Subchapter M - Cost Inspections

Hi Everyone,

Can anyone tell me what kind of costs I am looking at for Subchapter M inspections? What companies are the most cost effective and any advice or recommendations would be great, any cost comparisons would be well received. Thank you for your assistance.

This is an interesting topic. I’d like to hear reports on both cost and quality of Subchapter M inspections by various 3rd party vendors.

Personally, I think the entire notion of the Subchapter M allowing owners to shop for the lowest cost and most superficial inspections by company paid 3rd Party vendors is a farce.


I had wanted to start a new topic, but my new post button disappeared.

A few Subchapter M Inspection Questions:

How does a tugboat with a vertical ladder (made out of 1” water pipe) from the galley to the wheelhouse “pass” Subchapter M inspection? Especially, how does it “pass” with no hatch or other means of tightly closing off the ladder way in the event of a galley fire?

How does a tugboat with crews quarters in the forepeak with no collision bulkhead 5% to 15% of the vessel’s length back from stem head “pass” Subchapter M inspection?

How does a tugboat with less than 6 feet of headroom in the crew quarters “pass” Subchapter M inspection?

How does a tugboat with crews quarters in the forepeak accessed by a vertical ladder from the galley with no door or hatch cover “pass” Subchapter M inspection?

How does a tugboat with crew quarters in the forepeak, but no second means of escape “pass” Subchapter M inspection?

How does a tugboat with all of these defects “pass” Subchapter M inspection?

Is Subchapter M really as much of a farce as it appears to be?

Because no one has died due to those things yet/recently. Take one for the team and set a massive galley fire or run the tug into a dock at full speed flooding the forepeak and killing some crew members and you’ll get the law changed.

It passes the inspection because there isn’t anything in the regs prohibiting those things. If there was, half of all the small business out there would be shutdown. Subchapter M is more so about holding owners, operators, and crews accountable, rather than the actual vessel itself. Everything is recorded now. A majority of our inspection time was spent going over policies and procedures instead of walking through the vessel like a traditional inspection.

The answer appears to be:

Subchapter M “inspections” are not hull, machinery, watertight integrity, stability, fire protection, or safety inspections of the tugboat itself (as inspections of small passenger vessels are under Subchapter T, or as OSVs are inspected under Subchapter I).

Subchapter M is just an audit of the modern SMS paperwork being done on old, obsolete, and often unsafe, tugboats.

To the question: When is Subchapter M going to encourage the retirement of 40, 50, 60, 70 year old tugboats? The answer appears to be: Never.


Agree completely. While most Outfits are putting an emphasis on safety (or trying to), there’s still people out there pushing the limits in antiquated equipment. There is also a lot of variance between cg units.

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Based on the checklist I have, and a vessel I just spoke to a couple weeks ago, it does cover some of what you are referring to. The inspector on this particular vessel spent 8 hours. A large portion of this was spent on the paperwork, SMS, etc., but he also spent a couple hours with their chief engineer crawling around looking for check valves, etc. The fire portion is also covered, especially the CO 2 room, correct signage-follow up signage. We actually had a room built for the bottles, although it sounds like a waiver is possible for that too. Perhaps it depends on who is inspecting you. The alarm panels, shitter system, etc was gone over. We have 40 plus year old tugboat, but we have worked hard and spent a lot of money to come into compliance.

On safety equipment- there are a lot of little things people miss- battery expiration dates, fire extinguisher near the paint locker etc… When i was trying to figure out based on the changed wording of the regs, whether type 3 or type 5 work vests were required, even the inspectors had to double check. (Its type 5 by the way). Anyway, Ill let you know how ours goes in a couple months.

I have not been on a tugboat while undergoing Subchapter M inspection.

However, several of the tugs I have worked on have passed Subchapter M inspection.

I find it very hard to accept that some of these boats “passed.” They very clearly would not have passed any other type of USCG inspection.

Eventually, a few of these old tugs that have passed a USCG Subchapter M “inspection” and have received a USCG COI are going to be involved in tragic incidents which will shine a spotlight on this farce of a USCG inspection program.

Maybe because half the TPO’s are run by the good ol boys who take care of their brethren.
The only TPO’s that actually held a standard would be:
Decatur - no longer in business

Really? I heard good things about them. Most of the TPO’s are former coast guard anyways. These TPOs were multiplying in past few years…something had to give.

