Subchapter M

AWO Requests Subchapter M Inspection Suspension During Coronavirus Emergency

March 21, 2020 By David Murray

As part of its response to the coronavirus crisis, The American Waterways Operators formally requested March 18 that the Coast Guard suspend in-person Subchapter M inspection activities for at least 30 days. Since such a suspension will affect the July deadline by which operators of more than one vessel must have obtained certificates of inspection (COIs) for at least 50 percent of their vessels, the AWO asked that the Coast Guard reconsider that deadline as well.

The letter, signed by Jennifer Carpenter, AWO’s president and CEO, stresses that the request was made out of regard for the health and safety of towboat crews, and for Coast Guard personnel as well. “Consistent with guidance from the Centers for Disease Control and other public health authorities, the primary way in which exposure risks can be reduced is by minimizing interactions between vessel crewmembers and non-crewmembers. We know that the Coast Guard is likewise prioritizing the health and safety of its workforce as it works to maintain mission readiness. During this critical period for slowing the spread of COVID-19, we can work together to protect our respective personnel by deferring close contacts between them when life, the environment and property are not at immediate risk.”

The letter recommends that the suspension be reconsidered at the end of the 30-day period, and, if necessary, renewed. “Our letter notes that such a suspension may necessitate the reconsideration of the requirement under 46 CFR 136.202 that by July 20, 2020, operators of more than one towing vessel must obtain COIs for 50 percent of their fleet. These steps are aggressive, but we believe—based on our conversations with you—that it is necessary for the Coast Guard to take timely, decisive action at the national level to protect our respective workforces and the supply chain, minimize confusion and ensure consistency.”

Carpenter said AWO members are also working with the Responsible Carrier Program Standards Board, its third-party auditing partners and the Coast Guard to provide audit due date flexibility for AWO members who are implementing the Responsible Carrier Program. The AWO held a webinar for members on all the issues associated with COVID-19 preparedness on March 19.

The letter’s full text may be read on the AWO’s website.