Writing down the best procedure for a particular operation in a safety management system (SMS) helps standardize operations and minimize human error.
The content of each SMS will vary greatly, even within the same industry. That’s because it’s up to the company using or developing it to determine which operations should be included. Some regulatory requirements or industry programs dictate what topics require policies and procedures, but most provide general headings. For example, the International Safety Management (ISM) Code provides a general outline, such as Section 7 – Shipboard Operations. The company is expected to fill in the blanks.
Subchapter M is no different. The proposed requirements for the Towing Safety Management System (TSMS) contained in 46 CFR 138.220(c)(2) states: “Procedures must be in place to ensure safety of property, the environment and personnel.” But what procedures must be in place? This is where risk assessment comes into play.
What are the most dangerous evolutions that occur? How have people been hurt in the past? What caused a spill?
If a tugboat company handles lines all day every day, and parting lines pose a real and significant danger to crews, the company’s SMS should contain procedures based upon the line manufacturers’ specifications, inspect the lines regularly and know when they have become unserviceable.
Even if an auditor or government inspector doesn’t catch these omissions, the courts may. In a recent court decision involving a deckhand that was crushed to death in a capstan during a swing maneuver, the vessel was found to be “unseaworthy.” This ruling made the tug owner strictly liable under general maritime law. It was determined that the owner failed to adequately implement procedures and guidelines that would have provided the crew with the training, skill and knowledge to perform the maneuver safely.
Don’t buy a TSMS off the shelf. Get someone to facilitate the development of one specific for your company and make sure your best captains are involved in it.
