Conclusion - Towing Vessel Operators Must Choose Wisely

A properly implemented safety management system (SMS) can be a tool for operational excellence, and companies should not be steered away from adopting one. More than one person have expressed some confusion about why I would write a four part blog that appears to discourage the adoption of a Towing Safety Management System (TSMS), since producing safety management systems is a large part of our consulting business. The answer is simple; we're in the business of helping clients by giving them all the facts, both good and bad, and helping them arrive at the decisions which will be best for their business, not ours. We are just explaining the implications and potential consequences of adopting an SMS and not fully implementing it. In future blogs I will outline the steps required to develop and implement an excellent safety management system. One point about the TSMS option in the Subchapter M proposed rule requires clarification. One of my clients was under the impression that since the company had already adopted a safety management system that it would have to use the TSMS option in Subchapter M. That is not the case. A company may have been operating under an SMS for many years, but that company can still choose straight Coast Guard inspections to obtain its Certificate of Inspection (COI).  According to the proposed rule, the company will fill out an application for inspection and designate the compliance option for each vessel. The company may choose the TSMS option for some vessels and straight Coast Guard inspections for its other vessels. When Coast Guard inspectors show up to do the inspection, if they see an SMS on the bookshelf, they will not say, "Oh, you're on an SMS, we're outta here. Call a third party auditor." That option belongs to the company. We'll have to wait and see if that option survives in the final rule.