Plan Review and Approval

Rely on our expertise as you work to meet the requirements of Subchapter M.

Verification of compliance with the design standards may be required, as given in 46 CFR 144.135, for one of the following circumstances:

  1. The towing vessel is new – constructed after July 20, 2017;
  2. The towing vessel is to undergo a major conversion or alternation after July 20, 2017; or
  3. The towing vessel is being equipped with a new installation which is not ‘replacement in kind.

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For a new vessel, the verification of compliance must be complete prior to issuance of the towing vessel’s initial Certificate of Inspection. For a major conversion, the verification must be performed prior to the change. For a new installation which is not ‘replacement in kind,’ the verification must be done prior to the new installation.

The terms ‘major conversion’ and ‘replacement in kind’ seem quite vague on initial reading. Fortunately, 46 CFR 136.110 includes definitions for all phrases used in Subchapter M which could be confusing. 46 CFR 136.110 defines ‘major conversion’ as:

  1. A substantial change in dimensions or carrying capacity;
  2. A change in the type of vessel;
  3. A change which substantially extends the life of the vessel; or
  4. Otherwise changes the vessel so that it can be considered a new vessel by the USCG Marine Safety Office.

Likewise, 46 CFR 136.110 defines ‘replacement in kind’ as replacement of existing equipment with new equipment with the same specifications and performance as the original equipment. If the replacement equipment upgrades or improves the system in which the replacement is made in any way, it is not ‘replacement in kind.’

Systems which are a ‘major conversion’ or not ‘replacement in kind’ may include:

  • Hull and superstructure
  • Stability
  • Habitability
  • Egress and personnel protection
  • Ventilation
  • Lifesaving
  • Fire fighting
  • Propulsion or auxiliary machinery
  • Electrical equipment and distribution

While the USCG could verify compliance directly, the towing vessel operator may find this to be a lengthy process. 46 CFR 144.140 allows other entities to verify compliance through plan review – Professional Engineers and classification societies. There are compelling reasons to choose one or the other – flexibility and availability are two important considerations. Familiarity is another. If an operator has a relationship with a classification society, this would be a prime reason to have plan approval done by a classification society.

If the operator does not have a prior relationship, a Professional Engineer would be an equally good choice. Classification society reviewers are completely conversant with their Rules – and each society has similar, subtly different Rules. On top of the application of their Rules to a review, they must apply the Subchapter M requirements of Parts 141 through 144 of Title 46. Professional Engineers, on the other hand, will refer to the regulations of Subchapter M first – then use the referenced Rules within Subchapter M to determine compliance with the regulations.

When making a decision between using a Professional Engineer or a classification society, EDT suggests taking these into consideration:

  • How much verification of compliance is needed – is this a new construction, a major conversion, or just replacement of equipment ‘in kind?’
  • If considering a classification society, is the society recognized by the USCG?
  • If considering a Professional Engineer, does the engineer have registration in your state or the state your towing vessels operate in?
  • What is the discipline(s) of the Professional Engineer? In some states, the Professional Engineer is allowed to practice in disciplines where the engineer has education or experience; in others, the engineer must have passed by examination to practice in a particular discipline.
  • What do the fees include? Will a budgetary estimate be prepared explaining the fees?
  • Upon receipt of drawings and supporting documentation, when can a report or approval be expected?
  • Will a list of required documentation be provided prior to the review?”

Next Steps

Have questions about Subchapter M and the TSMS option? Our lead marine engineers are located in our EDT Oakland and EDT Seattle offices, and we also have licensed engineers across the U.S. that you can rely on. Connect with EDT marine engineers today.