The expected release date for the Subchapter M towing vessel inspection regulations Final Rule is now March 2015. While some may find the moving goalpost frustrating, the delay buys time for preparation.
Anyone who may be affected by this regulation should read over the Notice of Proposed Rulemaking (NPRM). It is worthwhile to consider what equipment and other changes may be required for each company vessel based on the 17 “sub-applicabilities.” Also it is important to decide if its better for your company to choose the Coast Guard compliance option or the third-party Towing Safety Management System (TSMS) option.
Towing vessel captains should not be forgotten when considering this important compliance option. It might be interesting if companies polled a sampling of its captains on how they feel about passing an audit where the auditor is required by regulation to determine, by gathering objective evidence, if the company has “effectively implemented its TSMS throughout all levels of the organization, including onboard its vessels.”
Even if the answer from captains is a resounding “bring it on,” onboard implementation of all company policies and procedures would be a good topic to focus on over the next six months.
