Clarifying Sub M Compliance Say what you do. Do what you say. Be able to prove it.

Say What You Do. TSMS Option USCG Option You say what you’re going to do through the TSMS. USCG Option You don’t say what you’re going to do- you just have to comply. Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Who fulfills the role of DPA? Designated Person Ashore (DPA) Role What is a DPA? The shore-side person(s) designated in writing by the Owner or Operator to ensure the TSMS is implemented and continuously functions throughout management and the fleet. Who fulfills the role of DPA? A designated shore-side employee or 2nd party with excellent communication skills and has access to top levels of management. TSMS Option Only Computer crashes & has not synced then data will be lost between syncing. DPA- Any DPAs in the room? What do you view as your primary roles & responsibilities? The responsibility is ultimately the owners/operators, be extremely cautious with outsourcing of the DPA function. Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

What does Subchapter M require of a DPA? Designated Person Ashore (DPA) Role What does Subchapter M require of a DPA? Designate shore-side person(s) to ensure boats are maintained and in operable condition. Ensure Company has emergency response assistance available for each boat. Responsible for making sure the requirements are being carried out in the management office and in the fleet according to the Company’s approved TSMS. TSMS Option Only Specifically with maintenance- repair when broken” is no longer acceptable. (1) know what’s on your vessel, and (2) be prepared to maintain them IAW with the OEM requirements. Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Internal/External Audits U.S.C.G. Inspections/Surveys 2. Do What You Say. TSMS Option Through Internal/External Audits Inspections & Surveys Maintenance Drills &Training Following your TSMS USCG Option Through 46 CFR Sub M Compliance Maintenance U.S.C.G. Inspections/Surveys Policies & Procedures Drills & Training Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

2. Do What You Say. Internal Audits & Surveys Conducted by Company Personnel or 2nd Party External Audits & Surveys Conducted by a USCG Approved TPO WHAT SHOULD I EXPECT? HOW DO I PREPARE? TSMS Option Only Internal Benefits: Audits & Surveys can be sequenced (don’t have to be done all at once). Internal drydock program as well, you can take “credits” (as long as it doesn’t exceed the time requirements) for drydockings according to your flexibility. Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Develop a timeline and implementation plan. Consider Past Deficiencies Area and Type of Operations Required Compliance Dates Personnel Condition and Size of Fleet Ship Yard and Maintenance Choose Compliance Option Resources & Cash Flow (U.S.C.G. or TSMS) Recordkeeping and Objective Select TPO (as applicable) Evidence UTV preparation (1 week) Minimum one year from the time you create a new TSMS (4-6 months if by Company, 2-3 months if outsourced) until you can get your TSMS Cert. 6 months of operation under the TSMS Certification until you’re eligible for Initial COI. USCG Option: Verbal USCG notification of intent for initial COI inspection (3 months prior to requested COI inspection) & submission of COI Application (1 month prior to requested COI inspection time) Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Prepare your crew and office staff. Training Required Drills, etc. What to expect Management Support External Oversight Good Two-Way Communication Internal Audits, Inspections & Exams Roles & Responsibilities are Understood Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Prepare your fleet. Engine Room Maintenance Safety Equipment Ship Yard Time and Repairs Fire Fighting Equipment Placards and Signage Deck Machinery and Tackle Labeling and Markings Wheelhouse and Navigation Equipment Note “maintenance” can save you money: avoid unplanned downtime, losing contracts due to inoperable status, changing cress, etc. Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Spend time with your crew onboard. Establish Trust Look at Ongoing Projects Identify Weaknesses Have Internal Inspection/Audits Work One-on-One with Crew Ship Checks Check drills, training, etc. Follow up with Corrective Action Answer Questions Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

3. Be able to prove it. TSMS Option Objective Evidence Recordkeeping Through Objective Evidence Recordkeeping Log Entries USCG Option Through Objective Evidence Recordkeeping Logbook Entries Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

U.S.C.G. Inspection or TPO Audit/Survey. Preparation Visit on Day Before Attendance by Office or Management Personnel Attendance by Outside Compliance Partner Important to start building & maintaining good relationships and open-lines of communication with your TPO and your local OCMI in the USCG Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Objective Evidence. Audits Accidents/Incidents Inspections Logbook Entries Surveys U.S.C.G. Reporting Internal Inspections Other Documentation U.S.C.G. Exams Interview Responses during Audits/Inspections/Surveys Maintenance Receipts Corrective & Preventive Actions UTV Decal Stickers Shipyard Reports Root Cause Analyses Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Log Entries & Recordkeeping. Electronic High Visibility for All Parties Real-time Compliance Secure Prompting of Required Entries Readily Accessible Data is Saved on Cloud Less Man-Power to Manage Learning Curve Form Creation Paper Existing User Familiarity Low Initial Cost Storage of Bulk Paper Documents Difficult to Access Data Low visibility Increased Man-Power Legibility Portability Revisions & Document Control Computer crashes & has not synced then data will be lost between syncing. The software can be auto-set to sync when you want it to. “Prompting” reminders- this can be used as a training tool & help to ensure the proper recordkeeping & log requirements are being entered properly. Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Follow-Up as required. As directed by Inspector, Auditor or Surveyor Address non-conformities or outstanding items Assign appropriate corrective action Complete required recordkeeping, documentation. TSMS Option: Review of TSMS, Revisions to TSMS, Master’s Review & Management Review Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

Questions? Kara M. Babb Marine Compliance & Regulatory Oversight Office: (504) 533-8845 Mobile: (832) 291-0087 Email: kbabb@conleymarine.com www.conleymarine.com