Steven Douglas from the Coast Guard Towing Vessel National Center of Expertise shares on Sub M excepted vessel requirements in Paducah, Kentucky
More than 40 tugboat owners and operators accompanied by several U.S. Coast Guard (USCG) personnel attended ABS seminars across Paducah, New Orleans and Houston to prepare for upcoming Subchapter M implementation timelines. The three seminars informed participants on the measures needed to begin demonstrating existing vessel compliance with 46 CFR Subchapter M regulations, effective July 20, 2018, and provided an opportunity to discuss questions concerning regulation compliance, interpretation, applicability and solutions.
Prior to implementation, owners and operators choose which compliance option best fit their needs. ABS Regional Vice President Joshua LaVire, ABS District Manager Dennis Bryson and ABS Operations Coordinator Paul Hite educated attendees on the regulation compliance options differentiating between the USCG Option and the Towing Safety Management Systems (TSMS) option. In regards to the TSMS option, the seminar hosts defined the roles and responsibilities of Third Party Organizations (TPOs) in performing external and or interval surveys, examinations and audits. Alternate compliance solutions under TSMS include the International Safety Management (ISM) and the Responsible Carrier Program (RCP). Both TSMS options were reviewed and compared by walkthrough of a GAP analysis.
With attendance of USCG personnel, seminar hosts fielded frequently asked questions from both attendees and common questions around the industry. Questions discussed by ABS hosts and USCG personnel pertained to exempt vessels, major modifications, COI issuance for large fleets, documentation required post survey, exam and audits, manning requirements between zones, TSMS vessel requirements at different ports and more.
The high attendance at these seminars highlight the importance of continuing the dialogue between tug owners and operators, USCG and Recognized Organizations such as ABS to inform and clarify on all matters related to Subchapter M. The ABS seminar program is integral to the provision of advice and practical guidance on the implications and implementation of new maritime regulations.