My thoughts on Subchapter M are:

  1. Right now it’s not doing much other than making the smaller companies sell out. Industry consolidation due to higher costs.

  2. It’s somewhat of a racket and I do imagine some TPOs will be shut down or reprimanded for passing vessels that’s shouldn’t be issued a COI because they are afraid to lose business.

  3. I think @Capt_Phoenix is right, until bad accidents happen, there won’t be much change other than higher costs.

  4. At least there is a CFR where relevant changes can be made for the future, this is best part about it.

  5. You can choose two options for inspection, USCG or TPO route. As of right now, 75% are choosing a TPO for inspection. Obviously the USCG still can be part of these inspections but let’s be honest, USCG doesn’t have the resources to inspect the 5,500 US flagged towing vessels (and growing). It will be interesting to see how this plays out going forward.

The USCG inspected tugboats I’ve seen aren’t any better than the TPO option boats. Neither get much of an inspection. The USCG option is cheaper for an owner.

Since Subchapter M is nothing but paperwork, and electronic versions of it can be obtained from vendors for less than $500 per boat per month, Subchapter M certainly isn’t going to force anyone out to sell out. It’s nothing more than an inconvenience and small cost for the owners.

A real inspection program similar to Subchapter T would involve significant costs. It would force a few boats to be retired. As they should be. That might put a few marginal owners out of business.

Sub M compliance inspections can be very thorough if the TPO has the right people in place, as well as owners that understand the need for this. The main issue was the whole business model for Sub M TPO vs USCG.
When you try to start a compliance business with an option that costs very little to nothing, it forces you to cut your costs down. How much money can a company make off of a $1500 Audit or Survey? You have to pay the inspector, at least half to conduct the audit/inspection/survey. If the USCG would not have priced out the TPO’s, then those companies could of had higher rates, paying more qualified individuals to conduct these inspections.
Decatur realized that the business model was not sustainable. What happens in 5 years when the initial contracts (TPO to Client) is completed, why would a company stay with any TPO at this point and not just go USCG, since now they know what to expect and have already had audits and surveys conducted. TPO’s will be priced out by 2023.

If you haven’t noticed smaller companies being bought by larger companies ie progressive being bought by Savage, Petchem by EN Bisso and consolidation in general Kirby buying higman, Kirby buying cenac, then you and I see things differently. Call it cost or inconvenience but this activity has increased. It’s also the costs money to become compliant; if you have to go to a shipyard and get a bunch of stuff done, that might make you reconsider. Justifying the cost of Subchapter M just from the cost an inspection is an elementary view at best. Talk to anyone that actually owns a towboat or tugboat.

Good point but wait and see, you think the USCG can audit 5,500 towing vessels every year?? I don’t. This scenario pays to have a private TPO instead of USCG to avoid having any shutdowns due to non compliance or the inability of an auditor to get the audit done on time. Subchapter M isn’t fully phased in until 2022!! I would imagine that not even half the towing vessels out there have a COI yet.

They dont have to have it yet. If a company has only one vessel they have to have it done by July of 2020. Companies with more than one tug have to have a percentage done by then with everyone having to be in compliance by 2022.

It also depends on what part of the country you are in. In many areas the USCG has time to do Subchapter M inspections. They make be rationing how many boats an owner can put through, but they are doing enough to keep the owners legal.

The trend of big companies buying up the small companies has been going on for along time. Subchapter M has nothing to do with it.

The only benefit a TPO gives over USCG is detention of the vessel. If the company goes USCG route and they find a major NC during inspection, then the vessel could be detained in the current port/area. If they are TPO, then that NC can be worked through a correction period and the owner can still operate. But as you stated those 5,500 vessels, will soon be less due to operators not affording the sub m upgrades and operational needs. Do I think the USCG can handle it, No, but if I was an owner, why would I pay a TPO when I can have the USCG do it, and if they can’t because of personnel constraints, then they will have to issue a extra time.

This shows a bit about the struggle of Sub M implementation, and the difficulties TPOs and USCG face as Sub M phases in over the 3-4 years.

At the end of the day, there are only 3 or 4 TPO’s that actually do inspections. Others are holding a TPO certificate for training or consulting, nothing else.
The best TPO was Decatur, now they combined with Sabine. Sabine is the best TPO, followed by ABS and TVIB. The new ITOW is under investigation for stealing IP from TVIB, I feel for all of the clients that are with ITOW, they should leave immediately and call Sabine.