, your fleet and crew are subject to annual inspections. However, if you go the third-party route, you will only undergo inspections once every five years. 

Whichever path you choose, the Coast Guard is responsible for issuing a towing vessel COI and may board a vessel at any time to verify compliance. Owners or managing operators can choose different options for individual vessels within their fleets but must specify on the inspection application which option is being chosen for that particular towing vessel. A COI is valid for five years from the date of issue.

Is Compliance Mandatory?

In a word, yes. To operate, a towing vessel must be in full compliance with Subchapter M with a valid COI issued by the Coast Guard onboard. In some cases, the Coast Guard may issue a temporary COI to a towing vessel, as long as a permanent COI is in progress.

Are your pollution prevention systems and procedures compliant? Learn how Safe Harbor protects vessel owners and operators with comprehensive vessel pollution insurance.

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