TSMS Template: Are they worth it

Subchapter M ushered in a new era for the inland water companied within the US in the towing industry. The need for the regulation was driven by the many accidents that occurred on the inland waters of the US owing substandard vessels and incompetent personnel in use. As companies struggle to meet the requirements of the new regulation, those opting for the TSMS option seek documentation templates that will ease the implementation efforts. At first glance these seem the ideal solution and a quick band aid to heal a new wound. However, in the long run companies will find that these templates slowly start failing and the damage they cause can be quite long lasting.

Subchapter M through the regulation seeks to usher in greater safety standards for vessels to enable safer operations as also protection of the marine environment. As with any change there was tremendous push back against the regulation to the extent that it took 10 years to come into force. Companies however are working to a tighter deadline to implement these regulations. As such it is in their best interests to minimize the change needed to enable greater buy-in. Templates will not enable this and will be analogous to fitting a square peg in a round hole.

For a TSMS complaint with subchapter M to work, the company should begin by identifying what is already documented. This documentation should be reviewed to ensure that it accurately captures the As-is of the operations as they are done on board or in the office. Once the system as it exists today is identified it is not time to compare it against the subchapter M regulations and note the gaps. These gaps that can then be filled in with new processes. Whenever new processes are being developed the organization should determine the feasibility of implementing them including the provision of resources.
Subchapter M requires a lot of training to be done but training alone will not enable buy-in from the personnel.

In order for the system to succeed and for all personnel to embrace it, there is a need to keep them involved in the development of the system from the outset. As processes are captured gain their inputs on the challenges they currently face or may potentially face. Based on available recourses identify automation options or engineering controls to reduce the chance of human error.

A TSMS thus developed based on what is done makes it easier for personnel to implement. It results in smaller changes, a well-accepted and thus well implemented system. Subchapter M regulations do not guarantee safe operations. They do however increase the likelihood of safe operations and a willing workforce increases that likelihood.

Avoid These 3 Common TSMS Implementation Pitfalls3

Do you face any of these symptoms with your TSMS:

  1. It does not add any benefit to the work you do
  2. You spend more time filling out paperwork than doing the actual work
  3. It does not reflect your work – the way you do it

If you answered YES to any of the above, then read ahead to see how QMII can assist you in simplifying your system to one that works for the inspector …. and YOU! 

Historically, 99% of towing vessels were never required to have a Certificate of Inspection (COI) commensurate with that of cargo ships, tankers and passenger vessels (including small passenger vessels).  All towing vessels are now required to be “in compliance with” the new inspection requirements when Sub Chapter M became effective July 20, 2018 (46 CFR 136.172).   Despite the new requirement, there are towing vessels that are not fully in compliance. 

In this age of Safety Management Systems, the working definition of “being in compliance” might best be thought of as having “documented evidence” of the requirements being in place (physically on the vessel) and being done hands-on (routine and emergency drills). Non-conformities must be documented.  Audits and other quality checks must have evidence.  Think of a cop show on TV where the detective says to the suspect, “I’ll believe the evidence.”

It stands to reason that the “evidence” has to be “Ready for Inspection” at the request of the Coast Guard.  The records and other documents that vessels need to have readily available are the heart of the matter in any Safety Management Program.  This has been the case with vessels that have been required to have a Document of Compliance issued by a classification society in accordance with International Safety Management.  The idea of an SMS is nothing new.  QMII experts have over 50 years of combined experience in helping regulated industries (afloat and ashore) pass their inspections. 

More importantly, QMII has experience in implementing management systems that work for the organization. Why spend money implementing a system for the inspector/auditor and get no benefit out of it? Sure, it is easy to take a template (easily available on the internet) and fill in the blanks to have a ‘compliant’ system. However, the common pitfalls with this are the same as those faced during the early years of ISM Code implementation:

  1. Overly documented management systems – Perhaps you do not need some of the procedures in the template given the nature of your work. Perhaps you already have existing documentation that meets the requirement.
  2. Lack of buy-in of personnel – This is because personnel has not been explained the benefits of having a TSMS in place. The question “What’s in it for me?’ must be answered.
  3. Template system – These are systems built of a template that do not meet the requirements of the organization or reflect the “as-is” of what they do.

At the end of the day, the shortcomings always fall on the shoulders of the “Industry Afloat.”  Take, for instance, the lack-of-communications syndrome.  We cannot overemphasize the idea of clear communication between these three stakeholders, the CG OCMI, the vessel owner (or managing operator) and the TPO.   

Based on our experience, QMII is committed to working with the maritime industry, so that we can help the industry segment that is regulated by the sub-chapter.