The link between insufficient training and accidents is well established, and the training implications of a new regulation such as Subchapter M cannot be ignored. What training is required under Subchapter M? Subchapter M provides some direction on those operational aspects that require training. However, it does not discuss how training is to occur nor how it is to be evaluated. This is common in maritime regulations as operations vary widely from one operator to another. In a perfect world, the requirements would also account for training methods. The difference between good and bad training is vast. So, keep in mind that the methods used are as important as what needs to be taught. Section 140 Operations is the most important from a training perspective, especially Section 140.515: Subsection (a), covers the need to train general health and safety information such as knowledge of the health and safety plan, procedures for reporting unsafe conditions, PPE, hazard communication, etc.
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