Subchapter M has caused a lot of buzz in the towing industry in the past few years yet many mariners don’t know much about it.
Subchapter M originated with the 2004 Coast Guard Act which mandated regulation in the towing industry. The regulation of the towing industry was heavily supported by the American Water Operators (AWO). Since the law was passed they have been very involved in devising the requirements for compliance. The following vessels are being impacted by the implementation of Subchapter M:
Vessels <26 feet unless moving a barge carrying oil or hazmat assistance
Workboats operating within worksites
Seagoing tugs >300 GRT
Inspected vessels that perform occasional towing
Companies are being given close to 20 years to become compliant with the regulations. The new changes are not earth-shattering. For example, a major part of Subchapter M is the requirement that towing vessels complete a USCG inspection and obtain a Certificate of Inspection (COI). These inspections vary little from inspections conducted on larger tonnage vessels and help create a culture of standardization across the US merchant fleet.
The other major part of Subchapter M is the requirement of having an adequate Safety Management System in place. Having a copy of the SMS on board as well as crew understanding of the SMS is also criteria for the USCG inspection, so without it, no COI will be issued.
While many companies have been quick to come into compliance with Subchapter M, there has been a lot of angst among the towing industry. Tug and tow boat workers speculate that the new requirements will result in raising the manning requirements on towing vessels. ATB’s are being built larger and more sophisticated than ever so it is reasonable to believe that the Coast Guard could want crew sizes on these larger towing vessels to be similar to that of handysize vessels. Until any new manning requirements are put into place by the Coast Guard, all we can really do is wait and see how Subchapter M will effect the job market.