Understanding what a Towing Safety Management System (TSMS) is all about — and what it isn’t all about — is extremely important.
It’s essentially a safety management system (SMS) tailored to the towing industry and is specific to the operational details and needs of a given company — at least in theory. A TSMS is not meant to be a one-size-fits-all static document. It can and should evolve over time as changing operations, procedures, technology and regulations dictate. And despite the towing industry finally shedding the uninspected label, it is not a legal requirement for a towing company to have a TSMS. The Subchapter M inspection regulations offer it as an option in lieu of a traditional, direct Coast Guard inspection. For a company that chooses a direct Coast Guard inspection for their vessel or vessels, no TSMS is required.
By not having a full-blown, “approved” TSMS in place does not imply that a given company is less committed to operational safety than those that do have one. Conversely, merely having an approved TSMS is no guarantee that a company has it together safetywise or is “safer” than a company that does not have one in place. Just like a mariner with a “bigger license” is not automatically superior in any fundamental way to another mariner who has a lower grade license. Quality is always a big variable, and what you see is often not what you get.
In any case, a thorough, well written, regularly updated operations manual that is thoughtfully implemented can be as effective or more effective than some randomly chosen TSMS. In fact, such operations manuals are absolutely necessary and form the backbone of any good TSMS. For either to be worthwhile it all depends on how they’re used, and whether or not there is a genuine, long-term commitment to developing and maintaining a good knowledge-based safety culture. Without those elements it will be both ineffective and a big waste of time and energy. The example must be set from the top down.
For those of us at the user end, a TSMS can either be a useful tool or a source of frustration and apathy.