Blog Post 4

Is Subchapter M going to take your lic

Posted by Jason on September 22, 2010

The short answer is probably not, but in this article I will tell several ways that it will affect you, your vessel and your license renewal.

Last month, the Coast Guard published its long-awaited Subchapter M/ Towing vessel inspection program rule. The proposed rule is not in effect yet, and will take some time to phase in over the next several years, but it is something that we as an industry must realize and abide by. The main goal of the proposed rule is to establish new standards to ensure the safety of all aspects of towing vessel operations. Those safety goals include the safety of the crew as well as that of the environment. In order to enforce these new goals, the Coast Guard has proposed that every towing vessel currently in operation be inspected by a Coast Guard Officer or a Coast Guard approved third party auditor.
These proposed rules have been a long time coming and do not only stem from the very publicized accidents of recent years, but the oil spill in New Orleans and several barge sinkings on the lower Mississippi only sped up the creation of the rule. Those accidents have given our industry a black eye. The lack of an inspection regime has allowed too many poorly maintained vessels to operate. While the new regulations will not eliminate them all, it is a step in the right direction.
For Carline it will require some changes; however we are very fortunate that our current Safety Management System and Vessel Maintenance programs are second to none. This is why we were able to successfully pass every vessel in our fleet during the voluntary inspection period of the UTV bridging program. Carline is one of only a handful of companies that received a flag letter from the United States Coast Guard congratulating us for this 100% passing grade.
We welcome the implementation of the new rules. A majority of the rules apply to the vessel and the management of it. This includes the paperwork and the duties of the Captain. Fortunately for those of us at Carline, the new paperwork requirements should not add to our daily duties since we already have included them in our routine. These new changes will be gone over in great detail with each crew member well in advance of the new regulations becoming effective, so there will be no chance whatsoever of it reflecting negatively on your license. By now, everyone should have seen some of the preparation we are doing with the TMAC system, SINEX computer system and the vessel inspections conducted by management. The new regulations will make these regular inspections and the things checked a requirement for every operator on the river.
The question of what this means for our industry and how will it affect everyone remains unanswered. Will the operators that cannot or will not abide by the new regulations be shut down? Will the Captains and crews who refuse to learn and abide be the new regulations be forced out of the industry? These are still unknown. The Coast Guard is very committed to pushing this regulation through and then enforcing it. Carline will remain dedicated to riding on the forefront of this changing storm within our industry. This will allow us to reassure all of our customers that we will be there to service them consistently: Safely on-time, every time!

Lew Parks