Social distancing requirements due to the coronavirus have made in-person inspections and audits of vessels extremely difficult. To help companies meet Subchapter M requirements, the U.S. Coast Guard has approved remote inspections and audits. In addition, companies can ask for a 90-day extension from their July due date if necessary. Companies should contact their officer in charge, marine inspection (OCMI) to apply for an extension, which will be approved on a case-by-case basis.
Remote methods can include video conferencing and electronic submission of photos, audit reports, recent classification surveys and vessel logs. The Coast Guard also has the option to board a vessel following protective guidelines from the federal Centers for Disease Control and Prevention. The Coast Guard’s Marine Safety Information Bulletin 09-20 contains the specifics for remote work.
Towing companies have two options to comply with Subchapter M: annual Coast Guard inspections, or the use of a towing safety management system (TSMS) approved and verified by a third-party organization (TPO).
Subchapter M requires that companies get a certificate of inspection (COI) for 50 percent of vessels in their fleet by July 20, 2020. COIs must be obtained for 75 percent of the fleet by July 19, 2021, and the entire fleet has to be inspected by July 19, 2022. The COI is good for five years, but vessels must be re-inspected by the Coast Guard or resurveyed by a TPO each year. There are about 5,500 towing vessels in the domestic industry.
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