Towing - Subchapter M Glass 'Half Full' Amid Progress And Challenges
Professional Mariner|December / January 2020
In one breath, Tom Allegretti, president, and CEO of the American Waterways Operators describes Subchapter M as “a singular milestone” for an industry striving to improve safety and eliminate spills.
Casey Conley
Towing - Subchapter M Glass 'Half Full' Amid Progress And Challenges

In the next, he acknowledges the Coast Guard’s towing vessel inspection standards remain a work in progress and could stay that way for some time.

“The mission of Subchapter M has yet to be accomplished,” Allegretti said during a conference at the Maritime Institute of Technology and Graduate Studies (MITAGS) campus near Baltimore in late September.

“There is a long road ahead of us to … bridge the gap between the regulation and the reality of our boats and our barges and our people,” he continued. “Subchapter M will only fulfill its promise when we have bridged that gap.”

Allegretti’s mixed assessment seems to ring true throughout the towing sector comprising roughly 5,800 active vessels and hundreds of companies large and small. Enforcement of the new standards remains something of an open question. Meanwhile, operators continue to report inconsistencies in how the regulations are interpreted by Coast Guard officials in different regions.

Dan Justis, who heads Subchapter M compliance for a large West Coast towing company, said two of its identical SOLAS-rated tugs in different Coast Guard port zones have different manning requirements. Justis said the matter is under appeal, but for now, the company must abide by the decision.

“We have noticed some distinct differences in manning requirements,” he said during the MITAGS conference, adding that the mixed interpretations are “kind of frustrating.”

Subchapter M took effect July 20, 2018, after more than a decade of development and review. As of that date, all towing vessels must comply with Subchapter M, even if they do not yet have a certificate of inspection (COI).

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