Page 22: of Marine News Magazine (November 2018)

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REGULATORY COMPLIANCE

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THE COAST GUARD IS STILL AN OPTIONTHE COAST GUARD IS STILL AN OPTION

Not all towing vessel companies are choosing Third Party Organizations (TPOs) for their Subchapter M compliance option. One size does not ? t all.

By Kevin P. Gilheany nder Subchapter M, towing vessel companies may COAST GUARD OPTION REQUIREMENTS opt to use TPOs to conduct their audits and sur- Obtaining a Certi? cate of Inspection (COI) requires an

U veys instead of inspections by the Coast Guard. operator to get their boats in compliance, conduct the re-

While many companies are going the TPO route, many quired training, have a health and safety plan, and have are opting for traditional Coast Guard inspections. a system to manage the operational, administrative, and

As a retired Coast Guard marine inspector, I have always record keeping requirements. Not having the paperwork advocated the Coast Guard option to our clients. There are in order can be just as problematic as not having the boat no additional inspection costs, besides the annual Coast ready for inspection. According to early reports, not all in-

Guard inspection fees which all companies pay regardless of spectors are looking at paperwork yet, but many are. It is the compliance option. Additionally, a towing vessel compa- essential to develop a towing vessel record (TVR) in order ny under the Coast Guard option does not have to operate ac- to ensure compliance.

cording to a towing safety management system (TSMS). This does not mean that operating under a TSMS is a bad idea. In GREAT LAKES fact, some companies that choose the Coast Guard option for One reason why some companies have chosen the TPO compliance under Subchapter M may operate under a safety option is that they have not dealt with Coast Guard marine management system with the same, or a higher, level of ef- inspectors before and are apprehensive about what those ? ciency than those companies that choose the TPO option. interactions might bring. “Three or four years ago, we paid

These companies still reap the bene? ts of a safety man- to have a TSMS developed because we were going with the agement system and are able to meet the demands of their TPO option because I was afraid of the Coast Guard and customers and industry associations. The main difference didn’t want them on my boats,” said Phil Andrie, owner of is that those companies that have chosen the TPO option Ashton Marine, LLC. “But since then, we had the Coast have voluntarily, in essence, given their TSMS the force Guard on our boats during some operations which made of law. The Coast Guard made safety management op- me change my mind, and we went with the Coast Guard tional for towing vessels despite great pressure from some option.” Ashton Marine is a small marine towing company in the industry to make it mandatory. Voluntarily mak- out of Muskegon, Michigan. ing a TSMS mandatory for compliance comes with sig- Andrie of Ashton Marine was also apprehensive about the ni? cant risk given the diversity of experience and opinions paperwork requirements, but reported that the Coast Guard amongst auditors and vessel crews. inspector visiting their boat was very impressed with the

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