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and that the Coast Guard is fully com- latory requirements. Get the captains to formities. Use a tool such as a Safety lose their license for it under 46 CFR mitted to rectifying those shortcomings. start doing it now. They will not magi- Management Workbook to get crews to part 5.

The Commandant agreed with Safety cally become experts on July 20, 2018. learn the policies and procedures. For

Recommendation #30, contained in that those captains that need reminding, let For those choosing the MOVE 5 report, calling for the establishment of For companies choosing them know that not following the TSMS Third Party TSMS option, conduct care-

MOVE 4 headquarters level Third Party Oversight the Third Party TSMS option, streamline policies and procedures could not only ful research and interviews with all TPOs

Of? ce, as well as a Third Party National the TSMS to reduce the risk of noncon- get the boats shut down, but they could before signing that TPO agreement.

Center of Expertise, “to conduct com- prehensive and targeted oversight activi- ties on all Third Party Organizations and

Authorized Classi? cation Societies that perform work on behalf of the Coast

Guard.”

In addition to this increased oversight of the Third Party Organizations, opera- tors should bear in mind that the Coast

Guard will come every ? ve years to con- duct an Inspection for Certi? cation on each Third Party TSMS boat to verify

Subchapter M compliance and confor- mance to the TSMS.

MYTH 5 All TPOs are not the same.

A TPO should not be chosen by price, or perceived ease of use, alone. Careful research and review of processes are es- sential.

MYTH 6 Companies do not have to use their current, all-inclusive, SMS as their TSMS. Whatever is approved as the TSMS by the TPO, basically has the force of law. This is in addition to every- thing else in Subchapter M. A standard industry SMS can be reduced by 52% and still meet the regulatory require- ments of a TSMS. Think risk assessment.

MYTH 7 It is not the Coast Guard’s position that companies should go with the Third Party TSMS option, although that may be the opinion of some Coast

Guard individuals.

TOP 5 MOVES TO MAKE

Here are the top ? ve moves to make now to get on the right course:

MOVE 1 Avoid groupthink and peer pressure and make a well-reasoned de- cision on the TPO v. Coast Guard com- pliance option which represents the optimum path to compliance for your company.

MOVE 2 Get each towing vessel surveyed for Subchapter M, preferably by someone with Coast Guard marine inspection experience.

MOVE 3 Establish a system of logs and records, such as a Towing Vessel

Record (TVR), as well as a compli- ance management system. Compliance management is not safety management.

Relying on a TSMS alone, unless it has been speci? cally designed to ensure comprehensive compliance with Sub- chapter M, may not cover all the regu- www.marinelink.com 13

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