Subchapter M – How much should we document

 

With the arrival of subchapter M many companies are faced with the dilemma of what and how much to document. Numerous templates are available on the world wide web that claim to provide the needed infrastructure to ensure compliance with subchapter M. In the ocean-going world of ISM many examples are available where the ISM Safety Management Systems have become an administrative burden for vessel personnel and perhaps documentation means to avoid litigation. How then can a towing safety management system avoid the same mistakes made by those complying with the ISM Code?

We must first recognize that the intent of subchapter M is to provide a framework for ensuring safe operations of vessels to which the regulations apply. Further this will ensure safer waters for all including those using the inland waters for leisure purposes and the surrounding communities. It will also make vessels safer for those sailing aboard and which person does not want a safe working environment. As with all change there is always an initial pushback and perhaps having worked without oversight for so long owners may not appreciate the eagle eye focus on their operations.

Another big pushback, as with the ISM code, will come from the vessel personnel with respect to the documentation that they will need to maintain. There are certain documents that need to be kept as records as required by subchapter M. Apart from these the system must be documented to reflect how the mariners operate. The documented system must not be a fictional system of how the users would like it to be or a system documented for the TSMS auditors. A “real” system brings to light issues that need to be addressed immediately. It brings to light issues that need to be addressed by the owners in ensuring safe operations of their vessels.

Always start by capturing what you do exactly as you do it. Then fit the requirements of subchapter M into the working current system. Fill in the gaps and then stop. Use the system, see where improvements are needed and then take action as needed. Often documentation becomes a means to prevent a blame culture. “We have the records to show that we did it!” A management system can truly be successful once users start identifying and freely reporting non-conformities and when the system is blamed for these non-conformities and not the individual.

Internal audits are a wonderful opportunity to identify areas for improvement that may otherwise have been missed and these too should be embraced and not feared. The towing safety management system must become a useful tool to enable safe operations and therefore must the documented to this extent in meeting the requirements of subchapter M. Over documentation will kill the system and under documentation will not be enough to benefit the users and the organization