Subchapter M documentation
Subchapter M is already in force and close to two years have passed since it was first passed. As with all management systems there is a tendency to over document. Over documentation often happens when organizations do not capture their system the way it works best for them but capture it based upon a template, advise of a consultant or perhaps even based on inputs from the auditor! The latter should be avoided at all costs and in fact the auditor should be advised that it is not their place to recommend.
Let us look at the records keeping requirements of subchapter m for a start. As with the ISM code and ISO 9001 subchapter m does not require a hard copy of all records to be kept. It allows an electronic copy of the records to be maintained provided there is control over the electronic records as well as a way to manage changes to records. 46 CFR 140.915 list the following items to be recorded in the Towing Vessel Record (TVR) or official logbook of the vessel Subchapter M :
- Personnel records – This includes a crew list, including passengers, and the watchkeeping responsibilities assigned to them.
- Safety orientation – This is a record of familiarization being provided to new-joining personnel prior to getting underway for the first time. The record includes the date of the training, topics covered, trainer’s signature and trainee’s signature.
- Record of drills and instruction – This includes a record of drills conducted as required by Subchapter m regulation 140.420. Drills to be conducted as if the emergency were real and record maintained of the type of drill, date of drill and a list of personnel attending.
- Examinations and tests – This include a record of testing of key equipment prior to getting underway
- Operative navigational safety equipment – All vessels required to comply with subchapter m need to have “required navigational-safety equipment in a fully-functioning, operational condition.” When there is a failure of such equipment and subsequent repair records of the same to be maintained in the TVR.
- Navigation assessment – subchapter m requires a navigational assessment to be conducted prior beginning a voyage and then re-assessed at each change of watch to determine any operational risks. Records to be maintained in the TVR of date and time when conducted, the person doing it, and the starting and ending points of the voyage that the assessment covers.
- Navigation safety training – crew members must receive training prior assuming duties related to the safe operation of the vessel. Records must be kept of this training.
- Oil residue discharges and disposals – Records must be maintained of any oil spilled overboard.
- Record of inspection of towing gear – Records to be maintained of type of towing gear and name of person conducting the assessment.
- Fire-detection and fixed fire-extinguishing – Records to be maintained per subchapter m 46 CFR 142.240.
The above is a list of records that need to be maintained. In a subsequent article we will cover the need for additional documentation as required by subchapter m.