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

2. 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 •

3. 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 •

4. 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 •

5. Internal/External Audits U.S.C.G. Inspections/Surveys
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 •

6. 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 •

7. 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 •

8. 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 •

9. 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 •

10. 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 •

11. 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 •

12. 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 •

13. 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 •

14. 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 •

15. 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 •

16. Questions? Kara M. Babb Marine Compliance & Regulatory Oversight
Office: (504)
Mobile: (832)