Subchapter M was implemented for regulations pertaining to towing vessels in general. Before Subchapter M, these vessels were considered “uninspected” without a COI even though many of these same vessels were under huge 10 year contracts with super majors. Trust me, a SIRE inspection from an Exxon representative is more stringent than a USCG check. So while a good majority of the vessels were already inspected, USCG took the opportunity to implement changes. I think everyone will agree this is a good idea as long it helps prevent injuries, deaths, lost time etc.
Anyways, these regulations don’t fully kick into effect until 2021, giving companies ample time to comply (its been in the works for over 15 years now so no company has the excuse they weren’t ready). But essentially Subchapter M will give these vessels a COI, and thus inspected. The USCG put into effect a bunch of rules and regulations, with very much input in from industry leaders to accomplish this.
The towing industry in the United States alone consists of over 5,500 vessels and 30,000 vessel side employees (AWO numbers) – that’s a gigantic portion of the industry that operates under the Jones Act. With the recent incidents in the Missisippi River you can see why this industry needed to be regulated further. However, this has led to a rise in TPO’s. Essentially, the USCG did a very good job of implementing policies in a part of the industry that needed it.
The USCG basically states in policy that you can have them check up on your vessels in an untimely fashion or hire an approved TPO that will do it professionally and quickly so EVERYONE is going the TPO route. These TPO’s once numbered 7, now I think 10. My concern is that inevitably, these TPO’s will “get in the pockets” of their clients and essentially create a system for abuse. If I am a TPO and I shut down 3 of your 70 vessels, why wouldn’t you switch to another TPO that is known for doing the opposite. Just my 2 cents on the good and the bad of the Subchapter M regs.