Subchapter M At 10: Building A Maritime Safety Culture
Ten years after Subchapter M established a federal inspection framework for towing vessels, Tava Foret views the anniversary less as an endpoint than as the beginning of the regulation’s next phase.
Foret, president and co-founder of the Towing Vessel Inspection Bureau (TVIB), said the industry has made measurable progress in safety management, inspection and accountability. The next challenge is ensuring that safety culture reaches every level of an operation, from senior management and shoreside personnel to masters, tankermen and newly hired deckhands.
“It took a long time for this culture of safety to really filter through and get traction,” Foret said. “Now it’s the next evolution. It’s not enough to be aware of it and fix it. Now it’s time to actually prevent it.”
Her involvement in developing Subchapter M gave her a close view of the regulation’s original objectives and the problems it was intended to solve.
“I have the 17 years before that it took to get the regulation,” she said. “My knowledge is what was intended, what were the goals, what were we going to do and what problems were we trying to solve.”
TVIB grew from those discussions. Its original founders were Tava and David Foret, Mike Rushing and Todd Rushing. Chris Parsonage soon joined the effort, bringing experience from larger towing operations. The group combined liquid- and dry-cargo backgrounds with a distinctly brown-water perspective.
Foret and Rushing attended numerous Towing Safety Advisory Committee and The American Waterways Operators meetings during the regulatory development process. While most participants approached the discussions as operators, Foret and Rushing were often the only auditors in the room.
“People would throw out these ideas, ‘This is great, we should do this,’” Foret said. “We raised the question: That’s great, but how will we audit that? How will we determine compliance with that?”
One early concept envisioned Coast Guard-certified auditors operating independently. That raised concerns about consistency. If dozens of auditors interpreted the requirements differently, effective implementation would be difficult.
Foret said one concern during Subchapter M’s development was how approaches rooted in blue-water operations would translate to the inland towing industry. TVIB was formed in part to bring a brown-water operational perspective to the new inspection regime and later became a Coast Guard-approved third-party organization.
For Foret, that role requires balancing the needs of operators with regulatory requirements. “While you are my customer and I want your input, I also have to balance that against the regulatory requirements,” she said. “Honestly, it’s about education more than it is policing.”
TVIB now has more than 45 certified auditors and more than 55 certified surveyors, Foret said. It also oversees internal survey programs used by many customers. Foret estimated that TVIB represents roughly one-third of the vessels operating under the Towing Safety Management System (TSMS) option.
Subchapter M Adds To Coast Guard Workload
Subchapter M added significantly to the Coast Guard’s marine inspection workload even as the marine inspector workforce declined.
In 2017, 905 marine inspectors conducted 18,424 inspections, including 368 inspectors in District 8. By 2024, the workforce had fallen to 768 nationally and 313 in District 8, now the Heartland District, while domestic vessel inspections increased to 21,187.
Subchapter M accounted for 4,259 inspections in 2024, with 6,172 deficiencies identified and a reported towing vessel deficiency rate of 1.27 per vessel.
The inspected towing vessel fleet has also declined, from 7,403 vessels in 2018 to 4,927 in 2024. By August 2026, the Towing Vessel National Center of Expertise placed the fleet at approximately 4,660 vessels. Of those, 3,222, or about 69 percent, operated under the TSMS option.
TVIB reviews more than 1,000 annual survey reports each year. Average survey deficiencies declined from about 18 per vessel in 2018 to about three in 2023 and have remained near that level. Vessel audits generally average one to two findings.
The data points to a more mature compliance system, while recurring findings in maintenance, testing, lifesaving equipment, electrical systems and documentation show that continued improvement remains necessary.
That persistence points to a distinction Foret believes should guide the industry’s next stage: the difference between correction and corrective action.
Replacing a deteriorated life ring or repainting worn vessel identification corrects an immediate deficiency. It does not necessarily address why the problem recurs. When the same issue appears repeatedly across a fleet, management should determine whether equipment selection, inspection frequency, maintenance procedures, training or accountability needs to change.
