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Subchapter M
If you own or operate a vessel greater than 26 feet that pushes, pulls, or tows alongside, you must now have your vessel certificated by the US Coast Guard.
46 CFR Subchapter M gives each owner or operator of those vessel two options towards certification.
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Whichever of the the two options you choose, let us at S & L Help you stay prepared!
The Coast Guard Option
This option requires the US Coast Guard to conduct all inspections necessary to ensure the vessel remains in compliance. With this option, you must schedule all inspections, such as your annual inspection and dry dock inspection. The CG option also requires the vessel to maintain a Health and Safety plan and the captain and crews to conduct recurrent drills and training. Let us help you:
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Identify the health and safety hazards your employees are exposed to and prepare a health and Safety Plan designed to mitigate those hazards.
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Prepare your vessel and crews for their upcoming CG inspections.
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Show the CG that you are a proactive operator by having your vessel surveyed and prepared for its dry dock inspection, thereby reducing your downtime.
Towing Safety Management System (TSMS) Option
The TSMS option gives you the flexibility to conduct your operations on your own terms with minimal oversight from the USCG.
A well-structured TSMS should address procedures for safe practices in vessel operation and safe working environment and a well-documented TSMS is your key to success. Instead of the Coast Guard conducting your inspections, the TSMS option allows you to be in charge of your vessel’s compliance. The TSMS option requires:
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Develop a Safety Management System. S&L Maritime will work closely with you to develop a SMS tailored to your specific operations and culture and will provide guidelines on how management intends to ensure compliance.
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Annual Management and Vessel Audits. As TPO approved auditors, we can provide all of your auditing needs to ensure the TSMS is implemented throughout the organization.
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Annual Vessel Surveys. As part of the TSMS Option, the company has the responsibility to ensure their vessel’s systems and equipment remain suitable for service. Approved by several TPO’s, S&L Maritime surveyors are approved to conduct those inspections on the company’s behalf.
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Dry Dock and Internal Structural Exams. Depending on your vessels route, each towing vessel is required to undergo an exam of the exterior of the hull, it’s running gear, and the internal structural condition every 2 ½ to 5 years to verify the structural integrity of the vessel. We have the necessary background, experience, and qualifications to ensure compliance.