Specifically, on or before July 22 2019, owners and managing operators of Subchapter M towing vessels must implement a Health and Safety Plan (HSP) and the associated record-keeping procedures regardless of whether or not the vessel has been issued a Certificate of Inspection.
In addition, the Health and Safety Plan includes general procedures concerning health and safety, identification and mitigation of health and safety hazards, and health and safety training for crewmembers and non-crewmembers.
USCG notes that towing vessels that work under the Safety Management System (SMS) may already have elements of the HSP within the SMS.
However, the HSP would want a stand alone document for those who haven't incorporated the HSP elements into their SMS, and for those towing vessels utilizing the Coast Guard inspection option.
Concluding, there is no requirement to issue to the USCG or TPO the HSP for approval; Yet, the plan is to be reviewed during inspections and audits.