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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.

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Important Read - WorkBoat February 2019

Great article in the February 2019 Workboat Magazine about the Subchapter M Think Tank we did at the Workboat Show in December. Good questions, good answers.

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Towing Vessel Inspections

One hundred percent of our towing vessel clients who have been through the Coast Guard's COI process have been sucessful, and have done at minimum expense.

 

We only employ retired Coast Guard guys who know exactly what they are talking about. We provided surveys, TVRs, H&S plans, and training, and our clients took action and got their COIs.

 

If you know of any companies that have not signed up with a TPO for the TSMS option, that need help with obtaining a COI through the Coast Guard, please share these great comments provided by our satisfied clients:

 

“I wish all boats were like this, this job would be a lot easier. The drills went flawlessly." -U.S. Coast Guard Marine Inspector following a COI for American Tugs, Inc.

 

After reviewing your Overboard Prevention procedures, I’m impressed. These are probably the best and most articulated procedures I’ve seen so far after 25+ COI applications.” -U.S. Coast Guard Marine Inspector to a client on our Health & Safety Plan 

 

"Hiring Kevin Gilheany was an easy decision. Without his assistance, we would not have been able to receive a COI as quickly as we did." - Phil Andrie, President, Ashton Marine, LLC

 

 “We appreciate all the experience and research you put into your TVR and Compliance Management System. As you must be delighted to hear, they are performing well in the inspection process and, truly, helping captains operate more safely and efficiently.” - Biblia, Inc. Marine Towing & Transportation

 

"Maritime Compliance International (MCI) has always given our company all the right tools to be in compliance. Their TVR is excellent, and Sub M surveys are a great tool to get ahead in the game. MCI has an excellent staff, and we couldn’t be happier with choosing MCI as our compliance partners" - Pedro F. Rivera Jr, Maritime Administrator, American Tugs Inc.

 

 “Maritime Compliance International responded quickly to our requested for assistance in becoming compliant with Subchapter M, without the complications of electronic forms, with simple forms and training that all of our Captains deckhands could comprehended.” – Mike Schmeltzer, Durocher Marine Division

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Subchapter M Think Tank

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I really liked the Think Tank format at the Workboat Show this year. We had a great discussion about Third Party Option vs. Coast Guard option, Coast Guard OCMI authority to defer enforcement, the level of intensity of audits under Subchapter M, and much more.

Please let us know if any company you know of needs help getting into compliance, regardless of the chosen compliance option. We are not a TPO. We work on behalf of the client alone, not the government.

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Subchapter M Think Tank - Workboat Show

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This should be a very interesting discussion. We hope to see you there.

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Book Recommendation

On my first Coast Guard cutter we got the ship lost. True story. It was before GPS, but there was a new Navy satellite receiver on board called SatNav. Because there wasn't as many satellites up as there are now, you had to wait for them to rise and set to get a good fix. We thought it automatically updated our position whenever a good fix came in, but that was not always true. If it went a long time without a good fix we were supposed to do a, "Code 51, Enter." No one knew that. No one really studied the user manual. We could have wrecked the ship. Luckily we figured out our error before we got close to land. It was certainly a "near miss" in today's terminology. It was my first year in the Coast Guard, and I was only an E-2, but I could have read the manual too. That lesson did not escape me.

In reading Rachel Slade's book, Into the Raging Sea, on the sinking of the U.S. flag ship El Faro, I was shocked to find that not knowing the ship's equipment also played a role in that disaster. According to the book, the captain made his decision to continue on his track based upon the private weather service forecasts, which he may not have known, were based a data which was twelve hours old. They also had the NWS forecasts available on board, which are based upon data only four hours old, but the captain preferred the private weather service forecasts. He may not have read the user manual.

I highly recommend this excellent book to anyone interested in continuous improvement in the maritime industry. The lessons to be learned are many, and apply to vessel personnel, shoreside staff, ocean going vessels, inland vessels, regulators, and their agents (TPOs). We talk a lot about lessons learned, and learning from our mistakes. This book provides an excellent opportunity to learn from others' tragic mistakes. If we don't learn from mistakes, such as not "knowing your equipment," we are bound to repeat them.

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Coast Guard Inspector: This is exactly what we need.

I have been advocating the Coast Guard option for Subchapter M since the NPRM was published. I've been telling our clients, and anyone else who will listen, all a tow boat company has to do is: 1. Get the vessel in compliance. (Paying for a regulatory compliance survey is a worthwhile investment.) 2. Have a system to manage your compliance including the TVR records. 3. Get a health and safety plan. 4. Get the required Subchapter M training. 

Okay, enough preaching. Let me tell you a success story of a client who listened...

