Subchapter M - Cost Inspections

Not sure about the TPOs you’ve mentioned but the TVIB has very strict guidelines in place for their inspectors.

I couldn’t like it but it did make me laugh.

TVIB has guidelines, wouldn’t call them strict by any means. Another good ol boy system.

I think most would rather not have the USCG coming down all the time given their lack of engineering backround of tugboats vs abs. It is easier for most to use the ABS option for audits since many companies already have an abs loadline it makes the crossover a bit easier. A lot of it comes down to it’s just easier to deal with abs than the uscg if there is a deficiency that needs to be corrected.

SubM has serious implementation flaws which make it a challenge for it ever being a true inspection/certification program in line with other 46 CFR Subchapters any time soon. I used to be at a TPO but then saw too much. Now I am an independent surveyor/inspector and I only do internal surveys and audits.

Owner/Operators – There are two camps, the bigger operators who are probably ISM already and the smaller operators who are starting from scratch. Most want the COI but don’t really want to change the way they do business with regard to maintenance and compliance.

Inspectors – Most are either from and comfortable with the old way of doing business or are branching out from the owner/operators. The majority are a mix of old dogs struggling with new tricks or new to the game and just don’t have a broad enough understanding of regulatory compliance as a concept and are trying to learn from said “old dogs”.

USCG – Does not understand how to integrate a SMS into/with the material condition aspect of the regulations. Most USCG people I have talked to have demonstrated they simply do not understand Quality Management Systems as a concept enough to effectively do this. I have quoted and referenced their own policies and procedures to them and have gotten the proverbial “deer in the headlights” look.

The big operators have big questions that the Sectors are not equipped to answer and HQ is extremely slow. Some small operators want to fly under the radar and get mad when you tell them anything new is required. Other smaller operators want to do the right thing but in truth don’t know where to turn for quality advice. I have heard operators refer to certain consults as their “TPO” when that consult is not actually a TPO.

The industry can get there, the problem is everyone just started way too late to effectively meet the timeline so it looks like compliance is a joke. In reality, I think its just a slower culture change than people expected.


@BrownWaterGuy you should start your own TPO. You nailed it on the head.

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@PDCMATE No thanks, I enjoy my life as it is too much to do something like that. I’ll stick to doing audits and surveys. I personally enjoy a role where I am helping operators reach compliance than one where I bang my head against the brick wall of bureaucracy all day long.


From what I have seen so far, the USCG Subchapter M inspections are very easy.

50 year old, under-maintained boats at small halfass operators are passing.

A quality company with nice boats has nothing to fear from a USCG Subchapter M inspection. After the first boat passes, passing the other boats will just be a formality.