What is the current status of Subchapter M implementation?
There was a lot of talk about this, but the topic seems to have gone quite again. I don’t hear many people worrying about it anymore?
Not really, most legitimate operators are already managing their fleet to beyond what the USCG would probably mandate. At least if you move oil. Yes there are physical issues with the boats, but honestly they’re no worse than the things I’ve seen on inspected vessels. The ones who are or should be worried are the one or two tug outfits who just move crane barges, dump scows etc. They’re running stuff nobody else wants and usually employ the people nobody else will; not always, but often. With that said, there are great one or two tug outfits out there with gleaming equipment and squared away operators.
My hope was for licensed engineers (or at least a QMED) on any route. I know they will not adress the 3-watch system so i have no expectations there. the compliance options are really a joke though and the only reasonable choice would be to have actual CG inspections.
If they’d abandon the old inland/near coastal boundary lines it would fix quite a bit on its own. That and clamping down on the frequency of inspection for known trouble-makers and deficient vessels; no need to inspect the good ones regularly but inspect (board) the bad ones all the time.
[QUOTE=z-drive;177734]…I know they will not adress the 3-watch system so i have no expectations there. [/QUOTE]
It’s in the U.S. Code, the Coast Guard can’t change it. Only Congress can chnage the U.S. Code.
yes, no argument there but why was there so much talk about it and solicitations for input on the topic, mostly regarding rest? That’s why I mention it.i had hoped it would have encouragedsomething to happen at a higher level.
I do worry about how Subchapter M might force the retirement, and scrapping, of some of the classic old tugs that are part of our maritime heritage. A tug does not have to be fit for crossing the Gulf of Alaska in December in order to do harbor work or tow gravel barges in July.
I also worry about how Subchapter M might force mom and pop companies to go out of business or sell out to the big guys.
I would like to see certificates of inspection that specify required crew compliment(s), certain equipment, and operating routes.