Subchapter M – Training vs. Competence

 

As the inland water maritime industry in the United States prepares to meet the deadlines for implementation of Subchapter M, many are focused on getting the paperwork in place. All too often the focus of systems is ensuring the right paperwork (documents/records) are in place to appease the auditor/surveyor/inspector. A small minority see the benefit of regulations such as Subchapter M and implement management systems built around what they do, reflecting how they do it. They build a culture of safety that empowers. Personnel follow the rules because they want to, they see the benefit in it and not because it is enforced.

This culture of safety will only come from awareness training to all personnel so they understand what is expected of them, why they have to do what they do; what are the benefits and what are the implications of them not meeting the Subchapter M requirements. Training plays a very important role in the success of any system but is often not given the importance it deserves. Let us take a looks as some of the training requirements of Subchapter M.

46 CFR 140.515 contains a list of training that crewmembers must have. These include:

•        General Health and Safety information – reporting unsafe conditions, proper PPE selection, safe use of hazardous materials, confined space entry etc.

•        Training for individuals other than crewmembers.

•        Refresher training as applicable

In addition to the above crewmembers joining a vessel for the first time must receive familiarization training, drills are to be conducted, and navigational safety training to also be provided. All these form a part of the vessel’s training program for the personnel. Companies will look to provide some structure for the development and delivery of this training in a consistent manner.

Further Subchapter M 46 CFR 139.130 defines the qualifications for auditors and surveyors. Under subpart b3. Auditors must successfully complete a ISO 9001 lead auditor course followed by a training course for auditing of a TSMS. The requirement for training of internal auditors are captured in 46 CFR 138.310. Internal auditors too must complete an ISO 9001 lead auditor course. Further it is recommended by QMII that those assigned to the role of designated persons complete a designated person course, so they understand the role that they have to play in the system and for its effectiveness.

While the above references of Subchapter M deal with the training required companies must determine the methods by which they will determine the competence of personnel in their employment. They must remember that training may not equate to competence. Competence is the ability to adequately demonstrate the ability skills and knowledge that may have been acquired through training. Competence is the distinguishing factor at times between safe operations and unsafe operations.