The Coast Guard and Marine Transportation Act of 2004 included a provision to add towing vessels to a list of vessels subject to inspection and certification. For more than 10 years, the towing industry and the Coast Guard have worked collaboratively to develop regulations and a plan to transition the vessels into an inspected fleet.

While public hearings were held and the regulations began to take form, the towing industry, working with the Coast Guard, began undergoing voluntary examinations by marine safety personnel. This work allowed towing companies to verify their compliance with the uninspected vessel requirements, determine what items needed to remedied (if any), and begin a dialogue with the Coast Guard as both entities moved toward towing vessel inspections.

Following adjudication of several thousand comments from a 2011 Notice of Proposed Rulemaking, a Final Rule was published June 20, 2016. This Final Rule set July 20, 2018, as the compliance date for all towing vessels subject to Subchapter M even if the vessel does not have a Certificate of Inspection. Towing vessels have a strong record of safe operations, so while July 20, 2018, represents a beginning of a new regulatory regime, these vessels will continue to operate safely and provide a valuable service to the nation’s economy.

Any discussion of Subchapter M must include a mention of Third Party Organizations (TPOs) that will perform much of the survey and audit work associated with vessels exercising the Towing Safety Management System option. The Coast Guard is vested in ensuring that TPOs succeed. Their success will be critical to the success of Subchapter M. While the Coast Guard will perform oversight functions, TPOs will work closely with the Coast Guard to verify vessel compliance and, if necessary, to develop alternate arrangements that will keep these vessels operating safely.

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.