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(Sub) Chapter M Finally Surfaces

Maritime Activity Reports, Inc.

February 12, 2013

For inland operators, Compliance, Safety & Technology make for heavy river traffic as software providers descend on a rapidly approaching, potentially lucrative niche market. Is there a panacea for subchapter M?

Pending USCG Subchapter “M” (SubM) regulations will eventually require towing operators to implement safety standards and use safety management systems, or alternatively, allow for an annual Coast Guard inspection regime. The new rules are expected to allow towing vessel organizations to customize their approach to meeting the requirements, while providing oversight using audits, inspections, and reviews of safety data. As many as 5,000 vessels and their operators will eventually feel the impact of the so-called subchapter M rules. Today, almost 1,800 domestic towing vessels do not participate in any formal industry safety schemes.
With the final language not yet determined, software developers are nevertheless pushing their solutions forward, in advance of the rule itself. Beyond this, markedly different approaches to the problem are emerging. As operators try to decide what to do next, one size may not fit all customers. 
Marine software, by now a familiar fixture on the inland waterfront, is being pushed forward as at least part of the panacea for this newest regulatory burden. For Inland operators, just knowing where to start can be as intimidating as the new rules themselves. And, not everyone can afford an enterprise solution. That’s Okay: this month, MarineNews sorts it out for you.

Baker Lyman / GL Alliance
Baker Lyman (BL) is known primarily as a Chart Agent has branched out into maritime software. When BL and Germanischer Lloyd (GL) this summer announced a strategic partnership intended to provide a turnkey Towing Safety Management System (TSMS) design, audit and record-keeping service to towing firms, it caught everyone’s attention. First out of the box, they are also no longer alone in this arena.
The Alliance has since announced that SCORE-Global of Covington, KY has been become the Alliance’s newest partner. Tug & Barge Solutions (TBS) of Mobile joined the organization in September of last year. Together, the four hope to corner the market for subchapter M compliance.
According to Baker Lyman, each Alliance partner is expert in the Sub-Chapter M processes. TBS conducts assessments and writes plans. Baker Lyman provides recordkeeping solutions with their type-approved CORSAIR TVR software. Classification society Germanischer Lloyd will certify TSMS plans and conduct office and vessel TSMS audits. SCORE-Global will provide non-exclusive auditing, risk assessments, and insurance/underwriting vetting services.
While the Sub-Chapter M language has not been finalized, the Alliance nevertheless encourages clients to enroll in their TSMS Transition Program. With the backdrop of industry worries of a looming dearth of TSMS service capacities for the Sub-Chapter M implementation, the new pact between these maritime providers is billed as a ‘one stop shop’ for Sub-M impacted operators. According to Baker Lyman, the RCP-TSMS Model Transition Plan will allow current AWO RCP companies to enroll into a statutorily certified TSMS process, prior to the definition of the Sub-Chapter M Final Rule.

Boatracs, Inc., a provider of integrated satellite communications and software solutions to the maritime industry recently announced that it had formed a strategic partnership with Maritime Compliance International, LLC (MCI). The two companies are collaborating in the development of a new electronic forms software product designed specifically for compliance management of the upcoming Coast Guard 46 CFR Subchapter “M” regulation.
Boatracs wanted to work with a partner that had experience with Coast Guard inspections, Towing Safety Management Systems (TSMS) and broader compliance issues. MCI was looking for a maritime software company to partner with because they were hearing from clients that the existing software solutions were too cumbersome, expensive and overwhelming.
According to MCI’s Kevin Gilheany and Boatracs President and CEO Irwin Rodriquez, one critical aspect of the Boatracs/MCI solution sets them apart. Featuring what they describe as “an automated Applicability Tool,” the single most difficult aspect of Subchapter M – determining what parts of the regulation apply to each individual vessel – can be solved immediately. The Boatracs Subchapter M software product begins with a set-up page of questions for each vessel, developed by Maritime Compliance International , that are designed to take a vessel owner through the entire regulation in a very manageable way. The answers build a Compliance Summary Form that details all of the Subchapter M requirements for that vessel, and the specific forms that will manage and document compliance. 
In a nutshell, the new partnership’s Subchapter M approach is to provide inland operators with a compliance software product that has three goals: Guide users through the applicability of the regulation for each vessel; provide the forms and management tools to implement a compliance solution that is compatible with either a Coast Guard or Third Party Inspector; and make it simple to use on the vessel and on shore at an affordable price point for any size fleet. Forms required for each vessel are received shoreside through a web-based application that can be accessed from any PC, tablet or smart phone. Customers pay a turnkey monthly fee per vessel that includes all of the software, forms, updates and 24-hour live support.
The Boatracs partnership can accommodate customers who want a turnkey solution, because Maritime Compliance International is also experienced in producing plans, and conducting surveys and audits. Customers are also free to work with any inspector they choose. The Boatracs Subchapter M compliance software gives inland operators the choice to use either a third party inspection or a Coast Guard inspection and will support a physical audit conducted by any professional qualified to perform that audit.

