Subchapter M is a little more than a year away from being fully in effect for most commercial towing vessels over 26 ft. Towing vessel operators who have been actively preparing for Subchapter M will be in a better position than those who are just now starting to sort out what this comprehensive regulation means for them. All towing vessels subject to the regulation will need to be in full compliance with the requirements of the regulation by July 18, 2018. Subchapter M requires covered towing vessels to obtain a certificate of inspection (COI) to be able to legally operate their vessels. The United States Coast Guard (USCG) will begin to issue COIs in July 2018. Recognizing that it will take many months before the USCGcanissue a COI for every towing vessel subject to the regulation, operators are required to obtain a COI for all of their vessels within four years, at a phased-in rate of 25% per year.
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