The Training Implications of Subchapter M

As a former faculty member at a large research university and someone very focused on training in the maritime industry, I noted that there was a limited amount of discussion of the training implications of Subchapter M. This is not a big surprise. The regulations themselves, which are roughly 45 pages long, appear superficially to devote only about one page to explicit training requirements. And the remaining 44 (roughly) are full of regulations that require the full attention of operators – from the potential implementation of a TSMS to vessel compliance, construction and equipment requirements, documentation systems, operational changes and more. There are decisions to be made and systems to be implemented, all of which are rightly receiving the full attention of operators.

So given the comparatively limited focus on training and the abundance of other issues that require understanding and near-term attention, training may not be front and center for most operators. While this is understandable and possibly even unavoidable, it is not unusual. Training excellence is sometimes one of the last thoughts, coming to the front of mind only when lack of training quality creates an event that cannot be ignored.

Subchapter M is about safety. But it is, in many ways, just a start because the focus on training is limited, and training is easily one of the greatest drivers of safety. I have written in the past about the example of British Columbia Ferry Services Inc. (BC Ferries) and their safety culture and training transformation that began in 2007. BC Ferries undertook a comprehensive effort to instill a strong safety culture and improve training outcomes through blended learning practices (combining online and in-person training) throughout the organization. This effort was massively successful, yielding improved on-time performance, a reduction in the accident rate of approximately 60 percent, and a reduction in annual insurance premiums of roughly 75 percent. All this by addressing the human element head on.

BC Ferries, while certainly a pioneer in training and safety culture, is not the only proof of the importance of training. There have been many studies on the subject.

In one extensively researched study, Capt. Stephen Cross of the Maritime Institute Willem Barentsz in The Netherlands determined that the human element can be attributed to approximately 80 percent of maritime accidents. Of those accidents, approximately 81 percent can be attributed to a lack of sufficient training. Thus, multiplying those numbers together, approximately 65 percent of all maritime accidents can be attributed to a lack of sufficient training. Other estimates provide an equally strong or even stronger link between insufficient training and accidents.

It is compelling to think that such a tremendous reduction in the financial and human costs of accidents might be available to workboat operators by focusing on one aspect of operations: training. And the best part is that there is already a great deal of precedent to help guide workboat operators on the path to improving training outcomes. With this perspective, let’s start down this path by looking at the training implications of Subchapter M.

Subchapter M provides some training direction by indicating which aspects of operations need to be trained and when. However, it does not discuss how training is to occur and does not directly say how training is to be evaluated. This is common practice in maritime regulations – mostly because there is a large degree of variability in operations from one operator to another. Mandating one specific form of training that fits-all would be difficult at best, and arguably impossible. This fact is alluded to in the discussion of comments and changes provided by the Coast Guard. In a perfect world, however, there would be common requirements that detail training and assessment methods. The difference in outcomes between good and bad training is vast. That fact is impossible to overstate. So regardless of the lack of direction on training and assessment methods in the regulations, it is critical to keep in mind that methods are easily as important as what needs to be taught. Having said that, what does need to be taught, according to Subchapter M?

When reviewing the Subchapter M document for training implications, most of the reader’s attention can be focused on section 140 – operations. There are a few short sections which cover training requirements at a high level. Additionally, there are implicit requirements sprinkled throughout the rest of section 140. Anybody responsible for training at a workboat operator will need to read the regulations thoroughly in order to embrace them fully, but an overview is provided below.

The most explicit section of Subchapter M dealing with training is Section 140.515 of the regulations. This section is only approximately ⅓ of a page, and thus provides only high-level direction. But minimally, these need to be covered by your training programs. There are 5 subsections of coverage.

The first, subsection (a), covers the need to train general health and safety information. It includes the need to train knowledge of the health and safety plan, procedures for reporting unsafe conditions, PPE, safe use of equipment, hazard communication and so on.

Subsection (b) covers the need to understand hazards relevant to each trainee’s potential exposure on or around the vessel. Subsections (c) and (d) speak to when training must occur and how frequently refresher training must be provided. Subsection (e) speaks to training for non-crewmembers and (f) covers the requirement to document all training.

