Towing Vessel Inspection Regulations Cleared by OMB

The government RIN Data sheet 1625-AB06 for subchapter M contains a "statement of need" which is very instructive.  It states, "The intent of the proposed rule is to promote safer work practices and reduce casualties on towing vessels by ensuring that towing vessels adhere to prescribed safety standards and safety management systems." Some companies may have very large SMS manuals which make it difficult for crews to use and as a result, few of the written policies and procedures are actually followed by captains and crews. It is very difficult to implement large "pie-in-the-sky" type of SMS manuals. When discussing this once with a towboat company manager, his response was that he was required to have policies and procedures in his SMS, but nowhere did anyone say they actually had to follow them..? While few are willing to be this candid about it, I'm sure that company is not the only one with that perception about their SMS.  Full implementation of the SMS will be the real challenge for all with Subchapter M. Stay tuned...