Subchapter M and a Coast Guard option success story

We recently received a call from a tug company looking to get ready for Subchapter M, just three months before the July inspection deadline. (Owners and operators are responsible for ensuring that 25% of their fleet has received a COI before July 22, 2019.)

They asked for a Towing Safety Management System (TSMS), since they were sure it was mandatory from everything they had heard. We could have sold them a good TSMS, but I told them the story of American Tugs Inc. in Puerto Rico.

We first met the Rivera family, owners of American Tugs, at the International WorkBoat Show several years ago. This family operation, which operates 11 tugs in Puerto Rico, became a one of our best clients. In the years leading up to Subchapter M we partnered with them to get their boats and crews ready. When Subchapter M arrived they embraced the change and started to implement our Towing Vessel Record/Compliance Management System well ahead of time. They also followed our regulatory compliance surveys and got their boats up to Subchapter M standards.

When the time came to see if all their hard work had paid off, they called the Coast Guard and scheduled their inspections. Here’s what an inspector from Coast Guard Sector San Juan said to the company after their first COI inspection for the 3,600-hp tug Marilin R.: “… Inspections such as the Marilin R. are what makes my job very satisfying. The inspection team was more than pleased with the condition of the vessel and the knowledge of the crew. I could tell that the crew and your employees put a lot of time and effort to get the vessel ready for USCG inspection standards.”

American Tugs has, reportedly, received the first two Subchapter M COIs in Sector San Juan. They did it not with a third party organization (TPO) and a TSMS, but by simply getting into compliance with Subchapter M.

Don’t make this more difficult than it has to be.

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 or

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