Get Started! Benefits, Advice Abound for SMS Laggards
When industry players say “the handwriting is on the wall,” they aren’t just talking about the pending Subchapter M regulations, but also about the already existing demand for safety management systems (SMS) in general for the domestic towing industry. While the U.S. Coast Guard and Homeland Security work to finalize Subchapter M requirements, operators are already finding it harder to win bids without some level of a Towing Safety Management System (TSMS) and ensuing proof of compliance.
The oil majors, Mexico and many clients already insist on adherence to safety standards, and in some cases they are aggressively conducting their own audits of contractors and reminding them to use JSAs. That has spurred companies like McAllister Towing and Transportation Co., Inc. to add International Safety Management (ISM) compliance to their SMS toolbox along with its American Waterways Operators’ (AWO) Responsible Carrier Program (RCP) certification.
“Clients definitely care. There are certain rig companies that only allow ISM companies to move their rigs,” says Anthony Roberts, marine traffic/operations officer for Louisiana International Marine (LIM), which is also ISM compliant. That’s why savvy operators aren’t waiting for the SubM ball to drop. They’ve already gotten, or are in the process of getting, certified under the IMO’s ISM program and or the AWO’s RCP, which is mandatory for its members.
“When our safety officer looked into Subchapter M a few years ago, at the time, we didn’t know if it would ever come into effect. We figured we’d do ISM and do the voluntary inspections,” Roberts says, noting that ISM compliance will put the company on par with whatever Subchapter M requires. “We figured that we would be ahead of the game as far as safety standards and wanted to be better than the next guy.”
Gulf Coast Tugs is another company that decided early on to embrace ISM certification. “I knew I’d be on top of the food chain as far as any requirements,” says president and owner Ken Hebert. “It puts you among the elite in that clients know what we have and how we run the ship and company professionally.”
Not waiting carries many benefits, not the least of which is crew safety. “I don’t think you can really measure the impact of less injuries monetarily. If you do these things, if you train people, you will automatically cut down on accidents. Saves you right off the bat,” says Roberts. A tangible money saver is having the time to schedule required inspections of your vessels between runs, when it’s convenient for the operators. “If you are waiting for Sub M to be finalized, you are going to be in big trouble,” says Hebert. “The cost will be a lot more if it hits all your boats at once. You’ll have to take your boat(s) out of service. If it’s not working, there’s no revenue, you can’t pay people,” he notes.
“How smart do you want to be? You know the company and the industry are always changing, and you gotta change with it,” says Hebert.
So where do the companies who have done little or nothing in terms of formalizing safety management begin?
“Every organization has some sort of operations manual; that’s really what you are starting with,” says Buckley McAllister, president of McAllister Towing. From there, he says, the AWO RCP “is a pretty good firm checklist of what folks want to see in an SMS, so that’s a pretty good starting point.”
SMS tutorials and webinars are another option. One such example is the Subchapter M seminar run by class society ABS and its sister company ABS Group. Ian McVicker, towing vessel coordinator for ABS Group, who gives a soup-to-nuts presentation on the subject, ticks off the following to-do list for those just embarking on the journey to safety compliance and certification:
- Visit or Revisit the U.S. Coast Guard’s August 2011 notice of proposed rulemaking.
- Before the rule comes out, document all that you can during current dry docks. Some of that documentation can be used as objective evidence toward a Certificate of Inspection.
- Talk to your partners, be it a shipyard, service vendor or other partner, and discuss compliance options and how they fit into the SubM mix.
- Discuss process and criteria for third-party selection.
- Figure out the training needed for SubM compliance.
- Assess your vessels. How close are they already to meeting the proposed rule, and what needs to be done to meet the requirements?
- Start planning how you will approach SubM.
Some vendor web sites, such as Helm Operations, offer up a wealth of tips, explainers and advice on how to get started. Here’s a quick to-do list from Helm:
- Pull your vessels out of the water and get them inspected. Check the U.S. Coast Guard for a list of the 10 most common towing vessel deficiencies.
- Begin developing a safety management system
- Develop internal audit expertise
- Install and train on new required equipment, like automatic external defibrillators
- Analyze your training gaps
- Learn and prepare
(As published in the September 2015 edition of Marine News - http://magazines.marinelink.com/Magazines/MaritimeNews)