There are now just 18 months left to get towing vessels into compliance with Subchapter M.
According to Maritime Compliance International’s Subchapter M strategic plan, all captains should have read the new rule by now, including managers. They all should also have read the Subchapter M Preamble in the Federal Register. Additionally, companies should have already decided which compliance option they will go with.
Do you need help choosing a compliance option? We developed a compliance option decision tool to help. It takes into account seven important factors for towing vessel companies to consider, free of spin and sales pitches.
Jan. 1, 2018, is the date by which companies must have taken the first official step in the compliance process: getting a comprehensive Subchapter M survey for each vessel.
This survey should be based upon assumptions about a vessel’s operation: route, number of crew, number of persons in addition to the crew, warm or cold water operation, excepted vessel or not, and the compliance option. Once the company has a comprehensive regulatory compliance survey report, they can budget and plan out the timing of upgrades throughout the year.
By April 1, 2018, operators must establish how the requirements for written records, operational policies and procedures, and training will be met. Some of our clients have stayed ahead of the game by implementing our comprehensive Towing Vessel Record/Compliance Management System, which includes all required policies and procedures. With a good survey, our comprehensive system and some training, these clients are all set for Subchapter M.
The items discussed above apply to all towing vessels, regardless of the compliance option. For those companies choosing the third-party option, they have a number of other considerations. More on that next time.