Maritime Compliance Report
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Public Forum on New Towing Vessel Regulations
The public forum sponsored by Maritime Compliance International, LLC held in New Orleans on September 9 was intended to inform the industry, not just on the contents of the NPRM, but also to discuss the implications and the intent of it all. The forum provided industry stakeholders with an overview of the regulations along with some insights, based on my past experience as a Coast Guard marine inspector, as to what it all might look like when fully implemented. This spurred some interesting discussions and some great comments which will be posted to the docket.
It was interesting to find that not everyone was aware that the Subchapter offers a clear choice for operators between tradition Coast Guard inspections and the third party Towing Safety Management System option.
In addition to an overview of the regulations, I presented a session on "Safety Management Systems – Intent and Implications." It is important for all owners and operators to be fully educated on these issues so that they can make the best choice for their company.
Some of the comments made to be posted on the docket include:
One commenter mentioned the pilothouse alerter system initial alarm must be set to a volume which will be effective in alerting the operator, but not loud enough to disturb the other captain and crew sleeping immediately below the wheelhouse.
One commenter remarked that during certain TSAC meetings it was mentioned that Subchapter M would be similar to Subchapter T and L, and that he didn't find it similar to either.
One commenter mentioned that this proposed rule was very restrictive as to which company employees could conduct internal audits, which seemed to be in conflict with ISM protocol which is not so restrictive.
One commenter suggested that clarification was needed on reporting visitors on board and excursion requirements, to allow for standard industry practice.
One commenter expressed great disappointment in the fact that there were no requirements to address fatigue, such as manning and working hours.
It was interesting to find that not everyone was aware that the Subchapter offers a clear choice for operators between tradition Coast Guard inspections and the third party Towing Safety Management System option.
In addition to an overview of the regulations, I presented a session on "Safety Management Systems – Intent and Implications." It is important for all owners and operators to be fully educated on these issues so that they can make the best choice for their company.
Some of the comments made to be posted on the docket include:
One commenter mentioned the pilothouse alerter system initial alarm must be set to a volume which will be effective in alerting the operator, but not loud enough to disturb the other captain and crew sleeping immediately below the wheelhouse.
One commenter remarked that during certain TSAC meetings it was mentioned that Subchapter M would be similar to Subchapter T and L, and that he didn't find it similar to either.
One commenter mentioned that this proposed rule was very restrictive as to which company employees could conduct internal audits, which seemed to be in conflict with ISM protocol which is not so restrictive.
One commenter suggested that clarification was needed on reporting visitors on board and excursion requirements, to allow for standard industry practice.
One commenter expressed great disappointment in the fact that there were no requirements to address fatigue, such as manning and working hours.
Comments