COLUMN SPECIAL REPORT Countdown to Subchapter M:Last Minute Tips for Choosing the USCG or TPO/TSMS Option from an industry subject matter expert ...By Richard J. Paine, Jr.Subchapter M will ? nally be imple- date can yield the same uneventful Y2K results, if owner/mented in the tugboat and towing in- operators have done their due diligence or at least are pre-dustry in only a few short months. It pared for a strong ? nish. To that end, a few last minute has taken over ten years to arrive, but planning tips can lead to a better result. Understanding the build-up and in some cases, hyste- of how the traditional USCG option and the differences ria, can only be compared to the Y2K offered in the Third-Party Organization (TPO) alterna-scare at the end of 1999. During that tive will impact Subchapter M compliance, in a crowded period, the world said Y2K would cause and growing inspected commercial vessel industry, will computer crashes, commerce to end make all the difference.Paineand daily life to come to a crashing halt.HE OAST UARD PTIONNow, fast forward almost twenty T C G Oyears and enter Subchapter M. The date, July 20, 2018, The USCG option is the traditional method for own-does not have the same media grabbing headliner im- ers/operators to become compliant with regulations and pact as 01.01.2000, but it does remain at the forefront receive a Certi? cate of Inspection (COI). The OCMI (Of-of owner/operators, as well as the United States Coast ? cer in Charge, Marine Inspections) has a dedicated team Guard’s (USCG) attention. However, the Subchapter M of inspectors within each local Sector that performs this Credit: Eric NorcrossMay 201822 MNMN May18 Layout 18-33.indd 22 MN May18 Layout 18-33.indd 22 4/20/2018 10:05:23 AM4/20/2018 10:05:23 AM