Due to the rise in COVID cases and the impact the Delta variant is having across the nation, TVIB realizes some people may not feel as comfortable traveling to attend a class. With this in mind, TVIB has decided to transition the upcoming ASTV class to be delivered virtually rather than the traditional in-person setting. This change will affect this training session only. Any future sessions will be decided on a case by case issue closer to the date of the course. Course registration is still open and course information can be found below.
Course Summary:
The Annual Survey of Towing Vessels VIRTUAL course is open to those members and non-members. It provides surveyors with the knowledge and skills required to perform TVIB TPO Subchapter M annual surveys of towing vessels. It has been designed to teach those who will be performing surveys as a part of an internal survey program, as well as those surveyors who wish to hold the credential to perform external surveys for TVIB. Everyone who successfully completes the course will receive a course completion certificate. This course is the surveying course required for those individuals seeking the TVIB Certified Subchapter M Surveyor for Annual Surveys credential.
Registration for the IN PERSON Drydock/Internal Structural Examination course remains open with limited seats available. The 3 day course will be held in person at Hines Furlong Line in Paducah, KY August 17-19, 2021.
The course provides surveyors who plan to conduct Subchapter M drydock and internal structural examinations of inspected towing vessels with the tools, skills and knowledge to complete these examinations, and provides a path toward an industry-recognized credential.
TVIB VIDEO MESSAGE: COI Enforcement Status As Of July 19, 2021
46 CFR 136.202(a)(3) (paraphrased) requires that all owners or managing operators must ensure that at least 75% of their towing vessels must have a valid COI on board by July 19, 2021.
For those needing to submit applications (CG-3752) or schedule Coast Guard inspections in order to obtain a COI, §136.210 (paraphrased) requires the following of owners and managing operators:
Schedule an inspection for the initial certification with the cognizant OCMI at least 3 months before the vessel is to undergo the inspection for certification
Deadline for scheduling inspection was April 19, 2021, to have met the July deadline for 75% compliance
Submit a CG-3752 Application for Inspection of U.S. Vessel to the cognizant OCMI where the inspection will take place at least 30 days before the vessel will undergo inspection
Deadline for submitting CG-3752 was June 19, 2021, to have met the July deadline for 75% compliance
CG-835Vs Issued for Phase-In Non-Compliance Immediately
CG-CVC Policy letter 20-01, dated 2/20/2020, indicates that those owner/managing operators that fail to meet the 75% requirement by July 19, 2021, will be receiving 835’s for the remaining portion of the fleet to equal 75%. The Coast Guard will be using listed owner data from a vessel’s COD as the primary source for establishing compliance and making contact with the owner. They will issue the 835s to the vessels with the oldest to newest build dates. According to the policy letter these 835’s will:
Be considered as administrative in nature and will indicate the owner/managing operator’s failure to meet the requirements of 46 CFR 136.202(a);
Be visible on the outward facing side of the Coast Guard’s PSIX data base; and
Require the owner/managing operator to make the vessel available for inspection within 90 days, failure to do so will result in a deficiency code of 60 which must be rectified prior to movement
TVIB has discussed its concerns about using COD owner information as the only source of data with various OCMIs, TVNCOE and CVC-4, as recently as this week. We have offered to share our fleet data with them in hopes of reducing the administrative burden of issuing 835V’s to owner/managing operators that are actually at or above the 75% requirement. In the event an 835 is issued to an owner/managing operator that is in fact at or above the 75% requirement and objective evidence is presented indicating same, then the 835 will be closed with no further action.
Laid Up / Out of Service Vessels Affecting Fleet COI Percentages
Besides ownership issues such as those of an LLC or a financial institution that could skew a fleet size there is another consideration for companies with vessels they consider to be out of service. If an operator owns a vessel that they consider out of service or on “port risk” but have taken no official action with the Coast Guard to remove the vessel from service, those vessels will count towards a total fleet size and will be included in the 75% requirement. A vessel is not required to have a COI in order to be placed into “laid up status” (reference CVC-WI-018(1)) which will reduce an operator’s fleet size. However, if a vessel is placed into “laid up status” it will be required to obtain a COI before entering back into service.
