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Regulations Setting a poSitive courSe ug and barge operators should navigate cautiously when it comes to the Towing Safety Management System (TSMS) proposed under the Subchapter M Inspection of Towing Vessels rule. The American Waterways Operators (AWO) and many of its members are under the impression that the TSMS is equivalent to AWO’s voluntary code of conduct—the Responsible Carrier Program (RCP). While the RCP addresses many of the same concerns within the rule’s outline for a TSMS, a number of proposed requirements either are new or exceed those in current RCP standards. T • Relevant to an operator’s organization and objectives; • Comply with applicable rules, regulations and guidelines; • Effective to achieve wanted results in the areas of operations, safety, and pollution prevention, while mitigating risks; • Sustainable over time while incorporating a process for continual improvement; and • Consistent with the plan-do-check-act cycle. Functional requirements aside, the RCP and TSMS also align partially in other areas concerning personnel policies and training, equipment inspection, and towing equipment requirements and specifications. What are the similarities? What are the differences? The RCP introduces topics to be addressed by a company within documented policies and procedures. Topics include a wide range of concerns and indeed several do overlap with Subchapter M including those that relate to functional requirements of a TSMS as summarized by Figure 1. So-called functional requirements of a management system describe the categories and types of controls intended to make a system: Subchapter M currently specifies that more requirements be incorporated into a TSMS than the baseline standards comprising the RCP in several key areas. 20 MARINE LOG March 2014 1. Survey ProgramS The TSMS must incorporate requirements to establish all aspects of a company’s survey program including: • Survey performance and related testing; • Details of equipment, systems, and By William Mahoney, SMS, LLC onboard procedures to be surveyed; • Surveyor qualifications; • Procedures for documenting and reporting major non-conformities, nonconformities, and deficiencies; • Procedures for reporting and correcting major non-conformities; • A manager who has the authority to stop vessel operations pending correction of non-conformities and deficiencies, oversee vessel compliance activities, and track and verify that non-conformities and deficiencies were corrected; • Procedures for recordkeeping; and • Notification and involvement of thirdparty organizations and OCMI under certain conditions. Note that annual survey expectations do not focus exclusively on hull and machinery items. As currently proposed, such events also establish an additional tier of verification by checking audit results, vessel recordkeeping, observation of drills or training, etc. Normally such activities would be verified during internal audits of the management system. Within Subchapter M, the survey is presented as an additional means of checking success in these areas. Glynnis Jones / for compliance

March 2014 Marine Log Magazine

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