Helm (eDoc)
Recently, this firm changed its brand to Helm, from eDoc, reflecting that the software they develop is Helm Marine Operations software. As their sole product, and in order to give the flexibility to scale into other products, the brand is evolving to Helm Operations.
According to eDoc’s Manager of Marketing, Rodger Bannister, safety comes from the top of every organization. He adds, “SubM is only a small part of our offerings – we take a very wholistic approach and function from all areas of the company. Not just on the boats, not just from subM, but throughout the organization.” He adds that a safety system must be auditable and include a checklist and he insists, “It doesn’t matter if you are using RCP or SubM – the software is configurable. The final version of the new rules is not even out. How can you have a neatly packaged program with no set program?”
In business and with its roots squarely in the maritime arena, Helm usually works with firms who have at least 15 vessels in their fleet. Most have a safety director on board. “They’re so knowledgeable - the companies teach us,” says Bannister. He adds, “SubM will be an evolution of RCP / AWO. This is vendor driven safety compliance and stems from the need to ‘systemize safety’ – or, in other words, a TSMA.”
That’s because, says to eDoc’s Manager of Business Development, Paul Cyr, RCP users are using eDoc right now, and systemizing TSMA for their oil major clients is just as important. Indeed, some are already doing more than that already.
Addressing the need to appeal to smaller clients as Sub M evolves, eDoc is moving some of their offerings – including their SubM solutions – to software as a service (SAS). The new delivery option will host data “in the cloud” and will eliminate the need for a heavy install in terms of hardware, etc. 
eDoc’s Cyr advocates first setting up a SMS properly and then customizing the software to fit the solution. He cautions those just dipping their toes into the SubM waters, “SubM isn’t the only thing to comply with. Don’t lose sight of safety while you worry about mere compliance. You do not have to re-invent the wheel.” Beyond this, he says, trying to reverse-engineer software first is a mistake; especially in advance of regulations which have not yet been finalized.

MarineCFO Live! is a web-based, software solution to manage personnel, jobs and billing, maintenance & schedules. Designed for small or medium-sized marine companies, it is web-based so there is no need to install servers. MarineCFO Enterprise is a software solution used to automate business processes from the boat straight through dispatch, personnel, safety, maintenance and financial reporting. It’s modular, enterprise-ready and customizable. MarineCFO does not market software for other markets – providing marine software for the marine industry is all they do. Because of this and with the advent of subchapter M for inland operators, MarineCFO is arguably well positioned for what is to come next.
In addition to myriad other purposes, MarineCFO provides a robust financial management solution which completes the system and provides a true “boat to balance sheet” offering. Operating on the basis that everything has a financial impact, the software seamlessly integrates and combines stovepiped data. And it is here where MarineCFO differs from other software solutions, asking, “How much does it cost to meet Sub-M and what does it mean to your bottom line?”
Dean Shoultz, MarineCFO’s CTO, told MarineNews, “We didn’t have to change our system, software or add to it. Ours is configurable. The HS&E module brings it all together. Already, that module addresses safety.” He added that configurable software – as many as 70 modules are possible – for the subM solution will be important, because no one yet knows what the final regulatory language will be. MarineCFO’s flexible system can be used as a TSMS, or to support and schedule the annual inspection method.
According to Shoultz, MarineCFO marries the complexities of adhering to the regulations with the harsh financial cash flow and economic realities mandated by those strategies. Shoultz adds, “The more profound impact of the new and pending regulations is the financial aspect. CFO addresses and helps manage that component.” Some MarineCFO clients have as many as 150 concurrent users on the firm’s flagship software suite. On the other hand, MarineCFO live – a much more affordable solution starting at $39/ month – is an online, cloud version, but caters to smaller operations groups.
Addressing the subject of the inspections themselves, Shoultz admits that MarineCFO does not perform inspections, but instead says, “We can put you in touch with right people who do.” Beyond this, he adds, “We’re not looking to monetize subM opportunities. Instead, we hope to minimize costs for our clients. You need to connect the dots between inspection checklists and financial implications. You cannot separate the two.”

Tugboat Compliance Systems
Tugboat Compliance Systems began in 2007 when Dana Teicheira, working as an Auditor for the American Waterway Operators Responsible Carriers Program, noticed the difficulty that smaller companies were having in maintaining their Safety Management Systems. Tugboat Compliance Systems is billed as a cost effective alternative for smaller outfits needing to manage a safety management system in a standalone version. In a pre-subchapter M world, there are a lot of operators in this particular boat.
According to Teicheira, his system is ideal smaller companies with 1 to 5 tugs. Set up as a “software as a solution,” with web-based cloud delivery, it comes complete with a secure data center. This results in lower initial investment and a transfer of the traditional IT duties to the software provider. Teicheira adds, “Just the ticket for small and medium sized operators.”
As he performed audits over the years, Teicheira found that safety programs and protocols were usually in place, but largely informal in their application. Beyond this, the sometimes-proprietary in-house computer programs used to facilitate these duties became neglected once the in-house IT facilitator left the company. With a Safety Management System (SMS) software adjunct for auditing safety in mind, Tugboat Compliance Systems aims to be the towing industry’s version of the bluewater SMS. TugBoat Compliance software contains all the components of RCP – digitizing and leading to better data and time-stamped alarms. Specifically geared to Subchapter “M” / RCP requirements, the system can integrate existing data but also can also be set up for those who don’t have a system already, easily creating templates and reports.
The Tugboat Compliance solution could also be packaged as a turnkey service; software plus recertification inspections. But, Tiecheira admits that initial certifications using a software / SMS provider that also does the inspections may represent a conflict of interest. Today, Tugboat compliance Systems already has a set of existing clients; with a few of those in the “turnkey” client category. Can a software firm born as the brainchild surveyor/auditor wear both hats in the subM game? It appears that it can. But, as Tiecheira likes to put it – perhaps in reference to the enterprise providers who provide the entire soup-to-nuts operating software suite, “We do one thing – not a thousand.”

(As published in the February 2013 edition of Marine News -

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