Maritime Compliance Report
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Subchapter M Final Rule
At a recent conference some interesting information was passed regarding Subchapter M. The Coast Guard has posted on the regulatory agenda, a date of September 2014 for the release of the Final Rule for Subchapter M - Towing Vessel Inspection Regulations.
While many are already aware of this date, it is interesting to note that Subchapter M is expected to be released as a Final Rule. Many had speculated that due to the large volume of comments, that Subchapter M may be changed significantly and therefore put back out for further comments. But, based upon the current information, when it is published, the rule will be final.
Additionally, the Coast Guard passed on that interested parties should become intimately familiar with the Notice of Proposed Rule Making (NPRM) which is available for viewing in the Federal Register. Reading between the lines, one might conclude that while changes will surely be made, the NPRM may not be far from the Final Rule once published. While it may not be time to invest great sums of money in order to get ready, it is certainly time to read the NPRM if you haven't done so already. If you wait for the Final Rule before you start figuring it out, you will surely end up behind the learning curve.
While many are already aware of this date, it is interesting to note that Subchapter M is expected to be released as a Final Rule. Many had speculated that due to the large volume of comments, that Subchapter M may be changed significantly and therefore put back out for further comments. But, based upon the current information, when it is published, the rule will be final.
Additionally, the Coast Guard passed on that interested parties should become intimately familiar with the Notice of Proposed Rule Making (NPRM) which is available for viewing in the Federal Register. Reading between the lines, one might conclude that while changes will surely be made, the NPRM may not be far from the Final Rule once published. While it may not be time to invest great sums of money in order to get ready, it is certainly time to read the NPRM if you haven't done so already. If you wait for the Final Rule before you start figuring it out, you will surely end up behind the learning curve.
The regulatory agenda will be updated in August. That will be our next opportunity to get a Subchapter M update. Stay tuned.
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