Subchapter M and crew safety

 

The towing industry has gone many years without regulation. The need for safety management systems aboard tow boats especially those operating on the inland rivers has been known for some time. Many incidents that resulted in damage to the marine environment and loss of life drive the publication of subchapter M. The regulation ushers in a new era for tow boat safety and for those working abord the vessels.

There is a greater responsibility of operators to maintain the vessels better as also to conduct periodic maintenance of equipment to ensure they are operating as needed. In addition, subchapter M 46CFR Subpart D places the requirements for crew safety. These requirements include the following:

1.       Personnel Records – The master of the vessel to keep an accurate list of crew members aboard as also their responsibilities. In addition, a record in the vessel’s logbook of the watchkeepers and the date time at which they assumed a week and when they were relieved of their watch.

2.       Emergency duties and duty stations – The emergency duties and duty stations should be posted in a conspicuous location as also include the responsibilities of each crew member for certain emergencies as listed in this subpart of subchapter M. Some of the emergencies to prepare for include fire, abandon ship and a person overboard.

3.       Safety orientation – All personnel joining a vessel must receive a safety orientation upon joining that covers certain key safety areas. A record is to be maintained of the safety orientation conducted. If they have sailed on a similar vessel prior joining, then only areas of differences need to be familiarized. The familiarization must be conducted prior to getting underway and this also includes familiarization for non-crew members.

4.       Emergency drills and instruction - Subchapter M requires that Drills be conducted as afar as possible on board the vessels as also at least once a year. The drills must be conducted as if there were an actual emergency and records of the drill should be kept.

5.       Fall overboard prevention – Procedures are to be established by the owner/operator of the vessel to address prevention of falls overboard and the recovery of persons in the water. This to include work on the two, when line handling and then transferring between the pier or other vessel.

6.       Work Vests and First Aid equipment – As per this subpart of subchapter M all applicable vessels need to carry work vest and/or lifejackets for persons working over side as also a medical kit based on the area of operations.

Subchapter M will take time before it is accepted and leads to a culture of proactive safety rather then reactive safety. Personnel understanding what’s in it for them will drive greater acceptance and embrace quicker the by all the value that this requirement brings.