Mark Sawyer with Marine Compliance Alliance. (Photo by Shelley Byrne)
Subchapter M

Workshop Focuses On Subchapter M Drydockings

Nearly 160 people representing about half the vessels in the Coast Guard’s Eighth District learned more about requirements for Subchapter M credit drydock inspections and internal structural exams—and that more Coast Guard guidance is coming—during a workshop August 11 in Paducah, Ky.

Marine Compliance Alliance hosted the workshop, which included speakers from the Coast Guard, National Towing Vessel Center of Expertise, shipyards and Subchapter M third-party organizations (TPOs).

Marine Compliance Alliance was formed in 2019 by compliance professionals wanting to establish a forum to discuss inland marine regulatory compliance, said Mark Sawyer, executive director.

A video recording from Rear Adm. Richard Timme, commander of the Eighth Coast Guard District, opened the workshop. He noted that with nearly 5,000 vessels with certificates of inspection, including more than 3,000 in the Eighth District, the challenge now turns to Subchapter M’s requirements for credit drydock hull inspections and internal structural exams.

“This is changing the culture of the industry and the expectations for shipyards and their customers,” Timme said. “Furthermore, the Sub M Western Rivers’ fleet is statistically a little bit older than other inspected vessels. For these reasons, I appreciate and understand the concern and uncertainty on behalf of the industry that are being brought up. There are issues to address with Coast Guard and TPO consistency with standards application, shipyard availability and risk-based criteria, among others.”

Timme said his staff and he understand those concerns and are committed to ensuring open lines of communication across the agency, with industry and with providing expectations to Coast Guard units and TPOs.

“We are in the process of developing a repair guidance,” he said.

The forthcoming repair guide will include applicable standards, best practices, general best policies and expectations.

“It may not address every circumstance, but it’s intended to provide a solid framework for addressing ambiguity,” Timme said.

He added that continued dialogue will be required, “and we’re committed to working with the fleet on this challenge as we have been since the beginning of the bridging strategy.”

He concluded by saying he understands the industry’s crucial role both in national defense and the national economy.

“I fully support this initiative as a step in moving forward in maturing the Subchapter M framework, and I appreciate that this event is bringing such a diverse group of interested parties together to facilitate a common understanding of the challenges we have moving forward and the possible courses of action,” Timme said.

By The Numbers

There are 4,723 inland towing vessels, according to information provided by Lt. Commander Terri Parris of the National Towing Vessel Center of Expertise.

Of those, 3,244 of the vessels are within the Eighth District.

Current data showed 4,497, just over 95 percent, have effective COIs. Of that number, 3,015, or 67 percent, took the Towing Safety Management Systems (TSMS) option, and 1,482 took the Coast Guard option.

In the Eighth District alone there were 3,148 vessels with a COI since 2018, and 2,359—75 percent—took the TSMS option with the remaining 789 taking the Coast Guard option.

Steve Douglass, Midwest technical adviser with the National Towing Center of Expertise, noted that through the COI process the inland fleet went from roughly 6,000 vessels to about 4,700 vessels. Some database entry errors were discovered. Some vessels went to South America, he said. Some were scrapped.

Because the available information on all types of vessels can be overwhelming, Douglass clarified which policy documents are associated with inland towing vessels and should be referenced for guidance.

While the Coast Guard’s Marine Safety Manual refers to all types of drydock inspections and internal structural exams, Douglass pointed workshop participants to Marine Safety Volume II, section B, chapter 3, which begins on page 270, for inspected towing vessels.
Additionally, he also referred to the section of the Coast Guard regulations governing documenting vessel compliance under the TSMS option, 137.305, and reminded them that when a vessel changes hands there must be a change of documents.

The other documents companies will need to refer to are the Navigation and Vessel Inspection Circulars (NVICs). Notes on inspection and repair of steel hulls are in NVIC 7-68. Information on rules pertaining to fixed ballasts are in 5-82.

Additionally, he said, “Each TPO must retain results of the survey audit for five years.”

The Coast Guard has the authority to inspect the records.

“As long as we can follow that trail, the vessel stays in compliance,” he said.

Dale Metcalf, Third Party Oversight Coordinator at USCG Sector Upper Mississippi River, pointed out that if a vessel changes from one TSMS to another or from one option to another option, it must have a new COI, but the date requirements for the drydock hull inspection do not change.

Finally, Douglass urged visiting the TVNCOE’s Tugsafe website at and using the TugSafe job aid before a Coast Guard or TPO inspection. Those using the site should enter all of a vessel’s information to receive the right guidance, he said. The site also includes compliance requirements and free online training.


