Happy Subchapter M Day! Our partners Tug and Barge Solutions have put together five subchapter m regulations within Sub M you should know now that the regulation is officially in effect. Here’s what they had to say:
Today Federal Regulation 46 CFR Subchapter M goes in to effect for the Tugboat and Towboat industry. Since the discussions began many years ago, Marine industry experts have been warning small and large Tug and Dredge companies to begin preparing for this day. It has arrived with little fanfare but BIG consequences. For companies who have not made their plans known to the USCG for compliance there is the possibility of the Coast Guard boarding those vessels and putting them out of commission until all issues have been resolved. This means no work until the vessel is in full compliance.
The law states that all vessels must be compliant by today.
Five Regulations you Should Know
For those companies working with Tug and Barge Solutions, you are on the right track to receive your COI before the deadline. If you are part of the 66% of the industry who has not made any plans to become compliant with Sub-M, today is a great day to begin thinking about envisioning what will happen when you are boarded by the USCG and forbidden to move until your vessel is Sub-M compliant. Then make the call to TBS.
1. Fire Hazards to be Minimized
Regulation 142.220
Each towing vessel must be maintained and operated so as to minimize fire hazards and to ensure the following:
(a) All bilges and void spaces are kept free from accumulation of combustible and flammable materials and liquids insofar as practicable;
(b) Storage areas are kept free from accumulation of combustible and flammable materials insofar as practicable.
What Should You Do?
Keep your bilges clean and free of oil and fuel. The USCG and TPOs are checking the depth of the bilges and seeing how much oil is in them. Not only does an oily bilge violate 142.220, but it also violates 140.655. The USCG may assume that the oily water is pumped overboard and then you are in violation of the Federal Water Pollution Control Act and Act to Prevent Pollution form Ships. When you have your bilges pumped out keep a copy of the form that the vac truck or facility gives you. It’s your proof that you didn’t pump it overboard.
2. Prevention of Oil and Garbage Pollution
Regulation 140.655
(c) No person may intentionally drain oil or hazardous material into the bilge of a towing vessel from any source. For purposes of this section, “oil” has the same meaning as “oil” defined in 33 U.S.C. 1321.
3. Hatches & Other Openings
Master’s Responsibility
Regulation 140.610
(a) All towing vessels must be operated in a manner that minimizes the risk of down-flooding and progressive flooding.
(b) The master must ensure that all hatches, doors, and other openings designed to be watertight or weathertight function properly.
(c) The master or officer in charge of a navigational watch must ensure all hatches and openings of the hull and deck are kept tightly closed except:
(1) When access is needed through the opening for transit;
(2) When operating on rivers with a tow, if the master determines the safety of the vessel is not compromised; or
(3) When operating on lakes, bays, and sounds, without a tow during calm weather, and only if the master determines that the safety of the vessel is not compromised.
(d) Where installed, all watertight doors in watertight bulkheads must be closed during the operation of the vessel, unless they are being used for transit between compartments; and
(e) When downstreaming, all exterior openings at the main deck level must be closed.
4. Operational Readiness of Lifesaving and Fire Suppression and Detection Equipment
Regulation 140.650
The owner, managing operator or master of a towing vessel must ensure that the vessel’s lifesaving and fire suppression and detection equipment complies with the applicable requirements of parts 141 and 142 of this subchapter and is in good, working order.
5. Readiness
Regulation 141.230
The master must ensure that all lifesaving equipment is properly maintained and ready for use at all times.
By our partners at Tug and Barge Solutions.
To learn more about how Tug and Barge Solutions can help you become Sub M Compliant, click here.
