Subchapter M


I received this email last year. it has “sample manning charts”

An inspector also handed me a “credentials and manning exercise” referencing the manning charts.


Too many small tugs(70-90ft) running around with a captain and one deckhand. Towing 3+ scows a night out to a dump with a soft line. That deckhand gets a workout. I consider captain plus 2 to be minimum for a 12 hr shift. .Gov knows they operate this way, yet they do nothing. Even the new “sample manning charts” show captain +1 deckhand for towing vessels under “100ton” for a 12 hr shift.


Chart is B2-44 of the MSM


Another hole left by sub M is the work hours for the Lakes…not more than 15 hours in a 24 hour period. Crazy. On the coast, “officially” it is 12 hours but we are juggling the crew to keep guys under 15 some days. Another deckhand and engineer would make all the difference when we have to fix stuff.

I don’t necessarily blame the companies but I DO lay it squarely at the feet of the regulators who need to grow a set and take a hard look at what they allow. I have tied up for crew rest in the past and will do it again if needed but why is it so hard for those who make the rules to see the problems? Silly question, I know…$


Thank you for the link to the USCG Marine Safety Manual, and the tugboat manning tables on pages B2-43, B2-44

These confirm the continuation of the present Two-Watch (12 hour) System for Tugs under 200 GRT on voyages of any length. That’s 95 percent of all ocean and coastwise Tugs.

In short, Subchapter M does nothing to solve the undermanning problem. To the contrary, it further enshrines 12 watches and one mate as the standard in the US tug and barge industry.

The AWO bought off the USCG to the point that Subchapter M is an utterly worthless paper chase that accomplishes nothing.


The 12 hour rule on tugs only applies to deck officers, not anyone else onboard. If you’re not subject to STCW rest hour regulations then there’s no law that limits how much the rest of the crew can be expected to work.


The Manila amendments added that any person onboard with firefighting duties or environmental protection duties be governed by STCW rest period rules. Consequently, at least in my little sandbox, even the cadet fills out a rest log. The logic from port state control is that everyone onboard has some level of environmental protection responsibility, everyone separates trash, etc. I’m not sure if I’ve been asked specifically by the USCG on that wrinkle yet.


STCW does not apply to 99 percent of US tugboats. Therefore STCW rest hour requirements do not apply.

The USCG refs that do apply specify 12 hours of watch, but there are frequently off watch duties, like arrivals and departures, making and breaking tow, bar crossings, cargo work, etc. The way most 24 hour crewed tugs operate with small crews and two watches, there may be some 12 hour days, but 15 hour days are frequent. 18 hour and longer days happen less often, but they do occur.

Actually it would be better if STCW applied because it allows temporary shorter rest periods, and catching up on rest later.

Rest hour logs are mostly pencil whipped by each crewman at the end of the week or month to show 12 hour days.

Electronic daily logs that are transmitted to the office everyday are becoming more common, but are dependent on the data that is manually input. Daily inputs should make it easier to track hours correctly, but if the Master starts telling the truth and inputs crewmens’ off watch hours worked, the office goes nuts and there is immediate pressure not to show the crew working over 12 hours.

This happens with inputting any of the checklist items in the electronic log. If there is a checklist item for chart corrections, and you accurately check no (which is often the correct answer when for a variety of practical reasons chart corrections have fallen behind, instead of yes, the office goes nuts. One quickly learns that the electronic log requires that you tell the office what they want to hear, not what is true.

Getting back to tracking rest hours, it would be easy today to equip each crewman with a smart watch that tracks his working and resting hours, and his exertion levels, and whether he is actually resting or goofing off during his rest time. This data could be automatically downloaded into the electronic log so that it could not be pencil whipped. Companies would not do this, because they don’t want anyone to know the truth about the lack of rest hours with the small crews we have today.


