Page 20: of Marine News Magazine (March 2018)

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COLUMN REGULATORY REVIEW

SITREP: Subchapter M

No matter what route you take, time is marching on and that means compliance requirements, inspections and audits are just around the corner.

By Paul Hite,

Senior surveyor and auditor with the American Bureau of Shipping (ABS)

This July, major sections of the Sub- Towing Safety Management System (TSMS) to the re- chapter M regulation will enter into quirements of Subchapter M and have it certi? ed by a force as the towing industry begins the TPO, or they can opt for certi? cation and regular inspec- process of certifying as many as 5,700 tions by the Coast Guard.

U.S.-? agged vessels that fall under the The vast majority of owner/operators have chosen the remit of the new safety and environ- TSMS route. The Coast Guard has actively encouraged the mental standards. Demand for tech- TSMS option, a strategy that is driving the current strong nical support from third-party organi- demand for TPO support. But there are still a surprising zations (TPO) such as ABS has been number of companies that have chosen neither their com-

Hite escalating rapidly as more and more pliance option nor partner. For them, the clock is ticking.

vessel owners start to build or bring ABS, which regularly provides technical oversight for safety management systems (SMS) into compliance with about 2,000 of the towing vessels subject to Sub M regu- the U.S. Coast Guard-driven mandate. lation, has recently issued TSMS certi? cates for a num- ber of companies and is helping others to update their

EADLINES PTIONS

D & O safety-management systems. We have also been conduct-

July 20 is the deadline for the sections (Parts 140-144) ing surveys of vessels to determine their individual levels of the phased-in regulation that set requirements for opera- of compliance.

tions, lifesaving, ? re protection, machinery and electrical Given the Coast Guard’s guidance, the TPO commu- systems (and equipment), as well as the construction and nity expected the vast majority of towing companies to arrangement of the vessel. TPO activity levels are increas- choose the TSMS option, and this has proven true. But ing daily, with requests for surveys and vessel audits having the USCG route to compliance is still proving popular, spiked in response to the Coast Guard’s recent opening of particularly among smaller companies that may not have a the application process for Certi? cates of Inspection (COI). safety management system already in place.

In a nutshell, vessel owners have two paths to Sub M compliance: they can design/modify a bespoke company L L C P

OOMING ARGE IN THE ENTER ORTHOLE

The towing industry has about 5,700 vessels that qual- ify for inspection under Subchapter M. The vessels using

TPOs will be inspected by the Coast Guard every ? ve years, while those choosing Coast Guard inspections will be inspected each year. Their COIs will be renewed on a ? ve-year schedule.

Owners and operators opting to go the Coast Guard route can expect the ? rst inspection – the one that will ultimately generate a vessel’s inaugural COI – to be com- prehensive; diving into almost every aspect of its opera- tion, safety processes and structural integrity. Theoretical- ly, each annual inspection could be as comprehensive, but the Coast Guard’s Of? cer in Charge, Marine Inspection – typically referred to as the OCMI – has some discretion on the scope of subsequent inspections.

ABS has advised owners with smaller ? eets that operate

Credit: ABS

March 2018

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