In another of the morning sessions, Jill Bessetti, Eighth District towing vessel coordinator, Capt. Alan Moore, Eighth District chief of prevention, and Geoffrey Scibek of Marine Safety Unit Huntington spoke about enforcement following the COI deadline and gave further information about the Inland Repair Guide that will be coming.

Moore said Marine Safety Unit Houma had issued 468 COIs, the most in District 8, followed by Sector New Orleans with 438.

In looking at unresolved deficiencies due to phase-in noncompliance, there have been 236 overall, with 91 of those in the Eighth District.

There have been 77 “Code 60s,” which prohibit vessels from further movement, issued since July 19, he said. Of those, 38 have been in the Eighth District.

Inland River Repair Guide

Bessetti said the forthcoming Inland Repair Guide will serve as guidance to Coast Guard inspectors and Coast Guard approved TPOs conducting credit drydock and internal structural exams on Eight District inspected towing vessels operating exclusively on a rivers route.

“While we have a lot of guidance already, some of it is not specific to the river industry,” she said.

She added, “We’re hoping this guide will serve as a starting point in determining threshholds on inspection standards,” but added that it should not be the only criteria used. Additionally, she said, companies operating under the TSMS option should work closely with their TPO.

Among the questions the Coast Guard is talking about internally and would like industry feedback on before the guide is issued is, “Should drydock inspection dates continue to be on all COIs?”
Also, she asked if some hull requirements are too strict on river vessels. A key question is, “When should hull gauging be required from the Coast Guard?”

Other major questions to be addressed include how the Coast Guard will determine when an inset needs to be cropped and renewed and when a tail shaft must be pulled.

“I know a lot of you have your own company practices on that, so I’m looking to take some feedback on this,” Bessetti said.

She also asked for industry to send in specific questions that are not addressed in current guidance so that they can be added to the draft of the Inland River Repair Guide draft.

“Just know we are working on consistency, and we’re working on practical applications, and we’re really happy to be at this workshop and to garner your feedback,” she said.

Scibek provided information on who will attend drydock inspections and the scope of a credit drydock, which requires that a vessel must be hauled out or placed in a drydock or slipway. How long a vessel needs to remain there will depend on its condition.

“Some of them can be as short as a day,” he said. “Some of them could take eight months.”

Internal structural exams, in contrast, can take place with the vessel afloat or on dock. The exam includes examination of the main strength members, internal framing, hull plating, ballast, cargo and fuel tanks. Sections of lining and ceilings may need to be removed.

“It’s basically a crawl of the hull,” he said.

When COIs are renewed, the Coast Guard does plan to be present.

“Usually it is a walkaround and look at logs [for TSMS option vessels],” he said.

Workshop attendees gave feedback that they would like the Coast Guard to consider staggering inspectors’ availability and more flexibility in general so as to prevent any length delays of a vessel’s movement.

“We understand that you are a 24/7 service, so all we can do is schedule it, and we’ll try to be there,” Scibek said.

Scibek also noted that inspectors are finding a lot of “temporary” repairs.

“Some of them have been there a long time,” he said.

If one is needed, he said, “Come up with a plan and document it.”

Finally, Scibek said that while the officer in charge of marine inspections (OCMI) will be able to approve an extension of the deadline for drydock inspections for up to a year, “The Coast Guard does not generally entertain drydock extensions unless there are extenuating circumstances. Those cannot be purely financial reasons and also not lack of planning.”

Best Practices For Third Party Oversight Coordinators

In preparing for drydock inspections and internal structural examinations, Metcalf said one of the things that really helps is when there is a central location for certain documents companies know inspectors will need to see.

What we have found that works well is what we see on foreign vessels all the time,” he said. “It’s just a binder.”

While some companies have moved paperwork to a digital format, it can be hard to track down when inspectors need it, he said.

Panelist Nick Myers, TPO coordinator for Sector Ohio Valley, also noted that some vessels don’t immediately have the credentials of off-watch merchant mariners, including their TWIC cards, readily available, which can cause delays.

Panelist Jason Buckmaster, TPO coordinator for Marine Safety Unit Houma, said companies should conduct a pre-walkthrough and write down anything they notice is wrong, listing and gathering worklist items well in advance of a credit drydock.

Metcalf added, “If you haven’t looked at your vessel and know what you’re expecting until the Coast Guard goes out there, you’re woefully unprepared, and you’re going to be in for a shock.”

