Subchapter M highlights the need to embrace innovative tech

Subchapter M has raised three distinct technology issues that we now wrestle with and will continue to grapple with over the next several years. Electronic recordkeeping, big data and cybersecurity are the hinges of a door that is only now beginning to open in the inland towing industry. These technological innovations have the potential of exercising an enormous influence not only on how the inland towing industry does business today, but also in the evolving shape of the entire American transportation market over the next several decades.

While few believe “paper and pencil” recordkeeping retains any tangible value, there are those in the inland towing industry who retain a quixotic sense of loyalty toward that honored process. If “paper and pencil” is not practical, it is even less sensible from a risk management perspective. The framers of Subchapter M anticipated the demise of manual recordkeeping and wisely included provisions for electronic recordkeeping in the final rule. Some maritime vendors took early notice of the 2011 Notice of Proposed Rulemaking for authorizing an electronic towing vessel record and began development of a technology solution even before knowing the standards of the final rule. Other technology providers chose to wait until the final rule was published and are only now bringing to market an electronic towing vessel record (TVR).

Unbeknownst to anyone but the Coast Guard was that the proposed electronic towing vessel record was indeed included in the final rule, but so also were standards for a TVR. These standards, only now published as Sections 410.910-915 of the final rule, describe in detail what an electronic TVR must do and what it must retain. Prime among these standards is the “correction and preservation” feature for data entry errors. Other standards include a number of statutory assessments, reports, surveys, audits and a clearly defined audit trail. Less than a handful of U.S.-based technology partners have been able to bring to market a fully compliant Subchapter M recordkeeping solution.

The collection of data sets from an extensive pool of diverse organizations offers big-data opportunities that have yet to be realized by the inland towing industry. Everything from conditioned-based maintenance to predictive analytics and social media leveraged through Microsoft Azure and Microsoft Machine Learning offer technology-driven opportunities only dreamed of just a few years ago. 

Knowing the probable dates and locations of future waterborne traffic congestion, the best crew configuration based on the tenor of Facebook postings, and the best opportunity to conduct an overhaul are all advantages afforded by technological innovation with the purposes of enhancing commercial utilization, regulatory enforcement and environmental stewardship. Although the technology is in place, Subchapter M has helped bring to the table that mix of operators, agencies, advocacy groups, trade associations, surveyors and yards so vital in building out the value in big data.

Lastly, the issue of cybersecurity is at the forefront of any discussion on maritime technology. The vitality and value of our Marine Highway requires a heightened awareness of cybervulnerabilities and the risk they pose not only to towing operators individually, but to our national security as a whole. I have advocated strongly for inclusion of cybersecurity plans in ISPS and, more recently, in Subchapter M TSMS and security plans. Onboard and shoreside software must be maintained like any piece of essential marine equipment. Technology and the platforms supporting it are a primary target of any terrorist seeking to disrupt our transportation network.  

The inland towing industry cannot ignore the importance of the three technology “hinges” of electronic recordkeeping, big data and cybersecurity. A failure to embrace any one, or all three, will ultimately lead to not only the economic demise of individual workboat operators, but the slow and costly degradation of our national security.

Dean Shoultz is chief technology officer at MarineCFO in Houma, La.

By Professional Mariner Staff