The Coast Guard says it will accept existing Safety Management Systems for purposes of granting initial certificates of inspection for towing vessels under Subchapter M rules.
The expected ruling came as a policy letter issued May 24 from Coast Guard headquarters, giving guidance to its marine inspectors and the towing industry. It qualifies existing, approved SMS systems adopted by operators for purposes of granting initial certifications of inspection, prior to the ongoing adoption of new Towing Safety Management Systems (TSMS) under Subchapter M.
Operators whose SMS is up to standards “will be deemed in compliance with TSMS requirements,” the letter says. “Other Coast Guard accepted existing safety management systems, such as the American Waterways Operators’ Responsible Carrier Program, may also be considered as meeting the TSMS requirements ... Owners and managing operators with a past performance of successfully operating under a safety management system have demonstrated a structured and documented system that enables personnel involved in vessel operations or management to effectively implement safety and environmental requirements.”
The guidance aims to reconcile a gap between the time companies get their approved TSMS and bring their vessels into compliance with Subchapter M and obtain certificates of inspection, a process that will be in full force July 20, 2018.
The letter sets additional conditions, mandating safety management system audits for vessels that have not had audits within three years, to be conducted by approved third-party organizations or companies with their own qualified in-house auditors.
A day before the letter was issued, Subchapter M issues attracted a standing-room audience to a panel discussion at the Inland Marine Expo in St. Louis. Experts from towboat companies and the nonprofit Towing Vessel Inspection Bureau (TVIB) talked about how operators and longtime vessel surveyors must orient themselves to handle the new requirements.
“It’s not necessarily something that’s built into anyone’s job description, said Chris Parsonage, TVIB’s executive director.
“We’ve had surveyors in the classes who had no idea what a TSMS was,” said David A. Foret Jr., president of the ACTion Group, Houston, and a TVIB instructor.
The audience size underscored the industry’s continuing efforts at coming to grips with Subchapter M requirements. For Parsonage and an industry panel — and much of the audience — it was another deep drill into the Coast Guard towing regulations and what they will require of towboat operators.
One key understanding is that of surveys and audits, Foret explained: “Your audit is testing the effectiveness of your [safety] system, and the survey as well … The Sub M audit is going to put the umbrella over your process.”