In a legitimate violation the company might claim they knocked the guy off, and he went and worked out so the data is inaccurate as to “working.” (I know, given many of us that’s not very plausible…) And if you’re sitting in a chair for your watch struggling to stay awake, is that data conclusive of “work”? Still, its useful data but with limitations. Also, a disgruntled employee might find a way to manipulate the data to opursue a false whistlenblower claim.


The crew would object about the invasion of privacy. Not hard to imagine HR tracking how may hours a day the guys spend masterbating, and whether it was on watch or off.


I swear, it was my Shake Weight. . . .


It is illegal for towing vessel deck officers to work more than 12 hours except in emergencies, it’s not just that they’re capped at 12 hours of watch. The rest of the crew has no maximum work hour regulations outside not being allowed to stand more than 12 hours of watch.


Probably, 80 percent of us must work more than 12 hours a day, or we won’t be working at all. That’s just the reality of the situation.


46 USC 8104

“(h) On a vessel to which section 8904 of this title applies, an individual licensed to operate a towing vessel may not work for more than 12 hours in a consecutive 24-hour period except in an emergency.”

“(j) The owner, charterer, or managing operator of a vessel on which a violation of subsection ©, (d), (e), or (h) of this section occurs is liable to the Government for a civil penalty of $10,000. The seaman is entitled to discharge from the vessel and receipt of wages earned.”


On a COI is there any indication as to which subchapter it’s inspected under? The last time I was onboard I couldn’t find one but I could just have missed it.

@jdcavo on a tug (~1,200 GRT) that was previously inspected under subchapter I before subchapter M came out does it also have to meet the requirements of subchapter M since it’s a tug? Does it fall under both subchapters or just one? If just one, which one?


I have wondered about whether tugs could opt to be inspected under Subchapter T or Subchapter I —-instead of —— being inspected under Subchapter M

AHTS have long been inspected under Subchapter I. Same for tugs over 300 GRT.

There are some multipurpose vessels inspected under Subchapter T. For example: Tugs that sometimes are used as crewboats; charter boats that sometimes tow construction barges; landing craft that tow barges, utility boats that also tow barges; etc.

The USCG allows vessels under 99 GRT that would normally be inspected under Subchapter I, to opt into inspection under Subchapter T instead.

I’m not going to get into whether tugs that are pumping fuel to other vessels could be, or should be, inspected under Subchapter D.

I hven’t really thought about whether a tug might be required to be inspected under multiple Subchapters. Or whether the owner’s might seek inspection under multiple Subchapters.


I don’t know. I have minimal (i.e. none) involvement with Subchapter M. Try asking these guys.


Summary of recent TSAC meeting and discussion on SubM among other things : They have a PDF on subM on if you follow the page. Its 68 pages in length.


I found a PowerPoint from AWO entitled Subchapter M: What you need to know.

Applicability: All US flagged towing vessels

  • Vessels less than 26 ft in length unless moving a barge carrying oil or hazmat
  • Assistance towing vessels
  • Workboats operating within worksite
  • Sea going tugs greater than 300 GRT
  • Other inspected vessels that perform occasional towing


Subchapter M at a Glance * a recentWorkboat Magazine article.

Subchapter M became law on June 20, 2016 creating a comprehensive towing vessel safety system that includes company compliance, vessel compliance, vessel standards and oversight.

The rule, with exceptions, applies to all U.S. flag towing vessels 26 feet or more and those less than 26 ft moving a barge carrying oil or hazardous material in bulk. It lays out inspection criteria as well as new equipment, construction and operational requirements for towing vessels.

The rule affects approximately 5,500 towing vessels engaged in pushing, pulling or hauling and the 1,096 companies that own or operate them. Towing vessels not covered by the rule include those inspected under Subchapter I, workboats and recreational towing vessels.

The annual cost to the towing industry for Suchapter M compliance will be $32.7 million, according to the final rule published in the Federal Register. Government costs are expected to be $8.8 million per year.

Based on the mitigation of risks from towing vessel accidents in terms of lives lost, injuries, oil spilled and property damage, the rule is expected to yield an annual net benefit of $4.9 million per year.