Page 31: of Marine News Magazine (February 2020)

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SUBCHAPTER M

Caitlyn Stewart

Senior Director – Regulatory Affairs,

The American Waterways Operators

David Orme

Chief Operating Of? cer with

Carlisle & Bray Enterprises requirements. A second concerned a M regs. He questions, for example, But keep watch: revised inspection

USCG Policy Letter regarding wheth- whether the same requirements should fees are on the horizon. We’ll update.

er certain inspection decals would re- apply for brown water operations ver- main valid, thereby satisfying a COI sus blue water. But he expects Sub M inspection requirement. Third, initial to evolve “as experience and common

Tom Ewing is a freelance uncertainties about returning a vessel sense are evaluated and applied.” writer specializing in energy to service after an accident. Sub M progresses in waters that and environmental issues.

For Canal Barge, McCarthy said aren’t yet placid, but surely navigable. “these issues have mostly been resolved due to continued open dialogue be- tween industry and the Coast Guard.”

David Orme is Chief Operating Of- ? cer with Carlisle & Bray Enterprises, a full services marine company with 23 vessels based in Covington, Ky., across from Cincinnati on the Ohio

River. Orme said Sub M startup has proceeded smoothly. The company has been able to align the inspection process with C&B’s operational needs, and half the company’s vessels are in compliance with Sub M. C&B works with the CG for COI inspections.

Orme commented that Sub M’s annual inspection fees are rather ex- cessive given the “substantial costs already associated with maintaining equipment consistent with require- ments and costs associated with down- time/loss of production.” He suggests an inspection every ? ve years unless a company has a history of violations.

Orme suggests a re-look at other Sub 31 www.marinelink.com MN