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Regulations Figure 1 – FunctiOnal requirements summary 46 CFR 138.215 FunCtional RequiRements oF a towing saFety management system (tsms) RCP ii. management and administRation (a) Policies and procedures to provide direction for the safe operation of the towing vessels and protection of the environment in compliance with applicable U.S. law Each towing company should develop and document written policies and procedures covering, at a minimum, those items outlined below. Companies should abide by these policies in conducting their operations and should ensure that their employees are aware of, and trained in, those policies and procedures which affect their job responsibilities. Companies should develop a mission statement expressing their commitment to abide by their established policies and procedures and to ensure employee awareness and knowledge thereof. All AWO carrier members, as a baseline, should be in compliance with all applicable federal laws and regulations concerning marine safety and environmental protection (b) Defined levels of authority and lines of communication between shoreside and vessel personnel; I. Organization and Levels of Authority 1. Depict company organization and document authority and general responsibilities of individuals at different levels, including vessel master and crew (c) Procedures for reporting accidents and non-conformities; B. Safety Policy and Procedures 4) Reporting of safety deficiencies and/or nonconformities E. Incident Reporting Procedures (d) Procedures to prepare for and respond to emergency situations by shoreside and vessel personnel; F. Emergency Response Procedures (e) Procedures for verification of vessel compliance with this subchapter; G. Internal Audit and Review Procedures (f) Procedures to manage contracted services; H. Vendor Safety (g) Procedures for internal auditing of the TSMS; including shoreside and vessels; G. Internal Audit and Review Procedures (h) Procedures for external audits RCP Addendum C. Audit Issues (i) Procedures for management review of internal and external audit reports and correction of nonconformities G. Internal Audit and Review Procedures 2. Vessel OperatiOnal prOcedures Policies and procedures are required to ensure compliance with part 140 “Operations” that relates to a number of vessel operational concerns that pertain to primarily above-deck operations including: • Pre-departure gear tests and inspections; • Vessel stability and water-tightness; • Navigational safety equipment operation and related recordkeeping; • Underway navigation; • Lookout; • Navigation watch assessment; • Pilothouse resource management; and • Navigation safety training. The RCP requires vessel operating procedures that address bridge transit, voyage planning for companies with operations on coastal routes, horsepower/tow size decisions, and fuel transfer. 22 MARINE LOG March 2014 Part 140 requirements additionally pertain to the health and safety of all crewmembers as presented by safe-working practices. 3. Vessel equipment installatiOns Policies and procedures are required to ensure compliance with part 143 “Machinery and Electrical Systems and Equipment” and part 144 “Construction and Arrangement.” These parts present detailed requirements regarding machinery and electrical installations that greatly exceed the “Equipment and Inspection” standards of the RCP. As the proposed rule currently stands, detailed expectations regarding the design, installation, operation, maintenance, and testing of primary and auxiliary machiner y, electrical systems and equipment are presented as a series of requirements. Construction and arrangement standards apply to both existing and new towing vessels. Why are all these differences a good thing for the industry? The RCP has gathered broad support as the basis for safe tugboat and towboat operations for well over a decade. The Coast Guard took this into account in developing Subchapter M—including the TSMS compliance option. TSMS requirements enhance those of the RCP in the areas of vessel survey standards, operational standards, and machinery and structural standards. The success of a management system is based on the lasting improvements that it creates. TSMS requirements augment the RCP in areas that will most likely result in positive change over time. ■

March 2014 Marine Log Magazine

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