Page 12: of Maritime Reporter Magazine (July 2018)

WORKBOATS

SUB M

July 20, 2018 & Beyond

About the Author

Captain Andrew Kinsey, Senior Marine

Risk Consultant, Allianz Global Corpo-

The bottom line is 46 CFR Subchapter M is drastically changing the rate & Specialty landscape of towing operations within the United States. Some im- pacts we have identi? ed and other will come to light as time passes.

As the Subchapter M compliance quirements will be in order to comply very important that the COI accurately need to be addressed. deadline approaches on July 20, 2018, I with the requirements of Sub M. This re? ects the trade, service and manning A key ? rst step in complying with this have had the chance to discuss these new information can be obtained by using of the vessel. Understand what you are regulation is to know and understand laws and their impact with a variety of the Inspected Towing Vessel Decision ? lling out. what is being required by the regulations

Assured’s with diverse backgrounds and Aid – TugSafe (https://www.dco.uscg. If you have questions verify with the and how these issues are currently being widely varying commercial tug opera- mil/Our-Organization/Assistant-Com- Coast Guard before submitting. addressed by your company. By having tions. mandant-for-Prevention-Policy-CG-5P/ Internal communication is critical to the personnel who will be involved in

From my experience, there is still a Traveling-Inspector-Staff-CG-5P-TI/ any Owner/Operator of a Towing Vessel implementing the procedures and con- great deal of confusion regarding the Towing-Vessel-National-Center-of-Ex- as we move ahead, regardless of which ducting the training, actively involved in compliance requirements relating to Sub pertise/TugSafe/) , which will generate a compliance option is chosen. In many developing the Health and Safety Plan,

Chapter M. In addition, a major central detailed list of what you need for a spe- cases, articles have focused on the TSMS you have the best chance of developing point that has emerged is the need for ci? c tug to prepare for an inspection or Option, but even if a company pursues something that will actually bene? t all proactive communication – both inter- survey and can be accessed on any com- the Coast Guard option, increased crew parties involved rather than just check- nal and external to company operations puter, tablet or smart phone. involvement in the regulatory process ing the box. – in order to identify and comply with Armed with this knowledge, you will and addition of Safety Procedures will be You know your operations better than these legal requirements. be better able to discuss your personal required. Commercial Towing Vessels’ the Inspectors and Surveyors who will

Regarding External Communications, compliance issues with your local Coast new designation as Inspected Vessels be visiting the vessel. Use the combined

Owner/Operators need to know how the Guard personnel. Remember, July 20, will introduce Owners and Operators to knowledge of your company to develop

U.S. Coast Guard in their district is ap- 2018 is the date when 46 CFR Subchap- a new world of regulatory concerns. a Health and Safety Plan that accurately proaching enforcement of these laws as ter M, Parts 140-144 will be implement- In addition, Subchapter M will contin- re? ects your operations and assists you well as informing the Coast Guard how ed. ue to bring about a cultural shift within in being a safer and more productive op- they are working to comply with them. Your compliance with these laws is re- the U.S. Towing Industry. Keys to suc- eration. This has to be done, but why not

An important step in effective communi- quired regardless of which compliance cessful operations moving forward in- make it bene? t your operation rather be- cation with the Coast Guard is to under- option you have selected or whether clude the need to keep accurate record ing an additional reporting burden. stand what questions they have already your vessel has received its Certi? cate keeping of all training conducted, to If a company has chosen the Coast answered. No one likes answering the of inspection (COI). Don’t wait for the maintain effective communications with Guard option for Subchapter M compli- same question twice. Coast Guard to come to you, be proac- the local Coast Guard Of? cer in Charge ance, the company still has to produce

The ? rst step before contacting your tive and protect your business and your of Marine Inspection (OCMI) and to rig- procedures to address Health and Safety local OCMI should be to visit the United livelihood. orously comply with these regulations Hazards. Required training will need to

States Coast Guard Towing Vessel Na- An important point for Owner/Opera- that are now law. Your employees need be conducted as well as records main- tional Center of Expertise’s Frequent- tor to remember is that they are respon- to be aware what is required; this applies tained. ly Asked Questions (FAQs) website sible for submitting the paperwork for to of? ce personnel as well as those on The bottom line is 46 CFR Subchapter (https://www.dco.uscg.mil/tvncoe/) and requesting the initial COI. This is USCG the boats. M is drastically changing the landscape sign up to be noti? ed for updates. This form CG-3752A. When completing this This need for all hands involvement of towing operations within the United is where you can ? nd answers to ques- form, remember to include “Persons in will only grow as the next Subchapter States. Some impacts we have identi- tions such as when you have to drydock. Addition to Crew” to the proposed man- M deadline approaches. The Health and ? ed and other will come to light as time

Will hull gauging be required (maybe) ning levels. Safety Plan outlined in 46 CFR 140.500 passes. However, these regulations are and can you still have doubler plates You may not think this applies to you, will occur on July 22, 2019, and applies not going to go away, nor can they be (depends). but what about the occasional need to to all Towing Vessels. The regulations ignored. For many operators, this will

Another highly recommended resource have additional personnel onboard? de? ne a number of Health and Safety result in new administrative and record- prior to reaching out to your OCMI is to Think about crew changes or the need Hazards that need to be identi? ed and keeping requirements regardless of the review what your individual vessel re- for tech reps or repair personnel. It is mitigated. Training Requirements also compliance option chosen.

12 Maritime Reporter & Engineering News • JULY 2018

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