Page 26: of Marine News Magazine (October 2012)

vary depending on the size and mission of the company. While large companies will spend more to implement and maintain an SMS, the cost to a small company may be more difÞ cult to absorb. MANY LAYERS TO THIS ONIONAdditionally, each owner or managing operator would have to consider additional costs associated with Subchapter M compliance. There will be new costs for dry-docking vessels. These costs will range from $32,000 for small towing vessels (800 hp) to $72,000 for the large towing vessels (6,000 hp.) Additionally, Tables 2 Ð 6 provide a brief summary of other potential time and costs associated with the implementation of this new system. These costs for an average size towing company could approach $3 million. It is also estimated that approximately 175 to 325 additional auditors will be needed throughout the inland waterway system. While the goals of Subchapter M are laudable, the depth and breadth of the regulatory scheme is far reaching. It will be up the individual reader to extrapolate the data from the TSAC EAWG Tables to determine the cost in dollars and time for any particular vessel or entity to come into compliance with Subchapter M due to the large number of commutations and permutations. However, it is most certain that a number of vessels and entities will not survive the implementation of Subchapter M, despite a generous phase-in process. Exactly how many of the 1,059 companies and 5,208 towing vessels will go the way of the dinosaur is beyond the scope of this article. From the tables presented, one may suppose that the number of victims will be signiÞ cant. Additionally, the cost of Subchapter M will almost certainly be passed onto the customer either in the form of taxes paid to the government or increased rates. Finally, Subchapter M could result in an unintended consequence. If shipping lines and barge companies begin to suffer signiÞ cant delays due to an insufÞ cient number of towing vessels being available to meet the demand, this could leave the door ajar for non-US ß agged towing vessels to enter the market. Alas, this too is a question for another day. COMPLIANCESMS related equipment Amount (USD)Engine room Þ xed pipe systems for MDE oil $4000Power loss emergency light installation $2000 (avg. 8 lights at $250 each)Fixed Þ re extinguishing system (galleys & stoves) $1200 Ð $2500Engine room remote monitoring (cameras)* $1500 Ð $3000Fire retardant paneling $3500 Ð $20,000Multi Ð point alarm system (10 Ð 30 points)$10,000 Ð $22,000Mechanical seals to facilitate dry bilges$40,000Electronic charting/AIS interface (Wheelhouse) $1200 Ð $9700Electric start/stop E/R equipment - Wheelhouse $4500CEMS speciÞ cNoise reduction (additional insulation) $1000 Ð $30,000Blackout shades and green lighting $1000RCP third-party auditing/monitoring cost $1800 Ð $5000Total $76,200 Ð $143,700Company Size# of Towing Vessels# of Persons on Audit Team Cost (Plus Expenses)Days to Complete AuditSmall<101 or 2$2,500-$3,5001.5 Medium10 Ð 201 or 2$3,000-$6,0001.5 Ð 2.5 Large>202$4000 to $60002.0 Ð 3.0 Table 1 - (800 ? 2000 hp towing vessels) Table 2 ? Cost & Time of Third-Party Audits of a Company SMS 26 MNOctober 2012MNOct2012 Layout 18-31.indd 26MNOct2012 Layout 18-31.indd 2610/2/2012 9:38:21 AM10/2/2012 9:38:21 AM