Transport Canada: Safe Manning Update
Transport Canada has recently sent out a notice with updates on Safe Manning that may affect fishing vessels under 100 gross tonnage. Below is the notice.
During the fall Canadian Marine Advisory Council 2023, the Personnel Standing Committee announced that Transport Canada (TC) was establishing a National Safe Manning Committee(NSMC). The purpose of the NSMC is to provide national oversight and enhance guidance to Transport Canada Marine Safety and Security Inspectors (TCMSSI) issuing Safe Manning Documents (SMD).
In April of 2024, TC established the NSMC, an internal decision-making body constituted of 8 members:
5 Regional Safe Manning representatives – 1 TCMSSI per region,
1 TC Nautical division representative,
1 TC Engineering division representative, and
1 TC Safe Manning Committee facilitator.
The NSMC meets weekly to review all new SMD applications in Canada to provide a recommendation for their issuance. These recommendations prioritize regulatory compliance taking into account marine safety items identified by the Transportation Safety Board of Canada (TSB) as it relates to fatigue management, passenger safety management and commercial fishing safety.
As a result of NSMC discussions to address regional inconsistences related to the issuance of SMDs and in the spirit of continuous improvement of our program, the following amendments to the safe manning work instructions have been implemented nationally. As an Authorized Representative (AR) there may be some new questions that you will encounter when submitting to renew or apply for a new SMD.
Guidance for when the AR has proposed a manning level greater than the determination of the NSMC:
When the AR has requested manning level greater than the determination of the NSMC, the appropriate Regional Safe Manning representative is to contact the AR, provide them with the determination of the NSMC, confirm the AR wishes to remain with the greater requested manning level, and document the AR’s reasoning for the increased crewing level. The SMD will be issued following the conversation with the AR.
Person overboard evaluation:
An internal guidance document has been developed for TCMSSIs to capture and record the details of a person overboard evaluation, which includes, but is not limited to the following elements:
a summary of the operating environment;
vessel arrangement;
vessel procedures; and
the summary of the recovery demonstration.
This internal guidance document was created to standardize the way in which person overboard evaluations are conducted across the country and gives the TCMSSI direction when renewing an SMD to ensure this evaluation is taken into consideration. If a change in the SMD is required to address this scenario, the AR will receive in writing the reasons why the change is being implemented, along with the renewed SMD.
Guidance for TCMSSIs issuing SMDs to fishing vessels less than 100 gross tonnage:
The safe manning internal work instructions have been updated to instruct TCMSSIs who are evaluating fishing vessels requesting a manning level of less than 4 persons to consider the vessel’s ability to reasonably respond to a person overboard situation.
When evaluating a fishing vessel requesting a crewing complement of less than 4 persons, the TCMSSI can ask the AR to demonstrate a person overboard retrieval. If the person overboard retrieval demonstration is successful with the proposed crewing, the TCMSSI can issue the SMD with the requested crewing level as per their discretion. If the person overboard retrieval demonstration is not successful with the proposed crewing, the TCMSSI is to issue the SMD with the appropriate increased manning level required to respond to a person overboard demonstration successfully.
If the AR can demonstrate they have procedures, equipment, and safe practices that prevent any individual on the vessel from falling overboard, the TCMSSI can use their judgement of the vessel’s safety and decide the person overboard demonstration is not required.