Commercial Vessel Compliance

5/10/2019: Subchapter M requirement for Health and Safety Plan

The Towing Vessel National Center of Expertise issued a bulletin to remind towing vessel owners/operators of a 46 CFR Subchapter M implementation milestone that is quickly approaching.

On or before July 22, 2019, owners and managing operators of Subchapter M towing vessels must implement a Health and Safety Plan (HSP) and the associated record-keeping procedures regardless of whether or not the vessel has been issued a Certificate of Inspection. The HSP is required to include general health and safety procedures, identification and mitigation of health and safety hazards, and health and safety training for crewmembers and non-crewmembers.

Towing vessels operating under a Safety Management System (SMS) may already have the elements of the HSP covered within the SMS. For towing vessels that have not incorporated the HSP elements into their SMS, and for towing vessels utilizing the Coast Guard inspection option, the HSP would likely be a stand-alone document.

There is no requirement to submit the HSP to the Coast Guard or TPO for approval. However, the plan is subject to review during inspections and audits. Minimum health and safety requirements can be found in 46 CFR Part 140 Subpart E and TugSafe Central.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.