A discussion with some Coast Guard officers at a recent industry meeting convinced me that it was time to rewrite Subchapter H.
There are several regulatory categories covering passenger vessels of various sizes. These regulations lay out requirements for construction, stability, watertight integrity, lifesaving, firefighting and manning. Subchapter H governs passenger vessels of more than 100 gross tons with a capacity of 12 or more passengers.
Subchapter H regulations were adopted in the 1960s and have not changed much since then. Other regulations governing passenger vessels such as Subchapter T have been overhauled. In the case of Subchapter K, new regulations were created in order to keep up with the evolution of the small passenger vessel industry.
Since 1970 when I entered the marine industry, there have been many technological changes, improvements in vessel construction, and numerous equipment innovations. Subchapter H was developed in the age of trans-Atlantic passenger vessels, so it now has very little application to those who operate “H” vessels in coastal or inland service. When Subchapter T became outdated, the Coast Guard reworked the regulations and created Subchapter K to address industry change. The Coast Guard should do the same with Subchapter H. It should focus on the international conventions on construction, training and manning standards and create a new Title 46 subchapter that addresses the domestic operation of passenger vessels over 100 gross tons.
The Coast Guard clearly applies a blue water mentality concerning “H” vessel operations. For domestic “H” boat operators, this means regulatory overkill from construction to manning. In reality, Subchapter K regulations more closely resemble the appropriate standard for domestic passenger vessel operations than Subchapter H does.
I recognize that a complete rewrite of Subchapter H is a huge task for the Coast Guard and industry, but it is a task that is more than 50 years overdue. If we leave the regulation alone and don’t rework it, it will be a disservice to domestic operators of “H” vessels.