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Business 241 views Sep 09, 2020
Subchapter M – Manning requirements

Subchapter M brings a new regime to inland water vessels on US waterways that they previously did not have to deal with. While the statement may come across as negative Subchapter M as a whole has been a positive regulation for many stakeholders on the waterways. It essentially calls for measures to be implemented to enable safer operations along the waterways. As a part of the regulations are the new manning requirements for vessels.

Under Subchapter M, 46 CFR 15.405, every credentialed mariner employed aboard must be provided with familiarization training of two kinds. The first includes familiarization with their duties and responsibilities prior taking them on. This would also include familiarization with all the equipment they would need to operate. A second familiarization includes training in the lifesaving and firefighting equipment aboard the vessel. They must also be made aware of their emergency stations. While the CFR does not specifically specify a timeline, it is recommended that this be done within 24 hours of the mariner joining the vessel, in keeping with international best practices.

Certification requirements for crewmembers, per subchapter M, include requirements for credentialing as able seamen, QMEDs and ratings forming part of a navigational or engineering watch. In addition, proficiency credentialing for lifeboatmen, fast recue boat, person in charge of medical care, medical first-aid provider, GMDSS radio operator and credentials for entry level personnel will be required. Details related to these can be found in 46 CFR 15.404.

It is important that the operators take measures to ensure that personnel serving aboard their vessels are complaint with the above requirements.  In addition, it is recommended that periodic, regular health checks be conducted for all seafarers. There have been many cases where poor health and fitness led to an untimely incident that resulted in great losses for a company. Familiarization in itself may seem a minor thing to be done and often may not get done diligently. History, however, has shown us lessons from numerous accidents where vessels were involved in an incident less than 12 hours after departing port.

Subchapter M also sets out the requirements for watchkeeping and working hours as applicable to vessel type. All the above will initially get implemented owing inspections done either by the USCG or an approved TPO. However, the intent of subchapter M is in essence to allow towboat operators to self-regulate. It is not the intent to police unless the need to do so arises. Safe waterways benefit all concerned and in a major economy like the United States is a hug contributor to the economy. A shutdown of a major waterway can severely impact the economy. People enable the systems aboard and need to be competent for the system to be successful.



Tags: #Subchapter M