Flexibility and Complexity: Operators Need to Select their Subchapter M Strategy for Compliance
written by Chris Parsonage, published in the July 2017 edition of SNAME MT (The Society of Naval Architects and Marine Engineers – Marine Technology) Magazine
“…path that the USCG has suggested will be best for many operators and the key to successful implementation of Subchapter M—the towing safety management system (TSMS) option. Under the TSMS, operators develop a comprehensive set of policies and procedures that cover all relevant aspects of managing their towing vessels. Instead of working solely with the USCG, operators select a third-party organization (TPO) to conduct periodic audits and surveys to verify the company is in compliance with the policies and procedures outlined in their TSMS and Subchapter M. Instead of annual USCG inspections, operators choosing the TSMS option and successfully operating under their TSMS will potentially have much less USCG involvement in their operations and on their vessels.
Companies that have been operating under a recognized existing TSMS, such as the AWO Responsible Carrier Program or the ISM code, are generally well prepared to comply with Subchapter M, particularly if they choose the TSMS option. They should expect to find their TSMSs might only need a few, if any, additional elements to be implemented before their TPO can verify their systems meet the Subchapter M requirements. Therefore, the gap for these operators will be significantly less than those starting from scratch. Those operators that do not currently have a TSMS in place, or have not begun the process to write a Subchapter M-compliant TSMS, have a steep hill to climb if they want to take advantage of the TSMS option by July 2018.”
“…there is a great deal of f lexibility written into Subchapter M for those who do choose the TSMS route. Generally speaking, operators are able to write their TSMS so that it fits their unique operation. One example of this flexibility is in the survey program option. Subchapter M provides operators selecting the TSMS option flexibility in choosing how to conduct the survey elements of their TSMS. Operators can choose to have their annual surveys and less frequent drydock and internal structural examinations “ISE,” either conducted by an independent third-party surveyor from a TPO, or they can develop their own internal survey program. Operators choosing the internal survey program can use a qualified company employee or hire an outside contractor with proper experience and training to conduct their annual vessel surveys and/or their drydock and ISE. The TPO will work with the operator to supervise the internal survey program.”