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 Safety Management System (TSMS) option structured to look very much like ISM.

Here's how the ISM Code works. Once a company chooses, or is required by regulation, to adopt ISM, a safety management manual is put together in accordance with the ISM Code (hopefully not bought off the shelf). The company then contracts with a “recognized organization,” such as an authorized classification society, who reviews the manual, audits the company and vessels, and issues the international certificates on behalf of the flag. A similar process is included in Subchapter M. The “recognized organization” is called a “third-party organization.”

The company refines their processes and manual, and works toward implementation. The SMS manual is then submitted to the recognized organization for review and approval. During this desktop review, the classification society makes sure the manual includes all the requirements of the ISM Code, the flag state, the International Maritime Organization (IMO), and of the classification society. The safety management manual is then approved. A comprehensive manual review does not occur every time the vessel is audited.

Once the manual is approved, audits are scheduled. First, an office audit is done to ensure the company is following the requirements of the company’s SMS manual. If the company passes the audit, a Document of Compliance (DOC) is issued. There is no equivalent to the DOC in Subchapter M. Next is an audit of each vessel to ensure they are following the requirements of the company’s SMS manual. The main players in this process are the master of the vessel and the auditor. Often, no one else from the company is present. If the vessel passes the audit, a Safety Management Certificate (SMC) is issued to the vessel. There is an equivalent to the SMC in Subchapter M — a Towing Safety Management Certificate (TSMC).

I find it strange that a towing industry “audit” usually includes an entire plan review and a comprehensive inspection of the vessel. During an ISM audit the auditor will walk through the vessel with a focus on verifying certain items from the SMS manual policies and procedures. However, an entire inspection or survey of the vessel is not conducted. That is an entirely separate function conducted by flag-state inspectors. These two separate processes are distinct in Subchapter M. The proposed Subchapter M calls for, if chosen, the use of third-party surveyors to conduct the flag-state inspection (survey) of the towing vessel, in addition to the use of third-party auditors to audit implementation of the TSMS. However, Subchapter M, vessel survey items can be done under an audited program.

Hopefully, Subchapter M will follow ISM, and the TSMS manual will be reviewed and approved up front and the survey function will be kept separate from the audit function. It is essential that an auditor is not bogged down with such repetitive duties. That will allow him or her to focus on the task at hand, which is ensuring that the vessel is operated in accordance with the applicable TSMS policies and procedures.


The views and opinions expressed in this blog are the author's and not necessarily those of WorkBoat.

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