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Subchapter M that contains compre- hensive new standards to ensure the safety of all aspects of towing vessel operations, from vessel equipment to human factors. The new 46 CFR Subchapter M would establish stan- dards for vessel operations, mariner health and safety, lifesaving, firefight- ing, machinery and electrical sys- tems, and vessel construction and arrangements.Other features of the proposed reg- ulations include:Requiring towing companies to implement a Towing Safety Management System as recommended by the NTSB. Companies that choose not to implement a TSMS would undergo annual Coast Guard inspec- tions of their towing vessels. Allowing for Coast Guard accept- ance of safety management systemsother than the International Safety Management Code to meet the TSMS requirements. This would allow AWO to review the Responsible Carrier Program against the requirements for a Coast Guard-accepted TSMS, make any changes needed, and submit theRCP to the Coast Guard for acceptance as a TSMS. Using Coast Guard-approved third parties to verify compliance with the new requirements, enabling the Coast Guard to better target its resources on those companies and vessels whose oper- ations warrant closer scrutiny. Exempting from coverage vessels less than 26 feet, unless moving a barge carrying dangerous or hazardous mate- rials; vessels used for assistance towing; work boats operating exclusively within a work site; seagoing towing vessels over 300 GRT; and vessels inspected under MN#9 (1-17):MN 2011 Layouts 9/7/2011 9:44 AM Page 15