Class Society Gears Up for Subchapter M
After almost 12 years since the US Congress first recommended that the towing industry improve safety, the final Subchapter M rule has been released. It will be formally published on June 20 and will take effect July 20, imposing new compliance requirements for inspection and safety management.
Until now, inland towing vessels have not been inspected by the U.S. Coast Guard (USCG). The level of inspection required will become generally the same as is seen in blue-water and passenger ships in terms of safety, record-keeping, COI-issuance, manning and other requirements similar to ISM and blue-water shipping.
RINA and Tug and Barge Solutions (TBS) are taking a flexible, lean approach to helping towing vessel operators comply, leveraging their combined technology and industry knowledge to offer an affordable, safe and efficient option.
Subchapter M outlines two methods for operators to reach compliance. The first is the TSMS (Towing Safety Management System) Option, which requires a company to develop and implement a TSMS and then be subject to external audits/physical surveys twice every five years. The second method is the USCG Option, which is an annual inspection by the USCG in conjunction with the development of a company health and safety plan. The USCG Option entails “user fees” which are presently set at $1030 per year, equivalent to the amount for other inspected vessels.
RINA and TBS have chosen to focus on helping small to medium-sized operators who chose the TSMS Option, as most larger companies will have the resources to comply through internal departments. Large operators can essentially hire a team of experts – like the team TBS has on staff – to create and manage their safety and compliance functions in house. For smaller firms, RINA and TBS’ “out-sourced” approach will save time and money and provide a solution tailored specifically to the needs of different operators and their various towing operations. The training services RINA provide are tailored to what each crew does in a specific company. These will be documented using the safety management system developed by TBS, which is also tailored to each specific company operation.
Typically, TBS trains a crew to properly conduct and record specific types of company training, and then conducts internal audits to insure compliance. Some companies perform in-house training, but it is not comprehensive or widespread.
RINA can now certify TBS systems, conduct class surveys, and issue SMCs (Safety Management Certificates), which are required to obtain the COI (Certificate of Inspection) from the United States Coast Guard, along with the other towing services it already provides (such as load-line certificates).
RINA and TBS will also join American Waterways Operators, a national advocate for the US tugboat, towboat and barge industry, which promotes the long-term economic soundness of the industry and works to enhance its ability to provide safe, efficient, and environmentally responsible transportation.
The opinions expressed herein are the author's and not necessarily those of The Maritime Executive.