We are working towards Subchapter M compliance. The SMS we are using wants a barrier of at least 3/16 inch steel. OSHA regs discuss separate storage. Most vessels im seeing are just putting them in a stand together outside withou a barrier. Does anyone know is there a CFR on this? Ive been looking through 46 CFR for subchapter M compliance and cant find anything. Does anyone know the correct answer for Sub M compliance? Thanks
I’ve seen both but the govt. ships i sailed had them out of the way on some weather deck. Try looking up inside/outside storage? As for the one in use … I’m not sure I recall the big tanks being in side at all, I do recall taking the guages outside often enough to install. The little portable outfits were inside… one for any tow line back aft. (deck) and another usually in the machine shop.
If the SMS specifies separate gas bottle lockers, then you must have separate lockers, even if that is not required by the CFRs. You must comply with the SMS. A sharp USCG inspector might pick up on that.
Thank you. It only states a steel firewall.
On ships, I have seen aft facing separate gas bottle lockers for about 10 bottles with wire mesh doors. There is a steel plate bulkhead between the lockers. I think this is standard and required by regulations.
I’m not sure what regulations might apply to US flag tugs. In practice tugs do not separate the gas bottles, and they are just lashed or secured in a cradle outside near the winch.
Given Subchapter M’s focus on paperwork, and look the other way approach to other structural issues, I suspect that Subchapter M probably does not require separate gas bottle storage lockers.
There is a MOU between the USCG and OSHA. It provides that the USCG has priority to regulate vessels, but that OSHA may regulate aspects of vessel operations that the USCG chooses not to regulate. So it’s possible, that OSHA regulations might apply to gas bottle storage on tugs, but I’ve never seen OSHA show up at a tug.
I do see certain customers (such as marine construction and dredging companies on government contracts) send out their safety guys to enforce OSHA requirements.
The focus is on PPE, but it sometimes does get into some structural issues like: handrails, gratings, platforms, gangways, signs, steps, painting of steps, nonskid, etc.
Time to re-write the SMS (again)
Most companies are using a “canned” sms for the AWO, ABS, or whoever. It’s not really practical for a company to customize the sms on it own.
We’ve customized ours a bit
you may need a “canned” SMS just to be in compliance in the short run but long term it should be completely customized to your company.
What would you rather do, completely change the way your company operates to match a pre-written SMS by somebody who likely doesn’t know you or your company? Or would you rather write an SMS that models what you already do?
Also …wouldn’t Oxygen and Acetylene come under 46 CFR 142.225
(a) Paints, coatings, or other flammable or combustible products onboard a towing vessel must be stored in a designated storage room or cabinet when not in use.
Thanks. I read that CFR also. It was just so generic I thought Id see what I was missing