Subchapter M

In July 2016, the U.S. Coast Guard’s Subchapter M laid out new safety and environmental standards for towing vessels. Most towing vessel operators will need to be certified as compliant under the new requirements of Subchapter M.

 

About Subchapter M

Subchapter M applies to all U.S.-flag towing vessels, except for:

  • towing vessels less than 26 feet, unless moving a barge carrying oil or hazardous materials
  • assistance towing vessels
  • workboats operating within a worksite
  • seagoing tugboats greater than 300 GR
  • some other inspected vessels that perform occasional towing

It supersedes the jurisdiction of the Occupational Safety and Health Administration (OHSA) and any state regulations on vessel design, construction, alteration, repair, maintenance, operation, equipping, personnel qualifications and manning.

It will be phased in over a six-year period for existing vessels. Although the law took effect in July 2016, existing vessels will not be required to meet most of its requirements until July 20, 2018.

 

Subchapter M provides two compliance options:

  1. Coast Guard inspection: the traditional inspection model under which all inspections are conducted by the Coast Guard; OR
  2. The Towing Safety Management System (TSMS): this option allows for Coast Guard-approved Third-Party Organizations (TPOs) to inspect and certify compliance. TVIB will operate under this provision of the law.

 

TVIB and Subchapter M

Ahead of the implementation of Subchapter M, the Coast Guard is currently reviewing Third-Party Organization applications, including ours. As a TPO under Subchapter M, we will be able to:

  • Train auditors and surveyors on the TVIB Subchapter M audit/survey process.
  • Train auditors and surveyors on the requirements of Subchapter M.
  • Provide and maintain an audit tool (checklist) for use by all auditors assessing compliance with requirements of Subchapter M.
  • Accredit auditors/surveyors to perform Subchapter M audits/surveys.
  • Verify auditor/surveyor qualifications as per Subchapter M part 139.
  • Track the apprenticeship process for new auditors/surveyors.
  • Provide a credential and/or certificate to apprentice and/or accredited auditors/surveyors.
  • Maintain a list of apprentice and fully accredited auditors/surveyors on the website.
  • Provide continuing education or refresher training on Subchapter M as changes occur and as updates are made to the automated audit tools.