SubChapter M Towboat Rules Six Years Later: "Scorecard is a Mixed Bag"

The more than half decade that has passed since the inception of the subchapter M towboat rule affords an up-close-and-personal look at how it is going. The scorecard is a mixed bag.

More than six years ago, the U.S. Coast Guard (USCG) began inspecting towing vessels for compliance with the new towboat rules; specifically, 46 CFR Subchapter M. It has been a long road to compliance with many starts and stops, and much learning on both sides of the law.
Has it been a success? If success is measured by Certificates of Inspection, then yes. Roughly four-fifths of the towing vessels that were afloat in July 2018 have their COIs. But the remaining 20% do not. In some cases, the boats weren’t physically able to pass the test and that is a huge measure of success. We don’t have to worry about the crew members on those boats and the danger to the environment that many of them posed.

• “Success is also hard to measure when you have two tracks to compliance. I believe that the companies that went the TSMS route initially – and really embraced it – are safer. But employee retention makes a fully developed safety culture a