Subchapter M: Addressing the New Towboat Standards

The final rule requiring Towing vessels to meet specific regulatory requirements under Title 46, Code of Federal Regulations, Subchapter M, was published in June of 2016, and at Meridian.us we are dedicated to helping you both understand and execute the new rules.  

The new regulation applies to all companies with towing vessels greater than 26 feet, as well as those under 26 feet moving barges carrying oil or hazardous materials.  According to the U.S. Coast Guard, a fully implemented Towing Safety Management System (TSMS) establishes a comprehensive quality control system throughout the company, which increases the safety and efficiency of all towing vessel operations. Across the maritime industry, vessel operators have told the Coast Guard that a proper TSMS increases safety while cutting overall operating costs. A proper TSMS will reduce accidents and equipment failures, and decrease or possibly completely undo delays.

 

Two options for towboat companies

The Coast Guard essentially gives towboat companies two options: either implement a safety management system or be inspected annually by the Coast Guard.

The benefits to implementing a TSMS are:

  • Greater flexibility in scheduling required surveys and audits,
  • Less vessel downtime,
  • No requirement for USCG presence for drydock and internal exams,
  • Greater flexibility in correcting discrepancies, and
  • Significantly less USCG intrusion on operations.

 

For those companies choosing the USCG inspection route, Coast Guard inspectors will visit the vessel at least annually and in some cases more frequently, possibly stopping operations until a Coast Guard inspector can visit the vessel.

The new rule will not apply to all towing vessels in your fleet all at once—there are specific phase-in requirements for the TSMS program. But regardless of the route your company decides to take, each towing vessel will eventually be required to have on board a Certificate of Inspection (COI).

For companies with more than one tow vessel:

  • By July 22, 2019, at least 25 percent of the towing vessels must have valid COIs on board;
  • By July 20, 2020, at least 50 percent of the towing vessels must have valid COIs on board;
  • By July 19, 2021, at least 75 percent of the towing vessels must have valid COIs on board; and
  • By July 19, 2022, 100 percent of the towing vessels must have valid COIs on board.
  • All owners or managing operators of only one existing towing vessel required to have a COI by this subchapter must ensure the vessel has an onboard, valid COI by July 20, 2020.

 

How opting for a TSMS can help your towing company

There are two aspects to a TSMS: Surveys and Audits. Surveys are the actual inspection of a ship’s systems, e.g., show me your emergency fire pump is properly installed. Surveys by companies using a TSMS (as opposed to the opting for the annual Coast Guard inspections) may be conducted by either someone in the towboat company or a Third-Party Organization (TPO). Audits focus on whether companies are following the processes and procedures of their TSMS.

Key take away – do not use the term “inspection” instead of “survey” when speaking with people in the industry—“survey” is a term of art in the towing vessel world.

Any TSMS must be compliant with the ISO 9001:2000 or ISO 9001:2008 standard. Reportedly, the Coast Guard will also consider approving standard like ISO 9001.

 

Where we come in

Meridian.us is offering the Audit and Survey programs as a service to our clients. Meridian will provide the highest levels of service at reasonable rates to ensure our clients receive the most for their money.  Meridian is a fully compliant third-party organization approved by the U.S. Coast Guard. Meridian is compliant with ISO 9001:2015 and ISO 28001:2015 standards as well as OSHA safe work practices.

Navigating federal rules and regulations can be one of the most difficult aspects of your job, let Meridian.us help you through the compliance process. Please contact Meridian.us at (251) 345-6776 or info@meridian.us.

‘Security Fatigue’ Can Cause Computer Users to Feel Hopeless and Act Recklessly, New Study Suggests

After updating your password for the umpteenth time, have you resorted to using one you know you’ll remember because you’ve used it before? Have you ever given up on an online purchase because you just didn’t feel like creating a new account?

If you have done any of those things, it might be the result of “security fatigue.” It exposes online users to risk and costs businesses money in lost customers.

A new study(link is external) from the National Institute of Standards and Technology (NIST) found that a majority of the typical computer users they interviewed experienced security fatigue that often leads users to risky computing behavior at work and in their personal lives.

 

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