Subchapter M

What's New
  • AWO held a webinar on the Certificate of Inspection application and issuance process under Subchapter M on May 31 featuring an expert panel including personnel from the Coast Guard Office of Commercial Vessel Compliance and AWO members who have recently obtained their first COIs. To listen to the webinar, click here.
  • AWO has released the TSMS Option Compliance Guide to help members implementing the RCP comply with the TSMS requirements of Subchapter M.
  • The Coast Guard Office of Commercial Vessel Compliance has released policy letters (17-01, 17-02, 17-03, 17-04, 17-10, 18-01) for companies choosing the TSMS option to facilitate their 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, 2016, and existing towing vessels are required to be in compliance by July 20 of this year. 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 issuance of Certificates of Inspection for existing towing vessels will be phased in over four 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.
 
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 accepted the AWO Responsible Carrier Program as an existing safety management system that meets the TSMS requirements of Subchapter M.
 
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 facilitate ongoing Coast Guard-industry discussion ro resolve implementation issues and answer questions.
 
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.  
 
For more information please contact Caitlyn Stewart at (703) 841-9300, extension 262 or cstewart@americanwaterways.com.