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Maritime Compliance Report

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Subchapter M Update

The update to the DHS regulatory agenda now shows the expected publish date of the Final Rule for Subchapter M, towing vessel inspection regulations, to be March of 2015. While some find the moving goal post frustrating, it also buys time for preparation.

Anyone who may be impacted by this regulation should take the time to read over the Notice of Proposed Rulemaking (NPRM). Some things to consider are: what equipment and other changes may be required for each company vessel based on the 17 "sub-applicabilities;" and, is it best for the company to choose the Coast Guard compliance option or the third party TSMS option.

Towing vessel captains should not be forgotten when considering this important compliance option. It might be interesting if companies asked a sampling of captains how they feel about passing an audit where the auditor is required by regulation to determine, by gathering objective evidence, if the company has, "effectively implemented its TSMS throughout all levels of the organization, including onboard its vessels." Even if the answer is a resounding, "bring it on!" on board implementation of all company policies and procedures would be a good topic to focus on over the next six months.
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