Kevin Gilheany Kevin Gilheany is a marine consultant and owner of Maritime Compliance International in New Orleans. He works with companies to help increase profitability through improved compliance and management systems. Gilheany is a retired U.S. Coast Guard marine inspector, certified marine surveyor and auditor, and crew endurance management expert. He has also provided contract training to the U.S. Coast Guard, was an adjunct instructor of maritime security at Tulane University’s Homeland Security Studies Program, and has contributed to marine industry publications. He can be reached at email@example.com or www.maritimecomplianceinternational.com.
Ten things you think you know about Subchapter M. (You’re wrong.)
We should see the Subchapter M final rule within a few months.
Despite the fact that the proposed rule has been published for years, a great deal of misinformation and misunderstanding still surrounds it. Some operators are willing to pay consultants to tell them what to do, and others will try to make sense of it on their own. Still others will wait until the Coast Guard shows up and see what happens.
There is no...
A new film pays welcome tribute to the Coast Guard's core mission of search and rescue.
During a massive storm off the Massachusetts coast in the winter of 1952, a tanker literally splits in two, with only half of the ship remaining afloat.
A Coast Guard boat coxswain from Coast Guard Station Chatham, Mass., is told to put together a crew and take a 36-foot surf boat out into the monster storm to render assistance.
“The Finest Hours” is the film that retells this rescue story, based on...
Towing industry audits shouldn’t be bogged down by comprehensive manual reviews and inspections.
An audit should not include a comprehensive manual review and comprehensive inspection of a vessel. These three functions should be kept separate and distinct in order to preserve the quality of the audit.
When I was a Coast Guard marine inspector, verification of audited programs were all based around the International Safety Management (ISM) Code. As proposed, Subchapter M offers a Towing...
Towboat operators must carefully consider compliance options.
Six months and counting… Perhaps this deadline for the Subchapter M Final Rule will be the final one. It certainly feels that way. Folks in the know seem to be more confident than ever before. I’m also starting to see the media buzz, and our company has received requests for assistance from five new towboat companies just in the past month. So, what should towboat companies be doing now to prepare?
No one reads the phone book, so it’s no model for an SMS.
Towboat captains take pride in their craft: driving boats. That’s what they enjoy, and that’s what they signed up for.
Towboat captains are respected for their ability to handle boats and are paid well for their experience. So why do we put a big fat telephone book of a safety management system (SMS) on the boat and expect captains to actually follow its procedures? No one reads the telephone book.
The truth is, an SMS for...
The threat of a spraying fuel fire is high for all vessels.
A common cause of engine room fires is fuel that sprays onto a hot surface, such as a turbocharger. This can occur when fuel line connections become loose or chafe through.
Many inspected vessels are required to have shields installed on fuel line connections to mitigate this threat. Flexible fuel lines should be inspected regularly for chafing, and should be replaced if they show signs of wear....
If you operate a commercial vessel 79 feet and greater that operates in U.S. waters, you only have three weeks left to submit your first EPA VGP annual report.
Under the first Environmental Protection Agency (EPA) Vessel General Permit (VGP) an annual report was only required to report non-compliance. Under the current 2013 VGP, an annual report is required to be submitted for all vessels covered by the permit, which includes all commercial vessels 79 feet and greater, operating in U.S....
The moratorium for requiring permits for incidental discharges from commercial vessels less than 79 feet is set to expire on Dec. 18.Currently, the
Environmental Protection Agency does not require Clean Water Act permits for
incidental discharges (other than ballast water) from commercial vessels less
than 79 feet. However, this moratorium is set to expire on Dec. 18.
EPA sources, it is unknown whether the moratorium will be extended past Dec.
18. If another moratorium is...
In anticipation of the possibility that Subchapter M will become final in 2015, I will be presenting a talk entitled "Subchapter M - Top 10 Things You Need to Know" at the Pacific Marine Expo in Seattle on Nov. 19.Don’t let your guard down. I have noticed many in the towboat industry are suffering from Subchapter M fatigue. Understandably, many are sick of the constant hype and have become desensitized at best, and disgusted at worst, at the mere mention of Subchapter M.
The towing vessel inspection final rule has been put off until March, but the new delay buys time for companies to prepare.The expected release date for the Subchapter M towing vessel inspection regulations Final Rule is now March 2015. While some may find the moving goalpost frustrating, the delay buys time for preparation.
Anyone who may be affected by this regulation should read over the Notice of Proposed Rulemaking (NPRM). It is worthwhile to consider what equipment and other changes...