In addition to 140.515, there are other sections which speak directly to training requirements - even though they do not use the word “training” in their descriptions. For example, section 140.410 documents the need for safety orientations prior to getting underway. The orientation covers the expected areas of required duties, lifesaving equipment, PPE, egress, and so on. It also covers the requirement to document the training. As another example, section 140.420 covers the requirement to conduct drills. It covers the types of drills, the nature of drills and the frequency of drills. Section 140.645 covers navigation safety training to ensure that every crew member understands their duties as a lookout, watch keeping terms, reporting procedures and so on. All of this needs to become part of a structured training program.

In addition to the page or so of high level explicit requirements for training, a careful reading of the operations section of Subchapter M reveals a broad range of other training requirements sprinkled throughout the operations section 140. Some of these are specific examples of the general requirements of 140.515, and others are items that simply require training without explicitly saying so. Thus it would be a good exercise for every operator to examine every paragraph of section 140, making a list of items which should be added to training and orientation programs. As a general guideline, if there is an rule regulating some aspect of operations, there is a training requirement in there somewhere. An operator which trains only to the explicit requirements is setting itself and, more importantly, its employees up for failure.

Possibly more important than the training requirements of subchapter M is how we choose to teach them. As an example, let’s look at the requirement to train “procedures for reporting unsafe conditions”.

On the surface, this provision works together with 140.210 to ensure that all unsafe conditions are be reported to the master, and is therefore simple and logical. But examined a little more thoughtfully, it empowers all crew members and reinforces the reality that everyone on board holds both individual and collective responsibility for safe operations. It is a principle of Bridge Resource Management (BRM) that all employees need to voice their concerns loudly and clearly – a standard that is credited for great advances in safety. The same principle applies on the deck or anywhere aboard.

Thus, in training crewmembers on how to report unsafe conditions, we have a golden opportunity to address the foundations of why it is important, and to stress the rights and obligations of shared responsibility for safety held by every member of the crew. Do we train only the knowledge and skill? Or do we ensure that our officers and crew understand the critical role and important contribution that is required of each of them so that the team can effectively achieve safe and performant operations? Every item being trained represents an opportunity to understand not just the what, but more importantly the why of the need to “get it right”. In this way, every training requirement in Subchapter M can be looked at as an opportunity to build a positive culture, not just to convey information. 

Of particular note, section 140.420 contains a very short statement specifically allowing alternative forms of instruction. This is noteworthy because it is one of the few statements in the regulations which speak to the how of training as opposed to only the what.

More importantly, it is noteworthy because the alternative form of instruction specifically mentioned (though not by name) is blended learning. Earlier in this article we spoke of the implementation of blended learning at BC Ferries and how it was at least partly responsible for a huge decrease in accidents and insurance claims costs. In fact, blended learning has been shown over and over again through experience and research to provide significantly improved training outcomes and retention. 

So much so that it is now rapidly being adopted by vessel operators to improve in-house training outcomes. So it is particularly interesting that the Coast Guard makes a point of indicating that it is an acceptable alternative form of training when it comes to drills. This is very positive.

Having said that, it is also interesting to note that alternative forms of training are not mentioned in any of the other training sections of this document, and that the Coast Guard chose to mention it only in the section on drills. Regardless, where allowed by regulation, operators should be strongly encouraged to investigate and consider the implementation of a blended learning approach to their training to achieve improved outcomes. The only cautionary note is that blended learning is new to many operators, and like any form of training, it is just as easy to do it poorly as it is to do it well. So seek advice when you embark on that path. 

The maritime industry is moving this way, so there are excellent experiences that operators can learn from.

Subchapter M provides tremendous latitude for operators in terms of training and assessment methodology. While perhaps this is a necessary compromise, it does means that to some degree operators are free to implement effective or ineffective practices. Creating a training program which adheres to the letter of the requirements but not the spirit of training excellence will adversely affect performance and safety. Subchapter M is not a document on training excellence and it should not be viewed as such. But it does describe a paradigm for safety which ultimately should be applied to training as well. 

Arguably the real goal of Subchapter M is to raise the bar of operational sophistication in the workboat industry. This means culture change, and there is no stronger driver of positive safety culture than employee empowerment supported by training excellence. The difference between an operator that trains because it is obligated to and one that views training as a critical part of its desire to implement a strong safety culture can be felt the moment you step on to their respective vessels. It can be seen in the way the crew interacts, in the way they perform their duties, in the condition and cleanliness of the vessels. It can also be seen in the improved safety and financial performance of the operator. So in order to achieve the true goals of Subchapter M, let us be sure to carefully consider and address the training implications and opportunities.

(As published in the November 2016 edition of Maritime Reporter & Engineering News)