May 9, 2019 – the USCG sent out the following notice via the GovDelivery
This is a reminder of a key 46 CFR Subchapter M implementation milestone that is quickly approaching. On or before July 22, 2019, owners and managing operators of Subchapter M towing vessels must implement a Health and Safety Plan (HSP) and the associated recordkeeping procedures regardless of whether or not the vessel has been issued a Certificate of Inspection (COI). Requirements include general health and safety procedures, identification and mitigation of health and safety hazards, and health and safety training for crewmembers and non-crewmembers.
Towing vessels operating under a Safety Management System (SMS) may already have the elements of the HSP covered within the SMS. For towing vessels that have not incorporated the HSP elements into their SMS, and for towing vessels utilizing the Coast Guard Inspection Option, the HSP would likely be a stand-alone document.
There is no requirement to submit the HSP to the Coast Guard or TPO for approval; however, the plan is subject to review during inspections and audits. Minimum health and safety requirements can be found in 46 CFR Part 140 Subpart E.
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