The Coast Guard Marine Transportation Act (2004) authorizes the US Coast Guard to:
- Establish a Safety Management System for towing vessels
- Require USCG safety inspection of towing vessels.
- Establish the hours of service for mariners engaged onboard towing vessels.
This regulatory process is referred to as Sub Chapter M.
MarineCFO’s Vessel 365 provides an electronic towing vessel record which is the baseline for both onboard & shore side Sub Chapter M regulatory record keeping. Towing Industry high impact areas including Safety Management & Planned Maintenance, Environmental Stewardship, Jones Act & Limitations of Liability Act, Manning & Training, and Risk Management are all supported by the Vessel 365 product.
Safety Management & Planned Maintenance
All Towing Industry operators selecting an ISM, RCP, or other USCG approved Safety Management System must provide objective evidence of ongoing and verifiable Planned Maintenance, a Non Conformity & Deficiency Correction Audit trail, and a Safety Assessment process. Vessel 365 exceeds Sub Chapter M objective evidence reporting requirements through an intuitive checklist configurator & document management system.
Compliance with EPA Vessel General Permit (VGP), Ballast Water Management (BWM), and MARPOL Convention regulations are verified through Vessel 365 record keeping and document management. Operators may customize Garbage Logs, VGP Forms, & BWM Forms to best suit their needs. Significant fines are imposed for failure to maintain onboard records in accordance with both United States and international environmental laws.
Jones Act & Limitations of Liability Act
During any Jones Act action against a Towing Industry operator any & all onboard record keeping is subject to Rule 34 (Request for Production) under the Federal Rules of Civil Procedure. As a timely & properly maintained onboard record keeping tool, Vessel 365, can afford the vessel operator protection against Jones Act claims while assisting the operator in meeting the conditions of the Limitations of Liability Act.
Manning & Training
Under Sub Chapter M each towing vessel will be issued a Certificate of Inspection in which USCG will designate the manning levels required for the safe operation of the workboat. Vessel 365 maintains the watch and work hours of all mariners onboard to assure compliance with rest hour policies. Required crew training and orientation is also documented through Vessel 365.
The successful implementation of Sub Chapter M processes by Towing Industry operators will reduce the inherent risks associated with this waterborne trade. Vessel 365 can provide marine insurers a towing operator’s regulatory data & documentation that identify reduced underwriting risk areas which can result in more competitive premiums for the towing operator.