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Maritime Compliance Report

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Subchapter M - 18 Months to Comply

There are now 18 months left to get towing vessels into compliance with Subchapter M. According to our Subchapter M Strategic Plan, by now all captains should have read Subchapter M, as well as all managers, who should also have read the Subchapter M Preamble in the Federal Register. Additionally, companies should have decided which compliance option they will go with. We developed a Compliance Option Decision Tool to help in this process. It takes into account seven important factors for towing vessel companies to consider, free of spin and sales pitches. So, if you haven’t done that much yet, you should consider catching up.

January 1 is the date set for companies to begin getting their boats into compliance by getting a comprehensive Subchapter M survey for each vessel. We recently completed our first two Subchapter M surveys for a client.  In order to do this properly, the company must first make some important decisions: the vessel route; number of persons in the crew; number of persons in addition to the crew; warm or cold water operation; excepted vessel or not; and the compliance option. The survey should be based upon these assumptions. Once the company has a comprehensive regulatory compliance survey report, they can budget and plan out the timing of upgrades throughout the year. 

April 1 is the date set to establish how the requirements for written records, operational policies and procedures, and training will be met. Some of our clients are getting ahead of the game by implementing our comprehensive Towing Vessel Record/ Compliance Management System, which includes all required records, policies and procedures. With a good survey, our comprehensive system, and some training, these clients are all set for Subchapter M. 

The items discussed above apply to all towing vessels, regardless of the compliance option. For those companies choosing the Third Party Option, they have a number of other considerations. More on that next time.

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