Subchapter M is too little too late.
Tugs should have been inspected under Subchaper I with a full USCG inspection (not 3rd party hired by the company), And USCG issued COI, and Safe Manning Document. This should have been done 40 years ago. Similar to how it’s done in the rest of the world.
Subchapter M is a USCG regulatory capitulation to the AWO and corporate bean counters. It’s an elaborate pretense of flag state regulation that accomplishes next to nothing.
No real inspections. No COI !
Blatant undermanning is not addressed. No Safe Manning Document !