Do You Have A Health And Safety Plan?

The Towing Vessel National Center of Expertise (TVNCOE) issued a bulletin May 10 reminding towing vessel owners and operators of a 46 CFR Subchapter M implementation milestone that is quickly approaching.

On or before July 22, 2019, all owners and managing operators of Subchapter M towing vessels must implement a Health and Safety Plan (HSP) and the associated record-keeping procedures. This is true 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.

If vessels are operating under a Safety Management System (SMS), the bulletin noted, they probably already have the elements of the HSP covered within the SMS. 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.

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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.

Minimum health and safety requirements can be found in 46 CFR Part 140 Subpart E and TugSafe Central.