Today, we begin the one-year countdown to Subchapter M. On July 20, 2018, towing vessels are required to be in full compliance with Subchapter M.
Have you taken the initial steps towards compliance with Subchapter M? Are you ready for Subchapter M?
As a Coast Guard Approved Third Party Organization (TPO), TVIB has a comprehensive solution for those companies choosing the TSMS option. We have a geographically dispersed group of auditors and surveyors from the west coast to the east coast, the gulf and the inland river system. Our auditors and surveyors have been working in the brown water segment of the industry for many years right alongside you. They understand your business, operational parameters and are poised to offer the greatest flexibility in performing services to fit your schedule and needs.
If your company is AWO RCP certified we are an AWO-recognized Third Party Auditing Organization approved to conduct RCP Management and Vessel Audits. We have a clear solution developed for those companies to utilize their RCP Management Certification as a path to receive their TSMS Certificate, consistent with CG-CVC Policy Letter 17-02. We believe we can expedite this process as the overwhelming majority of RCP audits completed were performed by TVIB Certified AWO-RCP Auditors. We stand on the competence of our auditors and do not see that a company that has had a successful RCP Management audit performed by a TVIB Certified AWO-RCP Auditor within the past 3 years would have to undergo additional audits of their shoreside operation or onboard their vessels that also have completed a successful RCP Vessel Audit within the past 3 years.
For those companies that are not participating in the AWO RCP we have a documented process for a TSMS gap analysis, audit of the TSMS and vessel assessments and/or audits in order for a company to obtain their TSMS Certificate.
Companies choosing the TSMS option must operate under a TSMS Certificate at least 6 months before obtaining a COI for any of the vessels covered by the TSMS certificate.
Do your vessels have a valid Towing Vessel Bridging Program UTV decal? CG-CVC Policy Letter 17-01 allows you to utilize a valid UTV decal to receive full credit for an initial inspection for certification. This means that those vessels can be issued a COI without an additional visit from a Coast Guard inspector. Plan to update those decals if any have expired, they are good for 3 years.
Are you planning to have an internal or external survey program? Maybe you’ve considered a hybrid approach of annual internal surveys with the five-year drydock/ISE performed by an external surveyor as a “check” on the system. TVIB has developed a Model Internal Survey program that a company can modify and tailor to their specific needs.
We are expanding our staff and our Houston operation to address the increasing administrative responsibilities of our TPO activities. We are working with developers on a software solution to manage all aspects of our oversight responsibilities. Presently we are completing the phase one implementation strategy and will be rolling this out to our TPO customers, auditors and surveyors in the coming days. We are building this solution to warehouse your TSMS, audit and survey reports, and track events. The system will provide alerts and reminders for upcoming events. TPO customers will have a portal built specifically for their organization.
TVIB is THE TPO YOU KNOW AND TRUST
For More Information Contact:
Tava S. Foret, Executive Vice President, Operations
832.323.2155
tavaf@thetvib.org
Chris Parsonage, President
832.323.2188
chrisp@thetvib.org