rss icon Subscribe
desktop mobile

SubM Deadlines Looming Large

File Image (CREDIT: AWO)

USCG RADM John Nadeau

Subchapter M - Only a few days left to schedule inspections to meet July 22, 2019 compliance requirements. Rear Adm. John Nadeau, assistant commandant for prevention policy, weighs in on options and instructions.

As of July 20, 2018, towing vessel owners and operators are responsible for ensuring that their vessels comply with the provisions of 46 CFR Subchapter M, even if they have not received a Certificate of Inspection (COI). Additionally, in accordance with 46 CFR 136.202, owners and operators are responsible for ensuring that 25 percent of their fleet has received a COI before July 22, 2019.

46 CFR 136.210 requires the owner or operator to schedule inspections for initial certification with the local OCMI at least 3 months in advance of the desired inspection date. Consequently, towing vessel owners and operators must schedule a vessel's inspection before April 22, 2019 if the COI is expected to be received in the first year. In addition, at least 30 days before the inspection, the owner or operator must submit a completed CG-Form CG-3752, "Application for Inspection of a U.S. Vessel," (new construction vessels use CG-3752A) to the OCMI indicating if the Coast Guard or Towing Safety Management System (TSMS) option will be used to meet these requirements.

Given that COIs must be issued to approximately 1,250 towing vessels during this first year of the phase-in period, and another 2,000 during the 2019-2020 phase, close coordination between owners and operators, Third Party Organizations (TPOs), and the OCMIs is necessary to reduce delays to the towing industry. If you have not already done so, I highly encourage you to make contact now with the local OCMI that will be conducting the vessel's initial COI and schedule an inspection date. While we understand the dates may shift due to operational obligations, a tentative date will help the Coast Guard manage resources to ensure a marine inspector is available. When scheduling an inspection, please indicate whether the vessel will be using the Coast Guard or TSMS option.

The phase-in period is provided to spread the workload and cost over time, and mitigate impacts on vessel owners and operators, TPOs, OCMIs, and other stakeholders. Failure to meet the regulatory phase-in schedule could result in vessel and other operational delays, civil penalties, or other possible enforcement actions.

Lastly, owners and operators are reminded of their ability to use a TPO to help them obtain a COI in accordance with Subchapter M and, as provided by CG-CVC Policy Letter 17-01, to take advantage of the uninspected towing vessel decal they may have previously obtained as part of the bridging program. Possession of a decal may eliminate the need for a Coast Guard inspection prior to the issuance of a COI. Owners and operators are strongly encouraged to contact their local OCMI and discuss these matters further.

Apr 19, 2019

 

Legal

Pacific Radiance Wins Case Against Chinese Yard

Image: Pacific Radiance

Singapore-based offshore vessel operator Pacific Radiance has won an arbitration award against a

Improper Crane Use Caused Crew Death -USCG

Inadequate training and improper shoreside crane operations were found to be the cause of a fatal accident earlier this year in the US Coast Guard buoy yard in Homer, Alaska.

Golar Spins Off TFDE LNG Biz

Pic: Golar LNG

Liquefied natural gas (LNG) shipper Golar announced that it has decided to proceed with a spin-off

Shipbuilding

Teekay Gets $450mln for Shuttle Tanker Fleet

Pic: Teekay

The midstream services provider to the offshore oil production industry Teekay Offshore Partners

Columbia Class Subs Take Shape in Virginia

A plasma-burning machine cuts the first steel plate that will be used to build the ballistic missile submarine Columbia (SSBN 826). Photo by Matt Hildreth/HII

A plasma-burning machine cut the first steel plate that will be used to build Columbia (SSBN 826)

Shipowners See Increase in IMO-Compliant Fuels, But Doubts Persist

Shipowners, who are facing one of the biggest changes in the oil industry in decades, are seeing more fuels that will be compliant with new rules on sulphur emissions from ships

Maritime Apps