The inland waterways industry is still waiting for the Coast Guard’s final Subchapter M rule to be published. They’ve been waiting so long that when "Subchapter When" is finally released it won't be surprising if companies have been lulled into a non-decision funk on such things as the Towing Safety Management System (TSMS). However, it may be impossible to make any decisions until the final rule is published.
The new projected date for publication of the Subchapter M final rule is February 2016. We'll see if that date is met or if the Coast Guard once again moves the goal posts for Subchapter When.
When the final rule is finally released, the Coast Guard doesn’t have the manpower to enforce the rule that will cover up to 6,000 inland vessels, some say. The Coast Guard "does not have the people for this rule, that’s why the third party inspections are being let in,” Ian McVicker, maritime consultant and independent representative for ABS Group's Paducah, Ky., office, said last week at the Inland Marine Expo in St. Louis. “Third parties will allow industry more flexibility.”
A real sticking point is each company’s TSMS. McVicker, who was with the Coast Guard, said a large part of the TSMS is taking everything a company does and putting it under one umbrella. “Each TSMS must be custom built. One size does not fit all,” he said. “A towing company with 20 boats is not going to have the same TSMS as a towing company with 120 boats.”
You have two years to comply with Subchapter M once the rule goes into practice. “There’s going to be some growing pains in this,” McVicker said.
The good news is that the Coast Guard has indicated that it intends to accept AWO’s Responsible Carrier Program (RCP) as a TSMS under the new Subchapter M regulations. Now all that seems to be left is the long-awaited release of the final rule. Come on Coast Guard, this is getting old.
