Subchapter K Small Passenger Vessel Compliance: COI, Crew, and Drills

Operators of small passenger vessels often know they are "Subchapter T" without realizing there is a heavier sibling. Subchapter K (46 CFR Parts 114–122) covers small passenger vessels of under 100 gross tons that carry more than 150 passengers, or that have overnight accommodations for the relevant numbers — the larger, higher-capacity end of the small-passenger world. The requirements step up accordingly. This guide covers what a K-boat operator manages, and how it differs from the Subchapter T world many operators start in.

K vs. T, in one paragraph

Both subchapters cover inspected small passenger vessels under 100 GT. The line is capacity and accommodation: Subchapter T generally covers vessels carrying 150 or fewer passengers (and the smaller, simpler operations), while Subchapter K covers those carrying more than 150 passengers or with overnight accommodations for them. More passengers means more lifesaving equipment, more crew, more demanding stability and evacuation requirements, and a heavier inspection.

What Subchapter K requires day to day

• Certificate of Inspection (COI) stating the route, the maximum passengers, the required crew, and the conditions of operation — the document that governs everything else, kept current.
• Manning — the licensed master and credentialed crew the COI requires for the vessel's size, route, and passenger load.
• Lifesaving equipment sized to the higher passenger count — life floats/rafts, life jackets (including child sizes), and the associated servicing schedules.
• Firefighting equipment appropriate to the vessel.
• Stability compliance for a vessel that may carry a large, mobile crowd of passengers.
• Drills and emergency instructions — passenger safety orientations and crew drills, logged.
• Crew credentials — MMCs, TWICs, medicals — each with an expiry.
• The drug and alcohol program under 46 CFR 16 / 49 CFR Part 40.

The operational reality: a K-boat carries a lot of people, often tourists, on a schedule. The compliance load is real, the inspection is more demanding than a T-boat's, and the consequences of a lapse — an expired credential, an out-of-date raft servicing, a missed inspection — are amplified by the passenger count.

Where the recurring burden sits

As always with inspected vessels, the day-to-day burden is keeping the moving parts current:

• COI and survey dates, never lapsing.
• Lifesaving equipment servicing (rafts, EPIRBs) on schedule for the higher passenger count.
• Crew credential expiries across the larger crew a K-boat requires.
• Drill records that an examiner or investigator will expect to see.
• An evidence trail ready for the more demanding inspection.

Where Binnacle AI fits

Binnacle AI carries the small-passenger-vessel compliance load for the K- or T-boat operator: COI and survey scheduling per vessel, lifesaving-equipment servicing dates with lead-time alerts, crew credential expiry tracking with an AI document scanner that reads MMCs and medicals from a photo, drill logs, and a USCG inspection simulator to walk the crew through the exam before it happens. Pricing is flat from $49/month with self-serve signup. The free compliance calculator generates your requirements from subchapter, tonnage, route, and passenger count. For the buying decision, see choosing maritime compliance software.

The bottom line

Subchapter K is the higher-capacity step up from Subchapter T — more than 150 passengers or overnight accommodations — and it brings more lifesaving equipment, more crew, and a more demanding inspection. The recurring burden is the same shape as any inspected vessel, amplified by the passenger count: keep the COI, the equipment servicing, the credentials, and the drills current, with the evidence to prove it. Get the requirements straight, and the inspection is routine.

This article is general information, not legal advice. Comply with 46 CFR Subchapter K and your COI's conditions of operation.