Clarifying Sub M Compliance

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 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

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

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

5. 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

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

7. Develop a timeline and implementation plan. • Consider Past Deficiencies • Required Compliance Dates • Condition and Size of Fleet • Choose Compliance Option • (U.S.C.G. or TSMS) • Select TPO (as applicable) • Area and Type of Operations • Personnel • Ship Yard and Maintenance • Resources & Cash Flow • Recordkeeping and Objective • Evidence Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

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

9. Prepare your fleet. • Engine Room Maintenance • Ship Yard Time and Repairs • Placards and Signage • Labeling and Markings • Safety Equipment • Fire Fighting Equipment • Deck Machinery and Tackle • Wheelhouse and Navigation Equipment Kara Babb Juneau • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

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

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

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

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

14. Log Entries & Recordkeeping. 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 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 Kara Babb • Marine Compliance & Regulatory Oversight • kbabb@conleymarine.com

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 • kbabb@conleymarine.com

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