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M should be aligned with other laws governing inspected vessels. To be sure; at TBS we are lucky: we deal with tow- ing vessels. On the other hand, a Coast Guard inspector might board a towing vessel in the morning, attend a char- ter boat in the afternoon, a tank barge after that and then a ship. If they don’t always get it right, it isn’t hard to see why.

A few months into year number two of SubM, it is clear that the new rule is imperfect. It took the Coast Guard four years after the NPRM came out to publish the