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TRAINING & EDUCATION knowledge of the health and safety plan, tions prior to getting underway. The another example, section 140.420 cov- ing to ensure that every crew member un- procedures for reporting unsafe condi- orientation covers the expected areas of ers the requirement to conduct drills. It derstands their duties as a lookout, watch tions, PPE, safe use of equipment, haz- required duties, lifesaving equipment, covers the types of drills, the nature of keeping terms, reporting procedures and ard communication and so on. PPE, egress, and so on. It also covers the drills and the frequency of drills. Section so on. All of this needs to become part of

Subsection (b) covers the need to un- requirement to document the training. As 140.645 covers navigation safety train- a structured training program.

derstand hazards relevant to each train- In addition to the page or so of high ee’s potential exposure on or around the level explicit requirements for training, a vessel. Subsections (c) and (d) speak to careful reading of the operations section when training must occur and how fre- of Subchapter M reveals a broad range quently refresher training must be pro- of other training requirements sprinkled vided. Subsection (e) speaks to training throughout the operations section 140. for non-crewmembers and (f) covers the Some of these are speci? c examples of requirement to document all training. the general requirements of 140.515,

In addition to 140.515, there are other and others are items that simply require sections which speak directly to train- training without explicitly saying so. ing requirements - even though they do Thus it would be a good exercise for ev- not use the word “training” in their de- ery operator to examine every paragraph scriptions. For example, section 140.410 of section 140, making a list of items documents the need for safety orienta- which should be added to training and (Photo: Drew Arenth) 20 Maritime Reporter & Engineering News • NOVEMBER 2016

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