46 CFR Subchapter M Towing Vessel Regulations: An Expert’s Perspective

Historically, the majority of towing vessels in inland and coastwise service are classified as “uninspected vessels.” Although inland and coastwise towing vessels are regulated by CFR, there are no requirements that they be classed and inspected like ships. The USCG has drafted Subchapter M Proposed Regulations for Towing Vessels that, when enacted, would require the approximate 6,500 towing vessels longer than 26 feet in length to be USCG inspected.

​Back in the day, I was Chief Engineer on an ocean-going tug. On board, we said “The 80/20 rule applies [to our work] - 80 percent sheer boredom / 20 percent sheer terror.” Some days it was the other way around.

Today, the “terror” component of that anecdotal paradigm has a more prodigious and formulaic name: RISK.

Risk combines the probability of some event occurring during a time period of interest and the consequences (generally negative) associated with the event.

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Originally printed in the ABA Tort Trial & Insurance Practice Spring 2014 Newsletter

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