Page 30: of Marine News Magazine (October 2018)

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REGULATORY REVIEW

SUBCHAPTER M

CASTS OFF

Credit: U.S. Coast Guard photo by Lt. Anthony Solares

Initial reports show that the towing industry is adjusting well to the new normal on inland rivers. In fact, it is business as usual for most.

By Tom Ewing uly 20, 2018 was a critical date for tow boat operators. ANCHORED IN SAFETY

That was the deadline for all U.S.-? ag towing vessels Sub M’s evolution stemmed from a number of horri? c

J – over 26 feet, or less if used to assist with transport towing accidents almost 20 years ago. These incidents led of oil or hazardous materials – to be in compliance with to Congressional action. The 2004 Marine Transporta-

Subchapter M, the U.S. Coast Guard’s towing vessel safety tion bill added towing vessels as a vessel class subject to regulations. It’s been a long time coming. As a regulatory USCG inspection. Among numerous provisions, the bill program, the CG ? nalized Sub M in July 2016, setting a authorized establishment of a safety management system two-year implementation time-line. “appropriate for the characteristics, methods of operation,

As most towing operators know, Sub M is an expansive and nature of service of towing vessels.” The bill addressed and dynamic program pertaining to vessel safety and safe maximum hours of service and required a demonstra- operations. Central to Sub M is the Coast Guard issued tion project on “Crew Endurance Management Systems.”

Certi? cate of Inspection (COI), the document recognizing Hours-of-service, though, did not make it into Sub M’s and formalizing Sub M compliance and, most critically, ? nal rulemaking. Another new demand was for electronic permitting the vessel to legally operate for ? ve years, when charts for towing vessels.

it must be inspected again. The Certi? cate of Inspection (COI) is the critical, cen-

October 2018

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