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Audits, Manual Reviews, and Surveys

An audit should not include a comprehensive manual review and comprehensive inspection of a vessel. These three functions should be kept separate and distinct in order to preserve the quality of the audit.

My experience as a Coast Guard marine inspector in verifying audited programs, was all based around International Safety Management (ISM). As proposed, Subchapter M offers a Towing Safety Management System (TSMS) option structured to look very much like ISM. For those readers unfamiliar with how ISM works, these are the basics of the program. Once a company chooses, or is required by regulation, to adopt ISM, a safety management manual is put together in accordance with the ISM Code (hopefully not bought off the shelf). The Company then contracts with a “recognized organization,” such as an authorized classification society, who will review the manual, audit company and vessels, and issue the international certificates on behalf of the flag. This process is included in Subchapter M, however, the “recognized organization” is referred to a “third party organization.”

The company takes time to refine their processes, and their manual, and works toward implementation. The SMS manual is then submitted to the recognized organization (authorized classification society) for review and approval. During this desktop review, the classification society makes sure that it includes all the requirements of, the ISM Code, the flag state, the International Maritime Organization (IMO), and of that particular classification society. The safety management manual is then “approved.” A comprehensive manual review does not occur every time the vessel is audited.

Once the manual is approved, audits are scheduled. First an office audit to ensure the company is following the requirements of the company’s SMS manual. If the company passes the audit a Document of Compliance (DOC) is issued to the company. There is no equivalent to the DOC in Subchapter M. Then comes an audit of each vessel to ensure that the vessel is following the requirements of the company’s SMS manual. The main players in this process are the master of the vessel and the auditor. Often times no one else from the company is present. If the vessel passes the audit, a Safety Management Certificate (SMC) is issued to the vessel. There is an equivalent to the SMC in Subchapter M, as it calls for a Towing Safety Management Certificate (TSMC) to be issued to the vessel.

Having been involved with towing industry audits since my retirement from the Coast Guard, I have found it strange that an “audit” usually includes an entire plan review and a comprehensive inspection of the vessel. During an ISM audit the auditor will walk-through the vessel with a focus on verifying certain items from the SMS manual policies and procedures. However, an entire inspection, or survey, of the vessel is not conducted. That is an entirely separate function conducted by flag state inspectors. These two separate processes are distinct in Subchapter M, as the proposed Subchapter calls for, if chosen, the use of third party surveyors to conduct the flag state inspection (survey) of the towing vessel, in addition to the use of third party auditors to audit implementation of the TSMS. However, the Subchapter does allow for getting the vessel survey items done under an audited program.

Hopefully, Subchapter M will follow ISM in that the TSMS manual will be reviewed and approved up front, and the survey function will be kept separate from the audit function. It is essential to not bog down an auditor with such repetitive duties, and allow him to focus on the task at hand: ensuring the vessel is being operated in accordance with the TSMS policies and procedures applicable to the vessel.
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