Sabine Surveyors Adapts To Prove TPOs Can Thrive
Since the advent of Subchapter M close to 18 months ago, much of the focus has been on how towboat operators are adjusting to life after July 20, 2018, and how the Coast Guard is applying the rules of 46 CFR Subchapter M.
But there’s a third critical component to Subchapter M, without which no one following the Towing Safety Management System option could achieve a certificate of inspection (COI): authorized Third-Party Organizations, or TPOs, along with class societies.
With more than 5,000 inland towing vessels in service and in need of surveys and audits in connection with Subchapter M, the Towing Vessel National Center of Expertise has recognized nine companies as TPOs. Towing companies following the TSMS option contract directly with a TPO, which then provides the needed Subchapter M surveys and audits.
One of the initially-recognized TPOs was Sabine Surveyors, headquartered in Port Arthur, Texas, with a main office in New Orleans, La. Sabine has six other offices scattered from Norfolk, Va., south to Cape Canaveral, Fla., and west to Corpus Christi, Texas.
And while some of the initial nine TPOs have left the Subchapter M market, Sabine has actually thrived. Since July 2018, Sabine has even absorbed the Subchapter M client base of two TPOs: Marine Compliance and, more recently, Decatur Marine.
Sabine leaders point to the company’s pursuit of ISO certification more than 20 years ago as a strategic decision that laid the foundation for Subchapter M TPO success. Today, the company is both ISO 9001 and ISO 14001 certified.
“As time went by and as Subchapter M regulations were developed, we realized we would probably be in a good position to be a qualified TPO,” Sabine Surveyors President David Pereira said of the company’s full integration of the ISO quality management system.
Early on, Sabine also made a strategic staffing decision in relation to Subchapter M: hire full-time staff dedicated wholly to Subchapter M surveys and audits.
“My big input was that I wanted to do this with our own people,” Pereira said. “We developed a good system on how we would do that, and we invested in people. Slowly, we brought in personnel to match the workload.”
That started with the hire of Rob Keister, a Coast Guard veteran who commanded the Coast Guard’s Houma, La., inspection group for three years, in addition to two years of inspection oversight of the overall Eighth District. Keister joined Sabine in August 2016 and immediately developed all the company’s Subchapter M-related processes. Sabine was named a Coast Guard-certified TPO in January 2017.
Now, Sabine’s Subchapter M team stands at five full-time surveyors/auditors.
“Ninety-five percent of their time is spent with Subchapter M,” Keister said. “That’s what makes us different from everybody else who either uses contractors or staff surveyors, who may be working blue water one day, rigs the next day and Subchapter M the next.”
Keister said his team is also well-equipped to resolve gray areas within Subchapter M and inconsistencies that emerge in how different Officer in Charge Marine Inspection (OCMI) zones interpret the rule.
“An advantage we have is that we deal with about 16 different OCMI zones,” Keister explained. “We can take what each one says and, if there’s inconsistency there, I can go to each one and say, ‘New Orleans is saying this, but Quad Cities or Chicago are saying that. Let’s get on the same page.’”
Keister also encouraged companies to not be afraid to appeal rulings to Coast Guard headquarters. The Coast Guard “isn’t going to hold a grudge if you appeal,” Keister said, plus it’s the most expeditious way for OCMIs to achieve consistency.
“That’s the best way for us to get as many of these gray areas with Subchapter M adjudicated,” he said.
Sabine has also invested heavily in developing software for both the customer and the surveyor/auditor in the field. Sabine staff use the web-based application while conducting surveys or audits on site.
“A normal survey may take four hours on the vessel,” Keister said. “Then you need one or two hours in the office to write up the report, develop a photo album and get that ready to be sent out. Now, when we leave that vessel and hit submit, the report has already been generated. It goes to admin to proofread it. We’re saving at least two to three hours on every case, and that all adds up.”
Vessel crew members and shoreside staff can also access a dashboard via the client portal to manage nonconformities, schedules and vessel information fleet-wide. The web-based application is particularly useful in the case of a non-satisfactory item or corrective action. Rather than having to exchange hand-written notes, calls and emails, the surveyor/auditor using the portal instantly generates a report with a link to the applicable language from the CFR, pictures and the needed corrective action. The client then takes the needed action.
“The client uploads that into the system, and it automatically gets uploaded and entered as a corrective action to a nonconformity,” Keister said. “It’s all automated. It’s all documented in the system. We have it instantaneously.”
Pereira pointed out the client portal and web-based application is a service Sabine provides to its customer base, free of charge.
“That’s a value-added item for our customers,” he said. “We looked at it and thought, ‘It’s helping us to work more efficiently, so why charge the customer for it?’”
Doug Bernard, business development manager for Sabine Surveyors, said it all goes back to Sabine’s commitment to be the most cost-effective TPO available to operators.
“When we made that investment to develop the software, we did it in the light of how this fits into our overall business plan to provide a service to our clients,” Bernard said. “We’re here for the long haul.”
Furthermore, Sabine is also one of three organizations certified by the Coast Guard to offer a course for internal auditors connected with Subchapter M. Sabine also offers a course for training internal surveyors and a third course offering a general Subchapter M introduction.
Looking toward the future, Pereira, Keister and Bernard said July 2020 will be another important Subchapter M date, with single-vessel owners required to receive COIs by then. If they haven’t already done so, those operators must choose between working with a TPO or taking the Coast Guard inspection option.
After that, they anticipate some transition leading up to July 2023, at which time many of the operator-TPO contracts will expire and some operators may elect to change TPOs.
“Over the next four years, it’s going to become a real big issue for a lot of vessels,” Keister said. “And that’s one reason you have a lot of these new builds. We have some companies who know some of their vessels just aren’t going to make it through the next drydocking, and they’ve got to get their replacements lined up now.”
In the meantime, they said they’ve been pleasantly surprised at the “afterthought” business that’s come to Sabine through the TPO work. As companies build new vessels or repair damaged vessels, Sabine can serve as an onsite surveyor of construction and repair.
That breadth of service has been worth the investment, Keister said.
“Because of the staff we have, because we decided to go about it this way, this is part of our structure,” he said. “And a beneficiary of this, in our opinion, is the Coast Guard and our clients. It’s been costly to go about it this way, but it’s well worth it.”