History is a great teacher. The maritime industry however fails to learn from it unless forced to through regulation. The maritime industry has been reactive since the sinking of the MV Titanic and continues to be so. A few operators have learnt that implementing an effective safety management system can be a boon in the long run from lower operating costs, better insurance costs and crew morale high from the knowledge that they are cared for. The ISM code was the result of the tragic sinking of the MV Herald of Free Enterprise and Subchapter M stemmed from the tragic collision of a tug-barge with an Amtrak bridge that resulted in the derailment of the train and the death of passengers.

Subchapter M while a regulation in its intent seeks to make inland water operators proactive in the management of their vessels. The Regulation initially will be perceived as a burden with added costs, added paperwork and added scrutiny. There will be those who try to find workarounds to the system. As with the ISM code, over time operators will learn the benefits from operating withing a safety management system framework. Under the regulations, operators must take an increased interest in their vessels. Ensuring they are supported with the resources they need to ensure safe operations. This includes personnel that have been trained per the requirements of Subchapter M.

The regulations include requirements for life saving equipment. Numerous incidents resulted in loss of lives as a result of inadequate or poorly maintained lifesaving equipment aboard the vessels. Towing Safety Management Systems (TSMS)  as all process based management systems are built around the framework of the PDCA cycle. The Plan-Do-Check-Act Cycle start with the planning of the system. Right from the plan stage companies need to assess the risks. This knowledge of potential risks come from previous experiences, industry knowledge, conferences, academia and data available on the internet. Risks that are unacceptable need to be brought to an acceptable level through the implementation of controls in the system.

Once the plan is in place, implementation starts, and checks need to be made along the way to ensure all is proceeding per plan. A key aspect to the success of the TSMS is the awareness of personnel of potential risks and the freedom to report these for action, without fear of doing so. This safety culture and just culture are key contributors to the success of the system along with the commitment of senior leadership aboard the vessels and in the office ashore. Checks may be conducted in the form of audits and other self checks. At planned intervals the management ashore should assess the effectiveness of their system and make changes to the plan as needed.

Subchapter M, though requiring compliance in intended to be a tool for operators to proactively manage risks and thus enable a safer maritime transportation system.