Russo: Subchapter M will require higher level of training, more written lesson plans


With the pending implementation of Subchapter M for towing vessels, many companies and masters are examining how these changes might affect their operations. As it turns out, no matter whether a company chooses the ISM Safety Management System (SMS) approach or the Towing Safety Management System (TSMS) approach, a large number of companies will be required to impose substantive changes on their training programs.  Training, itself, is not a new requirement, however how it has been conducted has never been the focus of much attention by shoreside management or by vessel management. That is about to change.

In the past, training was conducted either by regulatory requirement such as fire drills or by company policy such as AWO RCP requirements. Often little oversight of what the training actually consisted of was conducted, and as long as there was a log entry, everyone was happy.

Training is designed to impart knowledge, understanding and proficiency in a particular subject to the recipients. Drills and exercises are part of that training process. Formal SMS programs approved by class agencies such as ABS or GL often require that the training be conducted to some standard and records kept of who, when, where, why and how training was conducted. The TSMS programs will also impose similar requirements. These requirements may force the ordinary practice of seamen to adhere to a higher standard of knowledge, understanding and proficiency in their employment than was previously done. What this translates to is simply becoming more professional and more organized in the way crews receive training.

So what are the likely new requirements in training going to look like?  Fortunately the answer is something the average master can comply with without too much difficulty. To start with, written lesson plans are very likely to become the standard. When considering a subject, for example fire fighting on board a vessel, constructing a lesson plan for training is something that can be done in a day. Using firefighting as an example, start the process by defining the proficiency you want the mariner to demonstrate. You might use three different proficiencies: fire prevention, using a fire extinguisher and using a fire hose. 

To achieve those proficiencies, define what knowledge and understanding you will require the mariner to have. That is the start of a lesson plan. As an example, if the first area you want to teach is what is required for a fire to occur, you can specify how much time is required to transfer this knowledge; then you might list the key teaching points for this lesson; and finally list any training aids such as videos. That could constitute the written lesson plan. You could assemble all required and desired lesson plans in a simple three-ring binder.

After you create the lesson plans, then you will need to decide on the frequency of how often they are taught. Some subjects like firefighting or abandoning ship will be required to be taught frequently and some like spill response will be taught less frequently. Writing that down along with your written lesson plans completes your written training program.

As you conduct training, it is sometimes desirable to have mate or engineer conduct training in certain areas such as fuel transfer. This also helps them develop professionally.

Research has shown a mixture of theory and practical knowledge imparted in drills helps the crew to professionally respond to an emergency or incident quickly and without having to provide an excessive amount of command guidance. When you are designing your lessons plans, it does help to review what has been written. Over time, you may choose to have the mate write the lesson plans and then review it in a similar fashion to voyage planning meetings.  

After a training program is generated, then you will be required to demonstrate who received the training and how often. This is a simple log sheet that should be kept on the boat and also turned in to the office. At the office, each mariner’s personnel file should contain a training page that lists this information. The result of this record keeping is that a company can demonstrate what was trained, when it was presented and who received it to an auditor or the U.S. Coast Guard.

Training is changing, but keeping up with these changes and making your crew more professional is a goal which can be met.

Capt. Robert J. “Captain Bob” Russo is AWO RCP Auditor with Towing Vessel Compliance and is Chief Executive Officer of parent company Maritime License Training Co., both in Atlantic Beach, Fla. Visit

By Professional Mariner Staff