In 2019, USCG marine inspectors detained 41 towing vessels for Code 30 deficiencies, reflecting a vessel’s failure to implement a Towing Vessel Safety Management System (TSMS) or a lack of familiarity with a TSMS.
Of those, 32% used the TSMS option and 68% used the Coast Guard option. Vessels that chose the Coast Guard option are not required to implement an SMS, and therefore may not be proactively managing safety as closely as those vessels that chose the TSMS option, USCG said.
More statistics are needed on this potential correlation between having a TSMS and fewer Code 30 deficiencies, but it is encouraging to see these initial results nonetheless,
…said Cmdr. Jennifer Hnatow, chief of the Domestic Vessel and Offshore Compliance Division.
As such, an American Waterways Operators webinar in late February recommended ways to ensure towing vessel crews are familiar with their company’s Towing Vessel Safety Management System.
Hnatow said the most common themes related to Code 30 deficiencies were:
- a lack of adequate shore support through the Third Party Organization or
- the crew’s failure to demonstrate an active TSMS training regimen.
When Coast Guard marine inspectors go out for a scheduled inspection, or post marine-casualty, part of what their looking for is to ensure the vessel has the equipment required by Subchapter M but also that the crew understands how to use it. Practice makes permanent. The more you practice correctly – whether you have the Coast Guard option or the TSMS option – it’s going to be automatic in the event of an emergency. That’s why our marine inspectors ask those questions,
Hnatow also said the USCG marine inspector determines a company’s fleet size information from the Certificate of Documentation, which is based on information provided by the owner during application process.
If vessels in a company’s fleet are listed under different names or different mailing addresses, it will affect the phase in requirement percentage.
If you operate vessels owned by a different entity but you consider them to be part of your fleet, reach out to the local OCMI so they can make sure the phase in percentage is correct,
Finally, she offered several suggestions for promoting a holistic safety culture onboard:
- Make the TSMS available for the entire crew to read by posting it online or having a hard copy in a common area.
- Encourage ownership of the TSMS by assigning a crew member – even an unlicensed position – the responsibility for maintaining the hard copy of the TSMS.
- Company leadership should promote regular TSMS training as a special event and ensure the crew understands the value of regular training. Case studies can be used to provide context and illustration.
- Talk openly about results of audit and surveys. Talk to the whole crew on what they did well and where they need to improve.
TSMS is about constantly improving the safety of the vessel. That’s everyone’s responsibility.