Management based systems such as a TSMS must meet the regulatory criteria while at the same time reflect reality, be accepted by the crews and fully implemented, or they can lead to significant fines and be used as “checklists for negligence” against the company or the crew during litigation.  Our process in developing a TSMS includes, recommended policies and procedures, review by key employees ashore and afloat, consensus and revision of all policies and procedures, distribution of manuals, use of the Safety Management Workbook as a TSMS qualification program which requires crews to research up to 90 different scenarios in order to learn the contents of the TSMS.