A full day and many phone calls later, I’m not much smarter about Subchapter M than when I started my quest. What I do know is there are more changes coming as the USCG refines different articles for more clarity. The best advice – and I say that loosely – is to contact your local USCG unit and ask for a detailed SubChapter C. This report is known as the Uninspected Towing Vessels (UTV) Exam which covers parts 25 and 27. They will tell you what you’re missing. Then you can determine if you’ll stick with the CG to help you become compliant for your certificate of inspection (COI) or if you’ll go through a third-party operation (TPO) to get it done. If you’re a small boat company with 1 – 5 boats, don’t panic, there are companies out there to help you. One company I talked with at the Workboat Show was Kheiron.
Kheiron helps boat companies get a handle on their safety management system. They help you put it together and maintain it. “The owner’s like a one man show,” says Shane Istre, owner of Kheiron. “They’re not big enough to justify a full-time safety compliance person so we can come in just a few hours a month and take care of all their safety needs.
There are lots of companies out there available to help boat companies get ready for Subchapter M. But few who work with the mom and pop companies that make up the largest amount of boat businesses.
Part of Subchapter M is all their employees must have safety and compliance training. Come mid-2018 if they don’t the CG could tie their boat(s) up right where it sits with all the cargo on it until they’ve met compliance. This could prove to be extremely expensive based on the contract you have with your customer.
“We try to keep them in check with the CG,” says Istre. “Especially with all the new regulations coming up.” The process is as simple as getting a gap analysis done. The first step is to have your compliance person meet with them. They’ll go through any documentation you may or may not have or currently tracking and asses what you’re doing.
Next, they do a needs analysis. This shows what things you’ll need to do monthly to stay in compliance. From there the duties get separated. For example: you, as the boat business take on as many tasks you feel you can handle. Kheiron takes on the remaining tasks.
Istre’s longtime business partner, Rene Cheramie, is a third-generation towboat owner. His family’s been a small business for a long time. He knows what’s involved and how to help other small tugboat companies stay or get into compliance. “We have an a la carte service,” says Istre. “It’s not a fixed cost. We work within the boat owner’s budget, keeping the cost down. This keeps the boat owner running his business, not on the boat.”
Haven’t started preparing for Subchapter M yet? It would behoove you to do so; before June 2017. The process as it stands right now could take up to 18 months. Possibly more once the Coast Guard refines things.
Other services Kheiron provides is a state-of-the-art Learning Management System (LMS). This consists of at least 30 maritime courses. The LMS works well to get your crew trained while they sit in the hotel or at home waiting for their next gig. So, don’t take a chance. Contact Kheiron at: http://Kheironllc.com.