SubM: The Coast Guard IS Still an Option
Not all towing vessel companies are choosing Third Party Organizations (TPOs) for their Subchapter M compliance option. One size does not fit all.Under Subchapter M, towing vessel companies may opt to use TPOs to conduct their audits and surveys instead of inspections by the Coast Guard. While many companies are going the TPO route, many are opting for traditional Coast Guard inspections.As a retired Coast Guard marine inspector, I have always advocated the Coast Guard option to our clients.
Subchapter M: Top 5 Moves to Make Now
In 2004 Congress reclassified towing vessels as vessels subject to inspection. Thus began a lengthy process of regulation drafting by the U.S. Coast Guard, with a great deal of input from the towing industry. In 2011, the Notice of Proposed Rule Making was published giving the public its first look at what has become known as Subchapter M. Over 3,000 comments were received by the Coast Guard on the Proposed Rule. After five years of responding to those comments and revamping Subchapter M, on June 20, 2016 the Final Rule was published.
Subchapter M Survey Reports
The advent of the subchapter M towboat rules – even though the bulk of the rules don’t come into effect until July of 2018 – requires a close look at your equipment. How you go about that important task will make all the difference. Towing vessels should be surveyed for Subchapter M regulatory compliance, regardless of the compliance option chosen, so companies can budget and plan for upgrades between now and July of 2018. If a company is being proactive and strategic about Subchapter M, the time to start getting vessels surveyed for regulatory compliance is now.
(Sub) Chapter M Finally Surfaces
For inland operators, Compliance, Safety & Technology make for heavy river traffic as software providers descend on a rapidly approaching, potentially lucrative niche market. Is there a panacea for subchapter M? Pending USCG Subchapter “M” (SubM) regulations will eventually require towing operators to implement safety standards and use safety management systems, or alternatively, allow for an annual Coast Guard inspection regime. The new rules are expected to allow towing vessel organizations to customize their approach to meeting the requirements, while providing oversight using audits, inspections, and reviews of safety data. As many as 5,000 vessels and their operators will eventually feel the impact of the so-called subchapter M rules.
Workboat Regulatory Compliance: Boatracs, MCI, Join Hands
Boatracs announces strategic partnership with Maritime Compliance Internationa (MCI)l to provide Subchapter M compliance solution. The two companies are collaborating in the development of a new electronic forms software product for the workboat market designed specifically for compliance management of the upcoming Coast Guard 46 CFR Subchapter "M" regulation. The new product is based on Boatracs' industry leading electronic forms platform, Boatracs BTForms. BTForms is currently in use on almost 200 vessels to simplify the process of collecting accurate vessel data for dispatch, Health, Safety and the Environment (HSE), maintenance and management.
Safety Management System or a Checklist for Negligence?
Does your company have a safety management system (SMS), a safety program, or internal safety policies? Are there problems with implementation or making sure that all policies are consistently complied with? Are there items in the manual which do not apply to your vessels or operations? Does the manual call for unrealistic work practices? If you answered "yes" to these questions, rest assured you are not alone. Unfortunately, however, your company could also be in danger of severe financial penalties, and/or litigation. In some case, such as a serious accident, individuals, depending upon their position in the company, might even face imprisonment. The latest trend in regulatory schemes is performance based regulations.
A Maritime Lesson to be Learned from Aviation
The aviation industry learned a hard lesson earlier this year regarding regulatory compliance. While the lessons learned from the incident are many, the common theme that should be taken away by the maritime industry is that an owner and/or operator is responsible for compliance regardless of what individual regulatory personnel may say, accept, or even put in writing. For maritime companies without a compliance program, it has become common practice to rely primarily upon the opinions of individual Coast Guard inspectors or commands regarding regulatory compliance issues, despite occasionally receiving inconsistent guidance. What is wrong with this strategy? In the future another inspector may enforce a regulation which wasn't previously enforced.
New Orleans Maritime High School
to worsen in the near future. attracting and grooming potential employees for these lucrative and rewarding careers. idea whose coming is long past due. Orleans Maritime Charter High School. something that must be done, and now is the time. United Way School to Career program, and was the brainchild of Ms. local maritime industry consultant. School of Construction and Architecture. high school in New Orleans. representatives as well as representatives from the U.S. Coast Guard and the U.S. Administration. and pledged their continuing support of the project. some owners have already volunteered their commercial vessels as training platforms for the school. near future in order to solicit more ideas from all interested parties. charter high school.
