facebookgoogle+
Operational Excellence through Leadership and Compliance

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.

To avoid missing critical updates, don’t forget to sign up by clicking the white envelope in the blue toolbar below.

USCG on the Subchapter M Coast Guard Option

On October 4, 2016, I attended a joint Subchapter M conference in New Orleans put on by the American Waterways Operators (AWO) and the U.S. Coast Guard. The AWO representative gave a great overview of Subchapter M, with particular emphasis on issues of concern to industry that they have been working on with the Coast Guard. Both parties should be commended for their efforts and results.

Coast Guard comments
The presentation by the Coast Guard was given by Captain Verne Gifford, Chief of Inspections and Compliance at Coast Guard Headquarters. Much of Captain Gifford’s presentation focused on the Coast Guard’s efforts to incentivize the Third Party TSMS option. The Coast Guard is concerned about manpower issues to inspect the 5,719 towing vessels in the U.S.

I took the opportunity during the Q&A session to ask Captain Gifford to address some of the concerns I had heard from industry in response to the latest round of Subchapter M frequently asked questions (FAQs) issued by headquarters. I told the Captain that the FAQs seemed so one-sided in their attempt to incentivize the Third Party TSMS option that I have heard comments such as, “I don’t even think the Coast Guard wrote these,” and “This sounds like intimidation!” Captain Gifford assured us that it was not the Coast Guard’s intent to intimidate anyone, one way or the other, but that the Coast Guard does have concerns about available manpower to get the inspections done in a timely fashion. He estimated that half of the towing vessel fleet will go with the Coast Guard option. Other senior officers on the panel chimed in and explained that currently, inspections in the Eighth District are scheduled several weeks in advance, and sometimes only a few days. They stated, if you can deal with that, the Coast Guard option may be for you. Rear Admiral Callahan, Commander of the Eighth Coast Guard District, added that if you want to go with the Coast Guard option, they would do their best to accommodate you, but he just couldn’t promise how timely they would be in doing so.

Biggest takeaway
Rear Admiral Callahan also provided the biggest takeaway for me at the end of his introductory remarks. He said he was going off-script when he gave us three things to ponder (paraphrased): 1. Does your safety management system (SMS) foster compliance, or a safety culture? 2. Is your SMS implemented, or is it just sitting on the shelf? 3. If your SMS is implemented, is it implemented across all levels of the company: top management, middle management, and on the deck plates?

Normally, I might consider these comments standard Coast Guard SMS philosophy, but taken in the context of this conference where much of the talk was centered on going with the Third Party TSMS option, I took it as a warning. A warning to towing vessel companies to ensure, before they jump on this Third Party TSMS option, that everyone in the company is ready, from the deckhands on up.

Subchapter M Resources
Who wrote the Subchapter M FAQs?
 

Comments 1

Guest - Childs Dunbar, Jr. on Sunday, 09 October 2016 19:42

Thanks Kevin for asking the first of many comments to come.
You have always been a friend of our marine transportation industry.
Keep up this needed work.
Best
C

Thanks Kevin for asking the first of many comments to come. You have always been a friend of our marine transportation industry. Keep up this needed work. Best C
Guest
Thursday, 21 March 2019

Contact Us

This email address is being protected from spambots. You need JavaScript enabled to view it.
Phone: 504.249.5291 | Fax: 504.367.3308

Copyright ©
Maritime Compliance International
All rights reserved | Privacy Policy

Maritime Compliance Report Sign-Up

Click here to subscribe to the Maritime Compliance Report blog for critical email updates on compliance issues.

Stay Connected