Clarifying Sub M Compliance Say what you do

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

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

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 2 nd party with excellent communication skills and has access to top levels of management. TSMS Option Only Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine. com

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 Option Only Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine. com

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 2 nd Party External Audits & Surveys Conducted by a USCG Approved TPO WHAT SHOULD I EXPECT? HOW DO I PREPARE? TSMS Option Only 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 (U. S. C. G. or TSMS) • Resources & Cash Flow • Select TPO (as applicable) • Recordkeeping and Objective Evidence 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 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 USCG Option Through Objective Evidence Recordkeeping Log Entries 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 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 • UTV Decal Stickers • Corrective & Preventive Actions • Shipyard Reports • Root Cause Analyses Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine. com

Log Entries & Recordkeeping. Electronic Paper 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 Existing User Familiarity Low Initial Cost Learning Curve Form Creation Storage of Bulk Paper Documents Difficult to Access Data Low visibility Increased Man-Power Legibility Portability Revisions & Document Control 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 www. conleymarine. com Email: kbabb@conleymarine. com