Page 28: of Marine News Magazine (September 2016)

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AUDIT & COMPLIANCE

Subchapter M:

Post Publication Highlights

An extra T in TSMS, nowhere left to hide from systems documentation, and an emphasis on continuous improvement.

By (Captain) Katharine Sweeney

Back in January of this year, the Unit- apply to towing operations. When the vessel is running ed States Coast Guard (USCG) pre- light boat with no tow, does that mean the SMS doesn’t dicted Subchapter M would be released have to be followed? Sorry, no, it is still in effect; tow or no in spring 2016. I put my money on tow. The TSMS actually applies to the whole operation of

June 20, that being the very last day of the company, the vessels and the crews. “Safety Manage- spring, and on June 20 the long-awaited ment System (SMS)” is a more generic and appropriate regulation was ? nally published. term in my view.

Subchapter M doesn’t come with Subchapter M, like other subchapters, is concerned with much we weren’t expecting, which is a vessels of a speci? c size and type. Subchapter M applies to

McVicker good thing. Surprises in this industry are vessels 26’ or greater engaged in certain towing or pushing not met with enthusiasm. The USCG should be compli- operations. Enough said. There is no need to add the word mented in that regard. Aside from its impact on approxi- “Towing” to “Safety Management System.” mately 5,500 vessels and 1,100 companies, this legislation You may be wondering about the Certi? cate of Inspec- was needed, and many companies were mostly there already. tion (COI) option. Coming from the unlimited tonnage

Some people even thought the legislation did not go far side of the industry, I call this option “old style,” because enough. I, for one, believe it is a start, and starts are impor- it’s what we had before most companies went with the Al- tant. Slow steps are needed to enact monumental change, ternative Compliance Program (ACP) back in the 1990’s. as is careful deliberation. Risk assessment is a requirement Even with the COI option, you will still be required to in this new regulation. The same risk assessment should be train your employees and ensure they follow procedures. used by the USCG and industry partnership to indicate The USCG will require a “Health and Safety” manual or how much further the regulation needs to go. Only in time plan on board and you will still need some type of system. will we understand what was left out of the original sub- What will this change mean for crews? No matter where chapter and still needs to be addressed. you go, or who you work for, some sort of system will be

My question is why the regulation is called a Towing in place to ensure a practice of “do-what-you-say, say-what-

Safety Management System (TSMS). The industry should you-do and prove-it.” For those captains and crew that hate demand the “T” be dropped as the regulation doesn’t just paperwork and retreated to smaller tonnage, your time is

AWO

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