Subchapter M for Tugboats

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 !


so many different interpretations of the changes with subchapter m, and most of them likely wrong.
I personally need to read up on them more, but one subject I have heard is tugs will be looked at under their GT (formerly ITC) tonnage. I don’t recall reading this. A lot of companies have a push to have licensed engineers on board too, which I would see as being a requirement instead of a preference if this tonnage thing is true.

So what exactly is changing, and for the better?

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Have the “bluewater” unions done any analysis on Subchapter M to see if it opens up new opportunities for its licensed members?

Third party (owner hired) “inspections” and a TSMS (Towing Safety Management System).

As soon as I figured out that there was no COI and no Safe Manning Document, and that it does nothing to address undermanning, I used it for toilet paper.


I know this discussion/argument has been on here before but with the requirements for a towing endorsement and recency I’m not sure too many Bluewater/union guys would qualify or be able to do tug work

30 days of observation time on a tugboat and a one day TOAR course are not much of an obstacle.

It’s not that much of an obstacle until they actually have to do the work.


True. There is a world of difference between getting the license vs. having ability to actually go do the work.

Some types of work are easier than others. Some people have a knack for it, but most don’t.

My biggest issues with Subchapter M are no USCG inspection, and no COI specifying crew size. Without those basics, it doesn’t accomplish much.


Meh, who cares about the “drivers” looking out the window? LOL, there is another group of officers out there, ya know?

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Engineers? Most of them are unlicensed “deckineers.” Licensed or not, obviously, they need to be treated right.


This is a big part of the problem and the days of having “Galley Chiefs” are long over and if you have one, get rid of them as there are plenty looking for a good job!

As far as I’m concerned every boat should have a Licensed CE and they should be and only be an Engineer, not a part time CE and Full Time Deckhand!

As for Subchapter M, I agree with the other posters and really hoped to see real change. When I read the Final, I was letdown when I saw that they did not come out with a Minimum Manning Level. Hell, if the industry wants to say 2 men are fine on a 6,000 coastal boat, there is nothing to stop them. Well, maybe their Insurance Underwriters might have something to say and who would have ever thought that the Insurance Industry might actually help.

When it comes to the “Inspections” everything that I’ve read describes a glorified Audit or a Vetting Inspection which those that work strictly with Oil have been dealing with for years.

All of the talk about M putting a lot of Mom and Pop Companies out of business is a joke. If M forces them out of business, they must have been pretty shacky to start with!


Let me tell you about Sub M, mom and pop, and Alaska. I own a mom and pop operation in Southeast Alaska, and M will almost certainly put us under. Almost all towing taking place Southeast Ak originates in Seattle and is performed by the Seattle tugs. General towing, outside of the Seattle freight runs, is almost non existent. In the city where we are located we have the only tug with a UTV decal, and the only one starting down the sub M path. Our biggest problem, and the reason why we won’t be able to afford M, is lack of enforcement of existing CFR’s by the Coast Guard. Let me explain: Almost all towing is being conducted by fishing vessels, mostly tenders/packers in the 60 to 80’ range. Worried about manning? These vessels are operating with less than half of a standard tug crew, they lack towing credentials, don’t participate in drug testing etc. The vessels themselves don’t meet a single existing requirement found in CFR for towing vessels (unless by accident) if this sounds hard to believe it gets better! These vessels have federal contracts for towing! The US Forest service puts out contracts twice each year to have camp barges moved around S.E. AK and also contracts for fueling remote sites, delivering equipment etc. For almost 18 years we have competed for these contracts and every time fishing vessels come in less than half of us. The Coast Guard has Refused to enforce this situation. This is not an impossible task or a needle in the haystack, this Is a Federal contract! they know who is doing it and when. When we have requested enforcement action, they ask us how our sub M preparations are going. We have been told repeatedly by C.G. not to worry, and that sub M will shut these illegal operators down, but there are already towing regs and they won’t enforce those. We operate a safe boat, my family is often onboard, but if we have to start crop and renewing every dent, we will go under. It makes me livid to hear C.G. talk about improving safety on towing vessels while at the same time accommodating illegal ops. Would they prefer that I go away? who will assist the fuel barge once a month? Who will get a line on a drifting ship headed for a wilderness area shore? Mom and Pop’s play an important roll in a very vast and pristine area, where limited work prospects almost ensure that a Foss or Crowley tug will never live here.


Have you done bid protests on those federal contracts that you lost to fishing boats? You should. There is big money in winning federal bid contests. It sounds like you have a slam dunk case.


Galley chiefs and galley deckhands , sit around all day On the phone , can’t even manage to make fuckin dinner let alone sweep and mop “ I was gonna get that” “didn’t have time”

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Now that I have been on a few old rundown, poorly equipped, and undermanned tugs that have somehow managed to pass USCG Subchapter M inspections, or third party Subchapter M inspections, it is more evident than ever that Subchapter M is a sick joke.

I thought about becoming a Subchapter M third party inspector, but I can see that I would be promptly blacklisted for being honest and doing the inspections correctly.


Some factual inaccuracies here …

SubM includes USCG inspections for issuance of the Certificate of Inspection but the OCMIs have been given discretion in certain instances to issue the COI without attending.

Minimum Manning is documented on the COI when issued.

I think what tugsailor is likely getting at is:

  • No annual USCG inspection like a ‘real’ Inspected vessel.

  • Manning might be specified on the sub M COI, but it appears that, in general, the same low (possibly unreasonably so) manning as prior to sub M is being continued after implementation.

I said no manning specified in the COI months ago, and someone promptly corrected me.

It sounds like most OCMIs are just specifying whatever the owners want.

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Doh … didn’t look at the date of the post, my bad.

Incorrect, it just specifies inspection, not necessarily by the USCG.