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 substitute for educating yourself. Understanding the ins and outs of operating as an inspected vessel empowers operators to protect themselves from costly compliance errors that can arise from misinformation. What sort of misinformation? I’ve heard a great deal lately, and have compiled a Top 10 list of incorrect assumptions about the rule.
1. Under Subchapter M a towing vessel must have a towing safety management system (TSMS).
2. If a company is currently operating under a voluntary safety management system, they must use the third-party TSMS option.
3. The masters will be insulated from the Coast Guard by sharp office employees.
4. If the Coast Guard finds a firefighting or lifesaving issue for which they would shut a boat down, a third-party surveyor will be able to let the boat continue to operate.
5. An audit involves a plan review and vessel survey only, not crew interviews to see if they know and follow the written policies and procedures.
6. If a towboat claims to be a fleet boat in order to minimize equipment requirements, the Certificate of Inspection (COI) will not restrict its operations to a particular fleet.
7. “I don’t know, but I know where to look it up,” is typically a satisfactory answer to questions from the Coast Guard.
8. The Coast Guard wants you to use the third-party TSMS option, and may even retaliate if you don’t because they are understaffed.
9. A captain cannot have his license revoked for failure to follow the safety management policies and procedures.
10. An auditor or surveyor cannot go to jail for passing a vessel audit or survey when the vessel or company does not meet the standard.
Remember, the list above summarizes common misinformation about Subchapter M. Don’t fall victim and start at a disadvantage. Do the research, get educated, and decide for yourself what’s best for your company.
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The views and opinions expressed in this blog are the author's and not necessarily those of WorkBoat.
