Subchapter M: What to include in my Health and Safety Plan?

 

The publication of Subchapter M ushered in a new era for the towboat industry where the vessels would not be guided by regulations similar to the ISM code and be subject to regular oversight by the USCG. One of the requirement per 46 CFR 140.500  requires that no later than July 22, 2019, the owner or managing operator must implement a health and safety plan. By now owners and operators who have vessels plying on inland waters and to whom Subchapter M applies will already be complying with this regulation. For newcomers the article lists the content that your health and safety plan must cover:

The list below summarizes the content of the plan taking into account the requirements of Subchapter M:

•        Procedures implemented for reporting unsafe conditions – The crew must be familiar with the process for notifying the company of unsafe conditions.

•        Records of any health and safety incidents that occurred on board the vessel

•        Machinery and equipment not in proper working order removed or made safe through marking, tagging, or covering; or otherwise made unusable – Crew must be made aware of the lock out tag out procedures to ensure such equipment is positively segregated.

•        The company must make available appropriate Personal Protective Equipment (PPE) for all personnel and provide training in use of the same, as applicable.

•        PPE cleaned, maintained, and repaired in accordance with manufacturer’s requirements

•        All personnel trained in the proper use, limitations, and care of PPE

•        Vessel, including crew’s quarters and the galley in sanitary condition

•        The organization need to implement procedures in place to identify and mitigate health and safety hazards related to:

•        Equipment aboard the vessel as well as tools that crew will use.

•        Slips, trips, and falls

•        Working aloft – Checklists for such types of work include confined space entry benefit crew members to ensure that all steps needed are completed each time prior the work starting.

•        Confined space entry and use of hazardous materials

•        Blood-borne pathogens and other biological hazards

•        Electrical equipment and panels

•        Noise hazards for crew members

•        Falls overboard

•        Vessel embarkation and disembarkation (including pilot transfers)

•        Towing gear, including winches, capstans, wires, hawsers and other related equipment

•        Sanitation and safe food handling

•        Potable water supply

•        Personal hygiene

•        All crewmembers must be provided with the following health and safety information and training (as applicable to the vessel) within 5 days of employment:

•        Lockout/Tag-out procedures – Guidance for this may be taken from OSHA regulations.

•        Procedures for reporting unsafe conditions

•        Safe use of equipment including deck machinery, rigging, welding and cutting, hand tools, ladders, and abrasive wheel machinery – The organization should implement a maintenance plan for the equipment to ensure it is fit for its purpose.

•        Content and procedures of the health and safety plan

•        Hazard communication and cargo knowledge

•        Safe use and storage of hazardous materials and chemicals – Crew must be aware of the location of such materials. Only those authorized to handle these materials and cargo should do so using the appropriate PPE.

•        Confined space entry – the company should develop a procedure for this to ensure entry is only made once the space is deemed to be safe for entry.

•        Respiratory protection

•        Proper selection and use of PPE

In addition to the above Subchapter M also requires that refresher training on the above be conducted annually. Also, individuals, other than crewmembers, should be provided with training and/or information on relevant hazards and exposure aboard the vessel, as applicable. Further information on this may be found in subchapter M 46 CFR 140, Subpart E (Safety and Health).