Subchapter M

That have me the idea to look up where they get that information and I found it.

46 CFR 136.105 Applicability.

(a) This subchapter is applicable to all U.S.-flag towing vessels as defined in §136.110 engaged in pushing, pulling, or hauling alongside, except —

(4) A seagoing towing vessel of 300 gross tons or more subject to the provisions of subchapter I of this chapter;

(5) A vessel inspected under other subchapters of this chapter that may perform occasional towing;


Recent SubM article on marinelink dated March 27, 2018 if anyone has interest:

“another compliance issue that frequently arises pertains to the clarification of the manning requirements posted on the COI. As this is to be determined by the OCMI, the TPO is not permitted to suggest safe manning levels for towing vessels. Hence, vessel owners going the TSMS route are encouraged to consult Marine Safety Manual Volume III and their local OCMI to establish this.”

Another recent SubM article discussing the legal ramifications/liabilities associated with the new regs:

Old post, I know, but I just happened across this while looking for other things. Our Sub M COI reduced our manning for voyages over 600nm from 1 master, 2 mates, C/E, 2 Ab’s, and 1 OS down to 1 Master, 1 Mate, 2 Ab’s, and 1 OS. No engineers and no three watch system.

Is the tug under 200 GRT?

It’s 195 GRT.

Do you mean 100 GRT? 46 US Code 8104(d) excludes vessels under 100 GRT from having 3 watches.


Vessels less than 200 GRT are exempt from the Officers’ Competency Certificates Convention, 1936.

From the last half of 46 CFR 15.705 (d)

“The Coast Guard interprets this, in conjunction with other provisions of the law, to permit masters or mates (pilots) serving as operators of towing vessels that are not subject to the provisions of the Officers’ Competency Certificates Convention, 1936 (see 46 U.S.C. 8304), to be divided into two watches regardless of the length of the voyage.”

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Even if the boat is SOLAS and the international tonnage is over 500? This topic is kind of parallel to the other topic I just started yesterday.

ITC tonnage does not matter in the US. The only thing that matters is US GRT, sometimes know as “US regulatory tonnage.”

There are plenty of 100’ to 150’ , 4000 to 6000hp US tugs that are only 99 GRT.

99 GRT or less means: no MMC or Twic card or medical card required for the deckhands and engineer. The owners can hire anyone off the street. Just the Captain and mate must have MMCs with the proper endorsements.

The USCG is routinely issuing Subchapter M certificates of inspection for tugs under 200 GRT that only require a four (4) man crew. That’s only two watches, and it makes 12 hour days damn near impossible. Everyone is routinely over 12 hours.

Under 200 GRT also means that STCW does not apply.