If you own a marine company or run a fleet of tugs or other towing vessels, you may need to ensure that your fleet complies with Subchapter M Regulations. Since implementing the regulations, we at Edward Maritime have received frequent questions from our valued clients about it.
This blog post is here to answer some of those questions.
What Exactly is Subchapter M?
U.S. Coast Guard Subchapter M is an up-and-coming set of training and inspection standards for the towing industry.
It was released in 2016 and is based on qualitative risk assessment and risk management standards, expanding upon existing industry safeguards and requiring new training protocols and vessel compliances.
To ensure a seamless transition into Subchapter M for currently operating workboats, the U.S. Coast Guard is collaborating with the American Waterways Operators, or AWO, a national advocate for the tugboat, towboat, and barge industries in the United States.
Who is Affected by Subsection M?
All towing vessels operating within U.S. territorial waters that are subject to Coast Guard inspection must comply with Subchapter M, with the following limited exceptions:
Vessels under 26 feet in length that are not transporting oil or other dangerous goods
Vessels providing towing assistance
Ships used for construction purposes that operate inside a designated work area
Maritime tugboats, if gross register tons are below 300
Because of their federal status, Coast Guard regulations precede those of OSHA and individual states.
Subchapter M governs:
Construction
Design
Operation
Equipment
Repair
Crew qualifications
If your boat is required to comply with Subchapter M, you can get certified in one of two ways:
Coast Guard Inspection: This is the tried-and-true method of having your ship inspected by the United States Coast Guard as part of a Safety Management System.
The Towing Safety Management System: You can get third-party verification that your fleet is in line with Coast Guard standards by using the TSMS.
How to Become Compliant With Subchapter M
First, you must get a Certificate of Inspection (COI) from the US Coast Guard (USCG) or renew an existing one.
Next, you need to prepare for inspection by following this checklist:
Put together a strategy for health and safety.
Develop a training guide that meets the standards of Subchapter M.
Prepare proof of having received safety training
Establish and maintain a reliable method of keeping records
Inspect your fleet
Make a list of things that need fixing or updating.
Find out what you're doing wrong and how you can fix it.
How Edward Maritime Helps You Stay Compliant
Whether something is out of compliance with the codes, or the US Coast Guard has requested that you make the necessary changes, we can assist you in making those modifications.
Overboard valves, alarms, lights, tanks, piping, etc., are just some things we can fix.
When it comes time for your next inspection, we'll take care of all the details with the coast guard to ensure a problem-free process.
We get the coast guard's approval for our work by submitting a detailed repair report and passing a series of tests after we're done.
You can return your boat to work after all the necessary repairs and modifications have been made and approved. If you are in the Gulf Coast area and want to ensure your boat complies with Subchapter M, don’t hesitate to reach out for a free quote!
Edward M.
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