As of June 20, 2016 Subchapter M is officially here. It is supposed to address many issues in the towing industry and make our profession much safer. Everything has been addressed including fire fighting, supplies, record keeping, drills, surveys, inspections, training, navigation, security, lifesaving, etc. Everything, except for Manning and Work Hours. Everything except for the most important issue in the entire package. We can have the best equipment, with the best shoreside support team, with the best policies, training and guidance, but what does any of that matter if the crew is exhausted? Exhausted crews get injured more often, make bad decisions and fall asleep on watch. Manning is the most important part of Subchapter M