Myers added that while the Coast Guard is not required to attend the drydock hull inspection if using a TSMS internal survey option, the Coast Guard must be advised of the inspection and Coast Guard can consider attending, although granted the internal survey option still falls under the TPO’s oversight. Those using an external survey option do not have to notify the Coast Guard.

One of the questions that come up frequently is how to approach existing doubler plates. Metcalf said there are some ways doublers can be accepted, but those involved with the vessel should be able to answer, “Why do you want to keep this doubler here?”
While determinations can be made on a case-by-case basis, Metcalf said there have been a lot of issues of fuel or water being stuck behind such plates.

“But, at the same time, as a rule, we don’t accept doublers as permanent repairs,” he said.

Other issues discussed included guidance on wastage.

While the guidance in NVIC 7-68 is a 25 percent allowance in side shell, “Get me some analysis,” if a company thinks it should be allowed differently for some reason, Metcalf said. “Get me something that says why you think there should be 40 percent wastage there.”

The company should also come with a plan, he said.

Inspectors are also going to be looking at what might be a short-term repair versus what makes sense for the life of the vessel.

“If you have any justification, like planning on doing extensive repairs soon, and it doesn’t impact safety with fuel, engineroom and people, we can sometimes take it as an exception,” he said.

He also pointed out there is an appeals process.

“I know everybody asks for consistency all the time, and we try to do it,” he said.

For those seeking special consideration, he said, “Make it easy to say yes. The more information you have, the easier it is.”

Additionally, he said, giving as much notice as possible is helpful, and companies asking for consideration should provide documentation.

Another topic that comes up frequently concerns overbuild/as-built scantling.

“If you suspect your vessel is [overbuilt], do your research and prove it,” Metcalf said.

Shipyard Availability

A panel of representatives from shipyards representing about 100 drydocks throughout the country addressed questions about availability.

Several said their current problem is available employees, not drydock space.

“Our shipyards have been running about 90 percent of what we have available today,” said Bill Foster, representing McGinnis. “I could add several hundred welders and fitters and go to additional shifts and add capacity.”

Barry Gipson of James Marine agreed, saying, “Having all the capacity in the world but none of the workers doesn’t do us any good.”

Eric Bollinger with Bollinger Shipyards said supply chain issues continue to be a factor as well, especially with Z-drive boats.

“It’s tough,” he said.

Scott Theriot, representing Southwest, said the company is constantly calling major vendors and asking what the lead times are for things like welding rods and certain types of work gloves. It is difficult to lock in prices and schedules with the costs of materials changing frequently and sometimes not being able to get certain supplies at all.

 Gipson was among those saying that the best advice is for owners to maintain a close relationship with a shipyard. Foster said that should include what is going to fit and when.

“Routine conversations among all of us will just help with clarity about what is going to happen,” Foster said.

Bollinger said he knows one company is now doing its budget in the fall and then pencils in its planned drydocks for the next year.

The shipyard representatives stressed that they will do the work an owner wants done, but the owner should know what the Coast Guard requirements under Subchapter M are for the work.

Bollinger and Josef Vlach of Western Rivers Boat Management both said the most important part of preparing for drydock inspections is to have a good idea of the scope of work before the vessel goes on the drydock. Additionally, companies should plan well in advance and consider scheduling drydocks throughout the year rather than stacking shipyard work only during certain seasons.

TPO Panel

A panel of representatives from third-party organizations was a major afternoon draw in the workshop.

When talking about the biggest challenges ahead, Lee Nelson of iTow said there is a knowledge gap at some companies where they do not yet have an expert who is going to get a vessel repaired according to all the regulations.

Rob Keister of Sabine Surveyors agreed.

“The first five years it’s all about being in compliance to get the COI,” he said. “Usually there are one, two or a half dozen people working on compliance. Once we get into drydock, that’s often a completely different group of people dealing with Sub M with not as much exposure to TPOs and Sub M compliance.”

Keister said in scheduling it is a good idea to get the internal structural exam long before drydocking because it gives a much better idea of what the vessel’s needs are long before it goes on the drydock.

Nelson said that, much like when the COI process started, right now the vessels coming in for drydock hull inspections and internal structural exams first are the best of the best.

“But we know what is coming,” he said.

Common issues reported so far have been with deck hatch seals, broken cooler guards and internal, non-critical frames.

“I’ll be quite frank with you,” he said. “I think our work is just now beginning and that what we have done so far is minute compared to what is coming.”

Additionally, he said, while it was reassuring to hear from shipbuilders, he said he thinks companies, and especially smaller ones, could have trouble finding drydock space as needed.