Safe Harbor Updates

What Is Subchapter M?

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

On July 20, 2016, the U.S. Coast Guard (USCG) 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. With that deadline expiring a few weeks past, it’s important for all operators to ensure they are compliant. Here’s what you need to know about Subchapter M:

Subchapter M In Brief

Subchapter M outlines towing vessel safety regulations for inspections, as well as standards and options for safety management systems. These regulations are applicable to all U.S.-flag towing vessels that push, pull, or haul alongside (with some exceptions). 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.

Subchapter M’s goal was to set minimum safety standards in the towing industry that would help protect people, property, and the environment.

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. The USCG conducts all annual towing vessel inspections.
  2. Operators adopt a Towing Safety Management System (TSMS). This allows USCG-approved Third-Party Organizations (TPOs) to inspect and certify compliance.

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 5 years from the date of issue.

Is Compliance Mandatory?

In a word, yes. A towing vessel is required to be in full compliance with Subchapter M in order to operate, 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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