Understanding Sub M training requirements

There is no stronger driver of positive safety culture than employee empowerment supported by training excellence. The difference between an operator that trains out of obligation and one that views training as a critical part of a strong safety culture can be felt the moment you step onto a vessel. It can be seen in the way the crew interacts, in the way they perform their duties, and in the condition of the vessels.

It would be an understatement to say that Subchapter M is on the minds of workboat operators. However, there is limited discussion surrounding the training implications of Subchapter M. This is not surprising — the regulations themselves devote little to training. There are many other issues that require the full attention of operators: SMS implementation, operational changes, and so on.

All too often, training only becomes an imperative when a lack of it creates an event that cannot be ignored. However, training drives safety. In one study, Capt. Stephen Cross of the Maritime Institute Willem Barentsz determined that the human element contributes to approximately 80% of maritime accidents. Of those accidents, roughly 81% were due to a lack of sufficient training. The link between insufficient training and accidents is well established, and the training implications of a new regulation such as Subchapter M cannot be ignored.

What training is required under Subchapter M?

Subchapter M provides some direction on those operational aspects that require training. However, it does not discuss how training is to occur nor how it is to be evaluated. This is common in maritime regulations as operations vary widely from one operator to another. In a perfect world, the requirements would also account for training methods. The difference between good and bad training is vast. So, keep in mind that the methods used are as important as what needs to be taught.

Section 140 – Operations is the most important from a training perspective, especially Section 140.515:

  1. Subsection (a), covers the need to train general health and safety information such as knowledge of the health and safety plan, procedures for reporting unsafe conditions, PPE, hazard communication, etc.
  2. Subsection (b) covers the need to understand hazards relevant to each trainee’s potential exposure on or around the vessel.
  3. Subsections (c) and (d) speak to when training must occur and how frequently refresher training is provided.
  4. Subsection (e) speaks to training for non-crewmembers.
  5. Subsection (f) covers training documentation.

Other sections also include training requirements. For example, section 140.410 states the need to hold and document safety orientations. Section 140.420 covers the requirement to conduct drills and their frequency. Section 140.645 covers navigation safety training, watch-keeping terms, reporting procedures and so on. All sections need to become part of a structured training program.

In addition to these high-level explicit training requirements, a range of other requirements are sprinkled throughout the section. It would be a good exercise for every operator to carefully read Section 140, and make a list of items to add to their training program. An operator that trains only to the explicit requirements sets itself — and more importantly, its employees — up for failure.

Training vs. understanding

Possibly more important than the training requirements of Subchapter M is how we choose to teach them. Do we train only the knowledge and skill? Or do we ensure that our crew understand the critical role and important contribution that is required of each of them so that the team can achieve safe operations?

Every item being trained represents an opportunity to understand not just the what, but more importantly, the why of the need to “get it right.” In this way, every training requirement in Subchapter M can be looked at as an opportunity to build a positive culture, not just to convey information.

It’s up to you!

Subchapter M provides great freedom for operators in terms of training methodology. While this is necessary, it does mean that operators are free to implement effective or ineffective practices. Creating a training program which adheres to the letter of the requirements but not the spirit of training excellence will adversely affect performance and safety. As indicated above, the difference between the two can be seen in the way your crew interacts, in the way they perform their duties, and in the condition of your vessels.

About the author

Murray Goldberg

Murray Goldberg is the founder and CEO of Marine Learning Systems Inc., based in Vancouver, BC, and a frequent consultant and speaker on the future of eLearning.

2 Comments

  1. Robert Russo on

    Interesting but as a TPO auditor I am looking for documentation AND proficiency in the knowledge and understanding. Documenting a crew member watched a video simply isn’t enough.

    • Vincent Caruso on

      As an employee let me say that in my 34 years on tugs and then ferries videos were our opportunities for a nap. The most effective classes had the instructure that made the class/information relevant to our specific jobs and work places. If he/she could keep us engaged he did his job.

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