Commercial Vessel Compliance

3/13/2017: New policy letters on Subchapter M implementation

The Coast Guard and the Towing Safety Advisory Committee are committed to providing the towing vessel community clarification on a wide range of issues related to the implementation of Subchapter M. Depending on the complexity of an issue, information may be found on the TSAC’s website, within the frequently asked questions posted on the Towing Vessel National Center of Expertise’s website, or in additional guidance or policy released from Coast Guard headquarters.


Last week, the Coast Guard published two policy letters that affect towing vessels:


  • CG-CVC Policy Letter 17-01: “Use of the Uninspected Towing Vessel (UTV) Decal to Meet Certain Requirements Regarding Issuance of the Initial COI Under Subchapter M,” incentivizes the use of the towing safety management system option, by allowing vessels that employ the option to use the uninspected towing vessel decal as objective evidence that could be deemed equivalent to the Coast Guard visit required prior to the issuance of an initial certificate of inspection.
  • CG-MMC Policy Letter 01-17: “Guidelines for Issuing Endorsements for Tankerman PIC Restricted to Fuel Transfers on Towing Vessels,” provides an option for mariners on towing vessels designated as a person in charge of a fuel transfer, to meet the provisions for a merchant mariner credential with a restricted tankerman endorsement in lieu of meeting the full tankerman PIC endorsement requirements in 46 CFR Part 13.


As guidance and policies related to Subchapter M continue to be developed, towing vessel companies must make the important decision to employ the Coast Guard option or the towing safety management system option. Although using a third party to conduct surveys and audits is a paradigm shift from traditional Coast Guard inspections, the Coast Guard encourages companies to utilize the towing safety management system option as it will likely provide greater flexibility to companies in scheduling and performing surveys and audits, while also establishing a comprehensive quality control system that will increase the safety and efficiency of all towing vessel operations.

If stakeholders have additional questions or concerns that are not clearly explained in the preamble or regulatory text of Subchapter M, we encourage them to submit questions via the TVNCOE website or attend the Towing Safety Advisory Committee meetings. The next TSAC meeting is scheduled to take place April 11-12, 2017, in Memphis, Tennessee.


This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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