Maritime Compliance Report
Welcome. Staying in compliance takes dedication, diligence and strong leadership skills to stay on top of all the requirements which seem to keep coming at a rapid pace. With this blog I hope to provide visitors with content that will help them in their daily work of staying in compliance. I hope you find it a resource worthy of your time and I look forward to your feedback, questions, comments and concerns. Thanks for stopping by.
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Safety Management – The Right Way
While there are plenty of examples of how safety management can be implemented incorrectly, I'd like to share with you an example of how to do it right, from scratch.
Last fall we contracted with American Tugs, Inc. in Puerto Rico, to develop and implement a safety management system. Not just any safety management system, but a Towing Safety Management System (TSMS) which would meet the requirements laid out in the Notice of Proposed Rule Making (NPRM) for 46 CFR Subchapter M. Here's how we did it:
Developing the TSMS – We followed the format laid out in 46 CFR part 138.220, and determined that the TSMS would have five major sections. We left Section 4 - Compliance with Subchapter M "reserved for the Final Rule." The company provided their standard operating procedures and we included our recommended policies and procedures and standard industry practices in the appropriate sections. We drafted the TSMS in accordance with our company philosophy that the policies and procedures must be concise and written in a way that can be read, understood, and followed by all.
Company review – The draft TSMS was then passed along to American Tugs, with the instructions to have all responsible parties, including company personnel and vessel captains, to read through the draft, provided input and edits. The company did an outstanding job of reading the entire draft and questioning many of the policies and procedures. They requested a number of changes, all which had to be checked against the regulations to ensure full compliance. It was critical to achieve buy-in from the captains by ensuring their expertise on the policies and procedures was included.
Coaching program – At the same time American Tugs contracted with us for a comprehensive coaching program for the two company personnel responsible for compliance, health, safety, security and environment issues. The coaching program was essential for them to understand where all the regulations come from, USCG, EPA, OSHA, etc.., and why such policies and procedures were required. The three month coaching also included the essential leadership and management skills to ensure the program is successfully implemented over the long term.
Implementation – The Company is now entering into the implementation phase. We will continue to assist them throughout the year with on board inspection; training and drills to ensure the captains and crews understand the importance of the program and how to properly execute it.
It has been a very rewarding experience working with American Tugs, Inc., a company fully dedicated to a program which will surely reap substantial benefits from their hard work in the years to come.
Last fall we contracted with American Tugs, Inc. in Puerto Rico, to develop and implement a safety management system. Not just any safety management system, but a Towing Safety Management System (TSMS) which would meet the requirements laid out in the Notice of Proposed Rule Making (NPRM) for 46 CFR Subchapter M. Here's how we did it:
Developing the TSMS – We followed the format laid out in 46 CFR part 138.220, and determined that the TSMS would have five major sections. We left Section 4 - Compliance with Subchapter M "reserved for the Final Rule." The company provided their standard operating procedures and we included our recommended policies and procedures and standard industry practices in the appropriate sections. We drafted the TSMS in accordance with our company philosophy that the policies and procedures must be concise and written in a way that can be read, understood, and followed by all.
Company review – The draft TSMS was then passed along to American Tugs, with the instructions to have all responsible parties, including company personnel and vessel captains, to read through the draft, provided input and edits. The company did an outstanding job of reading the entire draft and questioning many of the policies and procedures. They requested a number of changes, all which had to be checked against the regulations to ensure full compliance. It was critical to achieve buy-in from the captains by ensuring their expertise on the policies and procedures was included.
Coaching program – At the same time American Tugs contracted with us for a comprehensive coaching program for the two company personnel responsible for compliance, health, safety, security and environment issues. The coaching program was essential for them to understand where all the regulations come from, USCG, EPA, OSHA, etc.., and why such policies and procedures were required. The three month coaching also included the essential leadership and management skills to ensure the program is successfully implemented over the long term.
Implementation – The Company is now entering into the implementation phase. We will continue to assist them throughout the year with on board inspection; training and drills to ensure the captains and crews understand the importance of the program and how to properly execute it.
It has been a very rewarding experience working with American Tugs, Inc., a company fully dedicated to a program which will surely reap substantial benefits from their hard work in the years to come.
Previously published in my worlboat.com blog: Regulatory Roundup
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