46 CFR Subchapter M
Subchapter M — Towing Vessels
compliance, handled.
Subchapter M made towing an inspected industry. For a small fleet without a compliance department, that's an ongoing load — certificates, surveys, credentials, work-and-rest records, and a safety management system that has to be more than a binder. Binnacle AI carries it.
What Subchapter M asks of you
A current COI for each towing vessel — survey and inspection due dates that can't lapse.
Either the USCG inspection option or a TSMS with third-party audits and surveys — recurring external dates either way.
MMCs, TWICs, and medicals, each with an expiry that grounds a mariner — and potentially the boat.
The 46 USC 8104 12-hour rule for towing — distinct from STCW. (Check it with the work/rest tool below.)
Logged on schedule, plus a 46 CFR 16 / 49 CFR Part 40 drug-and-alcohol program.
The TSMS auditor and the Coast Guard both expect to see the evidence, not hear it exists.
How Binnacle AI handles it
- Credential and certificate expiry tracking with lead-time alerts — nothing lapses unwatched.
- Per-vessel COI and survey scheduling in one fleet view.
- Work/rest tracking against the correct towing regime (not STCW where the 12-hour rule belongs).
- An AI document scanner that reads an MMC, TWIC, or medical from a photo — no manual data entry.
- Drill and training logs with the records attached, and OFAC SDN crew screening.
- An audit-ready evidence trail a TSMS auditor or boarding officer can be shown in minutes.
Go deeper
Built for the small US operator
46 CFR logic, an AI document scanner, expiry alerts, and an inspection simulator — flat fleet pricing, no per-vessel fees.