REGULATORY REVIEW: Subchapter M
One Year In: Industry SME (Captain) Pat Folan weighs in from the front lines.It has been an interesting year for towing industry. As the new Subchapter M towboat rule rolled out, it didn’t take long to discover that the regulation wasn’t perfect. As stakeholders look ahead to what comes next, it is also helpful to take a look back at what went right, what didn’t, and more importantly – why.The U.S. Coast GuardThe US Coast Guard does not have the manpower to add more than 5,000 vessels to its workload.
Understanding Legal Liability in a Subchapter M Environment
There is more to SubM than just attention to safety. Protect yourself accordingly. In today’s environment, safety management systems for brown water marine operators are standard industry practice, whether they come in the form of the American Waterways Operators (AWO) Responsible Carrier Program (RCP) or the Tanker Safety Management Assessment (TSMA) framework developed by the Oil Companies International Marine Forum (OCIMF) for liquid carriers. However, with the full-fledged implementation of Subchapter M on the horizon…
Towing Vessel Inspection Bureau Acquires Marine Auditing Firm
Towing Vessel Inspection Bureau (TVIB) has acquired Quality Auditing, LC, effective December 31, 2016. According to TVIB, the purchase strengthens its three-fold mission to provide training and continuing education for marine auditors and surveyors, develop audit and survey tools, and become a U.S. Coast Guard Third-Party Organization (TPO) under 46 CFR Subchapter M. Founded in 2009, Quality Auditing, LC is a full-service marine auditing firm specializing in providing third-party vendor audits and AWO Responsible Carrier Program audits, utilizing a network of auditors located throughout the inland waterways. The acquisition enables TVIB to expand its regulatory compliance service offerings for the industry as it prepares to conduct audits and surveys as a TPO.
Lloyd’s Register, MarineCFO Partner to Provide Turnkey SubM Solutions
Industry Innovators Combine to lead US Towing Vessel Compliance. Lloyd’s Register North America, Inc. has formally announced to the United States Coast Guard its intention to assume Subchapter M Third Party Organization duties effective immediately. This message was followed by the signing of an exclusive Subchapter M joint marketing agreement between Lloyd’s Register North America, Inc. and workboat technology provider MarineCFO, who will jointly bring comprehensive solutions for compliance with Subchapter M. A result of the Coast Guard and Maritime Transportation Act of 2004, Subchapter M became effective July 20, 2016. The rulemaking transitions upwards of 5…
Dantin to Lead Baker Lyman's TSMS Program
Thomas Dantin Joins Baker Lyman as Chief Consultant for Towing Safety Management Systems. Baker Lyman has announced the association of chief consultant Thomas Dantin, well-versed in the towing and maritime industry. “Thomas has spent 40 years in the maritime industry and brings his wealth of knowledge to us,” said Corinne Titus, CEO of Baker, Lyman and Co., Inc. Dantin holds a BA from Nichols State University in Thibodaux, LA; a USCG 500 Ton Master of Steam or Motor Vessels on Oceans; is a certified ISM auditor and is experienced at designing Safety Management Systems for the towing industry. He is a commercial pilot for single engine land and sea, multi engine land airplanes, instrument rated and a certified flight instructor.
Insights: Rear Admiral Paul F. Thomas
Rear Admiral Paul Thomas is the Assistant Commandant for Prevention Policy overseeing three Coast Guard directorates: Inspections and Compliance, Marine Transportation Systems, and Commercial Regulations and Standards. The programs include waterways management, navigation and boating safety, ports and facilities, merchant mariner credentialing, vessel documentation, marine casualty investigation, commercial vessel inspections, and port state control. A longtime specialist in Marine Safety…
Baker, Lyman Hires Senior Consultant for TSMS
Baker, Lyman and Co., Inc. hired John Scarborough as senior consultant. He is an authorized agent for Germanischer Lloyd on the Corsair Towing Safety Management Systems (TSMS) Strategic Alliance for Subchapter M compliance software for the domestic towing industry. Scarborough holds a Maritime Law degree from Tulane University in New Orleans, Louisiana and a Bachelor of Arts from Duke University in Durham, North Carolina. He previously sailed with Rene J. Cheramie & Sons in the Gulf of Mexico and aboard large commercial yachts world-wide. www.bakerlyman.com
(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.
