Subchapter M: 22 months left, so don’t delay

There are 22 months left to get Subchapter M fully implemented on your boats. This can be overwhelming. The best way to deal with it is to break up the requirements into smaller tasks, chipping away at them in a strategic order over the next 22 months.

But first you must ask yourself if you are fully committed to compliance. According to our model for maritime compliance, this involves three things: awareness, acceptance, and understanding. Let’s just assume everyone is aware of Subchapter M. Moving on, acceptance next. Simply put, if you accept it you have told yourself, “Okay, this is it, it’s here now. Let’s find out what we have to do and get it done.” It’s kind of the opposite of the EPA’s Vessel General Permit where, understandably, many operators may not have accepted the fact that they are required to manage the rain running off of their decks.

This brings us to the last part of commitment, understanding. You can’t fully understand Subchapter M if you are waiting on others to tell you what it says or what you have to do. All prudent operators must ensure that all responsible employees read the final rule, including the preamble. Responsible employees include the towing vessel masters. The Coast Guard has also published the first bit of Subchapter M guidance in the form of frequently asked questions. These should also be read carefully and objectively. To maintain full commitment to compliance, operators should stay abreast of all guidance from the Coast Guard in the months ahead.

Once you have a complete understanding of Subchapter M, you can make the tough decisions that are best for your company and start chipping away at your strategic task list. Don’t procrastinate.

About the author

Kevin Gilheany

Kevin Gilheany is a marine consultant and owner of Maritime Compliance International in New Orleans. He works with companies to help increase profitability through improved compliance and management systems. Gilheany is a retired U.S. Coast Guard marine inspector, certified marine surveyor and auditor, and crew endurance management expert. He has also provided contract training to the U.S. Coast Guard, was an adjunct instructor of maritime security at Tulane University’s Homeland Security Studies Program, and has contributed to marine industry publications. He can be reached at kgilheany@marcomint.com or www.maritimecomplianceinternational.com.

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