# Subchapter M implementation
**URL:** https://forum.gcaptain.com/t/subchapter-m-implementation/50144
**Category:** Professional Mariner Forum
**Created:** [December 31, 2018, 2:20pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144 "2018-12-31T14:20:46Z")
**Posts on this page:** 15
**Page:** 2
### Author:  [@Ctony](https://forum.gcaptain.com/u/Ctony)
#### Post date: [January 1, 2019, 2:55pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/21 "2019-01-01T14:55:43Z")
> [@drew](#):
>
> We’ve had one for about two months. It was issued maybe 6 months after all inspections were done under TSMS/ISM option.
Has the manning changed in accordance with your coi? Curious if it did, and how so?
Also, size of vessel and route, and how that change the manning, if it did?
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### Author:  [@tugsailor](https://forum.gcaptain.com/u/tugsailor)
#### Post date: [January 1, 2019, 3:28pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/24 "2019-01-01T15:28:08Z")
While I have not seen an actual COI, on the newly inspected boats I’ve been on, there was no change in crew size.
4 man boats (Master, Mate, Deckhand/Unlicensed Engineer, and deckhand/cook) working 6/6 and operating 24/7 are passing inspection.
Subchapter M is a sick joke and laughably ineffective. It’s just what the AWO paid all those lobbyists, Congressmen, and USCG Admirals to do — water it down to nothing.
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### Author:  [@Ctony](https://forum.gcaptain.com/u/Ctony)
#### Post date: [January 1, 2019, 4:21pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/25 "2019-01-01T16:21:17Z")
Many were under the impression that licensed engineers would become a requirement from subchapter m manning, but apparently that won’t be the case.
In tough times i can see some companies trimming the fat at the licensed engineers expense now.
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### Author:  [@drew](https://forum.gcaptain.com/u/drew)
#### Post date: [January 1, 2019, 6:32pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/26 "2019-01-01T18:32:21Z")
When they came out with the limited PIC over a year ago, I thought that made it clear that the engineer requirement was not being added.
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### Author:  [@DirtyCoast](https://forum.gcaptain.com/u/DirtyCoast)
#### Post date: [January 1, 2019, 6:54pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/27 "2019-01-01T18:54:26Z")
I think manning requirements definitely need a look or at least a discussion. Things to consider:
1. requiring a licensed engineer for anything greater than 2000 HP or 70 feet long
2. A discussion on the introduction for a 3 watch system for voyage plans over a 5 day duration. I know STCW the cutoff is 600 miles but I think the inland companies would try to get around this. Many runs on the Mississippi River are over 600 miles with 2 wheelman.
Also, tankerman restricted license is not needed on board towing vessels to fuel up until Subchapter M is fully phased in on July 19, 2022.
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### Author:  [@tugsailor](https://forum.gcaptain.com/u/tugsailor)
#### Post date: [January 1, 2019, 7:05pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/28 "2019-01-01T19:05:05Z")
98% of US tugs are exempt from STCW, so there is no reason why they should need licensed engineers.
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### Author:  [@BrownWaterGuy](https://forum.gcaptain.com/u/BrownWaterGuy)
#### Post date: [January 1, 2019, 7:19pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/29 "2019-01-01T19:19:21Z")
> [@tugsailor](#):
>
> Six months from completed inspection to COI in hand. That explains why I have never seen one.
That is according to the rule. A TSMS vessel without a history of ISM or RCP must operate for six months with a TSMS certificate before they can be issued a COI
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### Author:  [@BrownWaterGuy](https://forum.gcaptain.com/u/BrownWaterGuy)
#### Post date: [January 1, 2019, 7:23pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/30 "2019-01-01T19:23:31Z")
The manning scales listed in the Marine Safety Manual do not require a licensed engineer until 200+GRT, coastwise or oceans.
That is only “guidance” though. OCMIs have very wide latitude to essentially do what they want. I heard of one OCMI wanting to require 3 licensed engineers on a coastwise ATB.
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### Author:  [@tugsailor](https://forum.gcaptain.com/u/tugsailor)
#### Post date: [January 1, 2019, 7:29pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/31 "2019-01-01T19:29:47Z")
That OCMI sounds like a smart guy trying to do a good job. The owners and AWO will promptly see to it that he gets a good dressing down from the Commandant and several Congressmen, or maybe a rapid transfer out to Diego Garcia. How dare he cost the owners a few extra pennies in the name of safety? Doesn’t he know all this safety stuff is just for show?
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### Author:  [@tugsailor](https://forum.gcaptain.com/u/tugsailor)
#### Post date: [January 1, 2019, 7:32pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/32 "2019-01-01T19:32:59Z")
I’ve been on a USCG option tug that didn’t have a COI onboard three months after passing the inspection.
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### Author:  [@BrownWaterGuy](https://forum.gcaptain.com/u/BrownWaterGuy)
#### Post date: [January 2, 2019, 2:04pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/33 "2019-01-02T14:04:40Z")
I know some people who do work for a few TPOs and i have heard of some unhelpful things with respect to the USCG.
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### Author:  [@tugsailor](https://forum.gcaptain.com/u/tugsailor)
#### Post date: [January 2, 2019, 2:39pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/34 "2019-01-02T14:39:13Z")
The USCG just wants to be the military and law enforcement. They mostly want to chase terrorists and drug dealers. Issuing licenses to mariners and inspecting vessels is no longer a priority.
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### Author:  [@DirtyCoast](https://forum.gcaptain.com/u/DirtyCoast)
#### Post date: [January 2, 2019, 2:41pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/35 "2019-01-02T14:41:47Z")
> [@BrownWaterGuy](#):
>
> I know some people who do work for a few TPOs and i have heard of some unhelpful things with respect to the USCG.
Care to elaborate? Thanks
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### Author:  [@BrownWaterGuy](https://forum.gcaptain.com/u/BrownWaterGuy)
#### Post date: [January 2, 2019, 7:04pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/36 "2019-01-02T19:04:42Z")
> [@DirtyCoast](#):
>
> Care to elaborate? Thanks
Just a few I’ve heard of off the top of my head …
Ghosting – USCG asks for more information on a pending COI application then disappears never responding to follow up emails and phone calls.
Not understanding the difference between audits and surveys – USCG can’t seem to understand that they have distinctly different objectives, definitions and scopes.
Too much verbal guidance and not enough written guidance
Not following their own process and procedures, shooting from the hip in requiring things without doing enough research to know what the situation really is.
Disconnect between HQ/Senior Leadership and OCMIs/Junior Officers
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### Author:  [@DirtyCoast](https://forum.gcaptain.com/u/DirtyCoast)
#### Post date: [January 2, 2019, 11:08pm UTC](https://forum.gcaptain.com/t/subchapter-m-implementation/50144/37 "2019-01-02T23:08:58Z")
Thanks for the response, that’s a little disheartening to hear but not at all surprising. I know USCG reached out for input from companies and the industry when putting together Subchapter M. I figured this might have fixed issues like that, but that’s me putting too much faith in a broken system. Hopefully the kinks get worked out and at least they have a CFR to add to going forward for towing vessels.
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