“What are you going to actually do to resolve it?” Foret said. “If you don’t ever solve the issue, then you’re just playing cleanup all of the time.”
Conducting a root-cause analysis for every minor deficiency would be impractical, Foret acknowledged. A more useful approach is to use annual management reviews and fleetwide data to identify patterns. A single finding may be routine, but the same finding across several vessels or successive years may indicate a systemic problem.
That process requires involvement beyond the vessel. Larger companies increasingly employ compliance officers and safety, quality and environmental personnel to track findings, deadlines and corrective-action plans. Smaller and midsize operators may rely on outside consultants.
The strongest systems, Foret said, do more than satisfy the minimum requirements. They use Subchapter M and the TSMS framework to drive continuous improvement.
“Complying with the regulation is not inherently hard, but if you really want to get to the intent of the TSMS option specifically, then that’s where that continuous improvement aspect really needs to take hold,” she said.
The same principle applies aboard the vessel. A safety management system cannot function as a binder on a shelf or a collection of electronic files. Mariners must understand their responsibilities within it, and those responsibilities change as they advance.
A new deckhand needs a practical introduction to company procedures and reporting expectations. A lead deckhand, tankerman, steersman and master each assumes a different level of accountability. Shoreside managers, port captains and designated personnel ashore must also understand how their decisions support or weaken the system onboard.
“Crews are always evolving,” Foret said. “They need to know what their role is now that they’ve moved from deckhand to lead deckhand or tankerman, or moved into a steersman’s program. How does my role within safety management evolve?”
In response to customer requests, TVIB has been developing a Subchapter M 101 course for masters. The program is intended to explain how operating a vessel with a certificate of inspection (COI) changes a master’s responsibilities. Topics include operating within the COI’s limitations, understanding potential licensing consequences and knowing when to contact the designated person ashore.
Some operators have suggested introducing the material during steersman training, before a mariner reaches the wheelhouse. Foret said that reinforces the need to build safety culture progressively rather than waiting until an employee assumes command.
“You don’t really hire for the deck plate; you hire for the wheelhouse,” she said. “You hope that at some point that green deckhand you hired is eventually in the wheelhouse. Their role is going to change and evolve. They take many steps along the way.”
For TVIB, the next decade will include expanding education beyond auditor and surveyor certification while maintaining enough qualified personnel to replace those approaching retirement. The larger goal remains unchanged: applying Subchapter M in a way that improves operations and protects mariners.
“We’ve never been about just checking a box,” Foret said. “We want to show companies what good compliance looks like and how we can help them get there.”
Every audit and survey, she added, is an opportunity to educate vessel crews and shoreside representatives.
“Are we helping them improve versus just complying?” Foret said. “That’s the question.”
Looking Ahead At The 10-Year Mark
At the 10-year mark, the Coast Guard’s draft Navigation and Vessel Inspection Circular proposing to extend the Streamlined Inspection Program to towing vessels raises an important question about the future of Subchapter M oversight.
The regulation has moved well beyond implementation. Over the past decade, the Coast Guard, towing vessel operators and third-party organizations have developed the systems, processes and experience needed to support Subchapter M and the TSMS option.
The draft NVIC would introduce another approach to oversight for qualifying operators, with an emphasis on modernization, risk-based inspection and reducing duplication. Those are worthwhile goals, but the proposal also creates an opportunity to evaluate the system already in place.
After 10 years, the industry has enough experience to ask what has worked, what has not and which elements of the current oversight structure have contributed to improved compliance and safety performance.
The larger question is whether parts of that structure can be streamlined without losing the benefits they provide.
Before moving toward another inspection model, the Coast Guard and industry may benefit from first assessing what a decade of Subchapter M has produced and which elements should remain central to towing vessel oversight.
