Companies and classification societies are working on programs that will help operators comply with the new towing vessel regulations, called Subchapter M.
The date for the final rule has not been determined, so companies are taking different approaches to Subchapter M.
It is extremely important for small companies to start this process as soon as possible. “It is not something they will be able to do overnight,” said Mike Serafin, managing director for Baker, Lyman & Co. “It’s a culture change for a lot of companies.”
In some cases, classification societies are joining with consultants to take care of the entire process. This is what ClassNK did when it acquired Safety Management Systems LLC (SMSLLC) of Portland, Maine.
In other cases, consultants will work with operators to get all the preparation done, and then bring in a classification society to do the audits and surveys. This is the case with the TSMS Strategic Alliance. This partnership originally included the German classification society Germanischer Lloyd and Baker Lyman, a New Orleans-based chart agent and provider of marine safety and navigation products. However, that partnership dissolved by mutual agreement Aug. 30. Baker Lyman has gone ahead and added four companies to the TSMS Strategic Alliance, which is already working with companies to prepare for Subchapter M.
The American Bureau of Shipping (ABS) is not discussing details of its plans. “We are prepared to assist industry in working with the Coast Guard to comply,” said ABS spokesman Rob Whitney.
According to the 2011 proposed rule, companies will be given two options for compliance. One would be to let the Coast Guard perform an annual inspection of towing fleets and operators. The second would be for towing operators to create a Towing Safety Management System (TSMS). This system would allow third-party organizations to conduct TSMS audits and surveys, which would be certified by the Coast Guard.
Consultants can help companies create the TSMS, including processing, procedures and recordkeeping.
Due to uncertainty about the final date for the towing vessel regulations, some companies are waiting before they start Subchapter M work.
ClassNK acquired Safety Management Systems so it could develop plans. “We can utilize our experience and expertise of SMSLLC to tailor safety management systems that are specific to the needs of inland and brownwater operators,” said Yasushi Nakamura, ClassNK’s executive vice president.
William Mahoney, director of operations, marketing and business management for Safety Management Systems, believes now is not the time to begin. “We are really not actively marketing to anyone yet,” he said. “We will see how it organically happens and see what the final rule is.” The company is considering holding regional workshops and sessions at major conferences to inform operators about the upcoming regulations.
TSMS Strategic Alliance is already working with operators to set up Towing Safety Management Systems. Baker Lyman and Tug and Barge Solutions of Mobile, Ala., are the lead companies. It also includes Score-Global, Marine Safety Consultants and Vector Maritime Group.