Subchapter M – Parts 136 through 144, Title 46 of the Code of Federal Regulations (CFR) - came into effect for the towing vessel fleet in the United States on July 20, 2018. Regulation 46 CFR 136.202 outlined a phase-in period for operators to have their applicable towing vessels inspected for compliance with the requirements within Subchapter M. The phase-in schedule was for twenty-five percent (25%) of the towing vessels to be initially inspected and compliant with Subchapter M each year, so that by July 19, 2022 all applicable towing vessels would be inspected. July 20, 2020 marked the halfway point towards verification of compliance. Within Subchapter M, delegation of certain inspection and compliance verification was given to qualified Third Party Organizations (TPO). This paper intends to give the progress towards compliance with Subchapter M from the perspective of a TPO. This paper will address how the TPO works with both the United States Coast Guard (USCG) and the operator, how the cooperation between the TPOs and USCG has progressed, how well operators have been progressing towards compliance with Subchapter M, trends in meeting the compliance requirements by operators, and a forecast into future trends for compliance.

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