Subchapter M Regulations
(Tugboats and towing vessels only)
This new Subchapter M Regulations compliance measure by the Coast Guard can be timely and cost-prohibitive. Many small tugboat or marine-related companies are evaluating their exit strategy due to these circumstances. We can help you should you decide when and how to divest.
Furthermore, it is subject to USA Flag towing vessels engaged in pulling, hauling, or pushing. Construction, design, and certification of commercial vessels.
Additionally, accommodation space means any sitting area, lounge, messroom, quarters, sitting area, recreation room, gallery, toilet space, shower room, berthing space, clothing changing room, or a similar space open to individuals.
Hence, a berthing space is a space that is used for sleeping and has bunks and bedding. Further, there are more definitions here: Subchapter M Regulations
This is a full audit that must be performed on a vessel. It is an examination to evaluate activities and related results to see if they comply with the vessel towing safety management systems – TSMS, or with another SMS – Safety Management System. These activities are evaluated to determine whether they were implemented suitably to achieve your desired objective.
Consequently, the examination is a comprehensive review of certain reports, records, documents, and other evidence that will help confirm compliance with mandated requirements. Subchapter M Regulations
For instance, things that may be included in the audit are: reviewing of records, examination of training records and work environments, inspection of equipment to ensure it is operational and properly maintained, observation of skilled persons performing specific tasks that align with their assigned duties, and interviewing responsible workers to ask questions about their assigned responsibilities.
Lastly, the audit is typically limited to a random selection or sampling that can provide the auditor with sufficient evidence of system compliance. Also, all owners of more than one towing vessel are required to have a Certificate of Inspection – COI by Subchapter M Regulations.
Learn more here: Subchapter M Regulations