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INSIGHTS implementation and audits are separate. We have enough do not like structured hierarchies. That’s not our industry. employees so that the TSMS writer is not the auditor of Both sides will have to change to make it work, but without it, nor are the ? eld personnel who are implementing it. the structured hierarchy, the boats wouldn’t function. And

We feel that our service is particularly helpful for the small Sub M mandates the master’s responsibility and Authority. operators who don’t have the resources and/or ability to The things that made the industry appealing for me (per- put a TSMS together, roll it out and then audit it and the sonal challenges, rising through Master to tug ownership, vessels. The different set of eyes that our auditors offer the navigational and vessel operations) don’t seem to work with customer, also work for us. They help us continually im- the millennials. But, we’ll get past all the issues and I think prove the TSMS and related services. become a safer, more ef? cient industry.

U.S. towing vessels have two options when it comes 46 CFR Subchapter M applies to all U.S. towing ves- sels 26 feet in length or more and U.S. towing vessels to being inspected for compliance with Subchapter M regulations. They can create – or enlist help in doing so less than 26 feet moving barges carrying oil or haz- ardous material in bulk. All told, the rule impacted – a Towing Safety Management System Option (TSMS).

Or, they can go through the Coast Guard Inspection Op- as many as 5,000 vessels. Some stakeholders pre- dicted that the rule would drive some operators out tion. This option may be seen as the most cost-effective of business. Has that happened to any great degree? option, but will it provide the same level of compliance as the TSMS option? What do you see as the best path?

Yes. I know of a few companies that have already thrown

We believe that the TSMS option is the only path to in the towel and see more that will not come through Sub achieving higher levels of safety on the boats. The USCG

M. As a business that is centered on helping the small op- erator, it is tough to walk into a company and see that option is the low bar – they only care about checking the they can’t make it. But there are companies that have never boxes related to the condition of equipment. It’ll be no invested in their equipment or people and they only drag different than tank barge inspections. Safety factors in tan- gentially because you need to have life rings in good con- the rest of us down. The herd will be culled.

dition, but they are not looking at the underlying safety program within a company. The USCG requires a Health

The SubM rule was implemented, in part, because and Safety Plan but they have given no guidance on how the Coast Guard and government research showed that towing vessels account for a signi? cant percent- it will be audited and how they will audit the required Sub age of all vessels involved in collisions, allusions,

M records. TSAC was against this option because it doesn’t groundings, commercial mariner deaths and inju- enhance safety and we take the same position.

ries, and as much as one-third of discharge incidents greater than 100 gallons into navigable waters (2010

Does the coast Guard have the resources to attend – 2014). Many of these operators were AWO Respon- and inspect every vessel if all ~ 5000 of these vessels sible Carrier Program (RCP) members to begin with. opted for the USCG option?

What difference, then, will SubM make?

I think that remains to be seen. I know of two companies

There will be no difference overnight, but over time I that will use the USCG option and the USCG is asking believe we will get better. Unfortunately, cell phones won’t everyone what option they will choose in order to plan for help. We speak a lot about distracted operations at the cap- the future. But they are not getting any additional resources tain’s level but it is far worse at the deck level. We are too and they seem to be in the dark about many parts of Sub M. connected to the world and every little problem at home They lag behind the TPOs because they do not understand (or aboard) is magni? ed by social media. The average at- our industry. Their marine experience is on government- tention span is 8.25 seconds. That’s .75 seconds less than maintained vessels that do not perform the functions of our a gold? sh’s attention span. So, as we develop policies and industry. Couple that with the fact that most people in our procedures we must take this into account. Training ses- industry do not want them on their vessels, they are bring- sions must work with this, too. And some aspects of the job ing up the rear. And they are the enforcers. The TPOs are require acute attention to detail. Especially when it comes being exposed to the oddities on our vessels. Companies en- to drills. The other part of this is the arrival of ‘millenni- gage them and pay them for advice. I think for most TPO als’ in the workforce. They are not motivated by the same auditors, the small towing company vessels are a shock to things that the boomers were. A 2015 Gallup poll found them. If you spent your life around classed vessels or petro- that only 28.9% of them are engaged at work. They look leum transportation, then the boat that’s moving rocks will for more collaboration, frequent, open communication and look different. But at least they are getting the experience.

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