One client of ours got their boat up to Subchapter M as well as they could. A local Coast Guard marine inspector came a couple of times and pointed out a few things they needed to take care of. This client contacted us because they were concerned about all the record keeping. We provided them with our comprehensive TVR/Compliance Management System which includes the Health and Safety Plan. Then we went to their offices and provided all the required training in one day.

The next morning the Coast Guard marine inspector (Chief Warrant Officer) came back to their boat. According to the client he was very impressed with our TVR/Compliance Management System. The inspector said, "This is exactly what we need."

If they had been ready to demonstrate drills, the inspector said he could have given them their COI that day. But the company wants to practice the "Guantanamo Bay" style drill procedures we provided them before they take that final step.

This, my friends, is the optimal level of compliance.

If you are still not prepared, or have any questions, or would like to discuss getting your vessel surveyed for Subchapter M compliance, or would like to know more about the TVR/Compliance Management System, please don't hesitate to give us a call.

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Critical Decisions - Subchapter M

Critical Decisions – Subchapter M

U.S. towing vessel operators, large and small, are faced with critical decisions:

Should they go with the Coast Guard option, or Third Party TSMS option?

If they go with the Third Party TSMS option, which Third Party Organization should they choose?

If they go with the Third Party TSMS option, what should they use for a TSMS?

How will they ensure compliance with log and record requirements, regardless of the option chosen?

Some companies have made their decisions and are confident moving forward. Others have made their decisions, but may be having doubts. Still others have no idea. There is no shortage of sales pitches, each one with a different spin, interpretation, or promise. This barrage of conflicting agendas, does little to help companies make the best decision for their compliance.

Maritime Compliance International is dedicated to helping companies make these critical decisions. We have the tools and solutions to help companies achieve the optimum level of compliance, and have a thirteen year track record of ensuring success for our clients. We are not a Subchapter M Third Party Organization, acting as an agent of the government.

I will be speaking on all these issues at the International Workboat Show next week. But even if you can’t make the conference session, come by and see us next week, booth:
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Have all your questions answered, take a look at our products and solutions, and get your free gift while they last. We look forward to seeing you.

 

 

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Marine News Magazine

Please take a look at my article in this month's edition of Marine News Magazine. (The article begins on page 20 of the magazine, page 22 of the electronic format.)  It's important information about surveying your vessel for Subchapter M compliance.

There are only 14 months left to get ready. If you need assitance with Regualtory Compliance Surveys, Towing Vessel Record/ Compliance Management Systems, Towing Safety Management Systems, or our Subchapter M Self-Study Course, please don't hesitate to contact us.

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Congratulations to E.N. Bisso & Son

Congratulations to E.N. Bisso & Son for its recent ISM certfication by ABS. The company has worked hard to achieve this goal with VP Mike Vitt leading the effort for the company. E.N. Bisso & Son partnered with Maritime Compliance International a decade ago. When they made the decision to seek ISM certification we developed their safety management system (SMS) into the ISM format, provided safety management workbooks for all captains to complete and learn the company's SMS, and conducted quarterly visits to each vessel to ensure steady progress. The ISM manual was approved with no deficiencies, the Document of Compliance was issued to the company following a successful audit, and now the vessels are being audited and issued their Safety Management Certificates. It is a pleasure to work with such dedicated clients.
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Subchapter M - 18 Months to Comply

There are now 18 months left to get towing vessels into compliance with Subchapter M. According to our Subchapter M Strategic Plan, by now all captains should have read Subchapter M, as well as all managers, who should also have read the Subchapter M Preamble in the Federal Register. Additionally, companies should have decided which compliance option they will go with. We developed a Compliance Option Decision Tool to help in this process. It takes into account seven important factors for towing vessel companies to consider, free of spin and sales pitches. So, if you haven’t done that much yet, you should consider catching up.

January 1 is the date set for companies to begin getting their boats into compliance by getting a comprehensive Subchapter M survey for each vessel. We recently completed our first two Subchapter M surveys for a client.  In order to do this properly, the company must first make some important decisions: the vessel route; number of persons in the crew; number of persons in addition to the crew; warm or cold water operation; excepted vessel or not; and the compliance option. The survey should be based upon these assumptions. Once the company has a comprehensive regulatory compliance survey report, they can budget and plan out the timing of upgrades throughout the year. 

April 1 is the date set to establish how the requirements for written records, operational policies and procedures, and training will be met. Some of our clients are getting ahead of the game by implementing our comprehensive Towing Vessel Record/ Compliance Management System, which includes all required records, policies and procedures. With a good survey, our comprehensive system, and some training, these clients are all set for Subchapter M. 

The items discussed above apply to all towing vessels, regardless of the compliance option. For those companies choosing the Third Party Option, they have a number of other considerations. More on that next time.

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