- AWO has released the TSMS Option Compliance Guide to help members comply with the TSMS requirements of Subchapter M.
- The Coast Guard Office of Commercial Vessel Compliance has released three policy letters (17-01, 17-02 and 17-03) for companies choosing the TSMS option to document compliance with Subchapter M.
- The Coast Guard’s Towing Vessel National Center of Expertise has posted answers to Subchapter M Frequently Asked Questions on its website.
- The AWO Responsible Carrier Program was accepted as an existing safety management system by the Coast Guard on November 21, 2016.
The U.S. Coast Guard’s final rule to establish an inspection regime for towing vessels at 46 CFR Subchapter M was published in the Federal Register on June 20. Subchapter M will take safety in the towing industry to a new and historic level by setting minimum safety standards for towing vessels, incorporating and building on the safeguards that AWO members have already put in place to ensure that the entire industry achieves the level of safety that is necessary to protect lives, the environment, and property. The rule will be phased in over six years. Subchapter M is the most important rulemaking ever to affect the tugboat and towboat industry. AWO is committed to helping all of its members successfully navigate the transition to towing vessel inspection, and to openly sharing information on Subchapter M throughout the entire towing industry as the rule is implemented.
AWO held webinars to provide an overview of the rule shortly after it was published. AWO also held a series of Subchapter M information sessions featuring the Coast Guard’s Subchapter M Implementation Team at each of its summer regional meetings and in New Orleans.
Subchapter M establishes two paths to compliance for towing vessel operators: either annual Coast Guard inspections or the implementation of a Coast Guard-accepted Towing Safety Management System (TSMS). The TSMS option is not only the best way to promote continuous regulatory compliance and prevent accidents, but also provides vessel operators with maximum operational flexibility under the new requirements. The Coast Guard has confirmed its intent to accept the AWO Responsible Carrier Program as a TSMS based on its assessment that the RCP is substantively equivalent to the ISM Code and achieves the audit frequency required by Subchapter M. AWO submitted the RCP to the Coast Guard for acceptance as an ISM-equivalent TSMS on August 30.
AWO is dedicated to ensuring that Subchapter M is implemented smoothly and effectively so that it achieves its potential to improve safety and environmental stewardship throughout the tugboat, towboat and barge industry without interruption to maritime commerce. To that end, AWO is working with the Coast Guard and the Towing Safety Advisory Committee to ensure industry members have an opportunity to review and make recommendations to refine the agency’s draft implementation policy and guidance, and to establish a forum for ongoing Coast Guard-industry discussion as implementation issues and questions arise.
The publication of Subchapter M is the culmination of over a decade of work by the Coast Guard, with the strong support of AWO and its members. For more information about the development of Subchapter M, please click here.