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USCG: Update to Guidance for TSMS Option Vessels Under Subchapter M

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Originally posted on the USCG Maritime Commons

POSTED BY LT AMY MIDGETT ON JULY 17, 2019

The Office of Commercial Vessel Compliance recently updated work instruction CVC-WI-013(3), “Towing Vessel COI Inspections under TSMS Option.” Updates include but are not limited to adding annual and renewal Certificate of Inspection guidance for Towing Safety Management System (TSMS) option vessels inspected under 46 CFR Subchapter M.

Officers in Charge, Marine Inspection (OCMIs) should reference this guidance when issuing a COI under 46 CFR Subchapter M for inspected towing vessels choosing the TSMS option. A flow chart is included in the Work Instruction to illustrate the TSMS compliance process. 

For full details, view or download the Work Instruction. 

If you have any questions regarding this policy please contact the Office of Domestic Commercial Vessel Compliance (CVC-1) via CG-CVC-1@uscg.mil. 

USCG: Certificate of Documentation Guidance During Application Processing Delays

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Originally published on USCG Maritime Commons

POSTED BY LT AMY MIDGETT ON JULY 15, 2019

The National Vessel Documentation Center (NVDC) is experiencing delays in the time necessary to issue a Certificate of Documentation (COD) due to performance issues associated with its Information Technology (IT) System. The Coast Guard recognizes the need to minimize the effect on the maritime community. The following guidance is provided: 

Vessels Engaged on Domestic Voyages Only (Coastwise/Fisheries): Vessel(s) with an expired COD may continue to operate domestically on the previously issued trade endorsements provided a renewal application has been submitted to the NVDC. Vessel owners should be prepared to present evidence, upon request, to the Officer in Charge, Marine Inspection (OCMI) or the Office of Commercial Vessel Compliance (CG-CVC), that a renewal application was submitted. 

New Construction/Initial Certification (All Trade Endorsements): In accordance with the Marine Safety Manual, Vol. II, an initial COI may be completed before the COD is issued provided the NVDC has received the application for documentation. Vessel representatives should be prepared to present evidence that the application was submitted to the NVDC to the OCMI. 

Engaged on International Voyage (Registry Endorsement): Vessel(s) with an expired COD that actively engage on international voyages and are subject to Port State Control may request a letter from CG-CVC for continued operation. Requests for a letter confirming vessel registry by the United States should be sent to FlagStateControl@uscg.mil and include objective evidence that a renewal application has been submitted to the NVDC. 

Recreational Vessels (Recreational Endorsement): Vessel(s) with an expired COD that actively engage in recreational use shall not be subject to COD related enforcement action, provided the vessel owner can present evidence that the renewal application was submitted to the NVDC. 

A list of cognizant OCMI / COTP contacts is available on the Office of Commercial Vessel Compliance website. 

In order to ensure NVDC can process the maximum number of applications possible, we ask that you submit any questions via electronic mail to nvdc.w.webmaster@uscg.mil while the IT System is operating at reduced capacity. Responses can be expected within 24-48 hours. We apologize for any inconvenience this may cause.

The latest NVDC Case Processing Report is available from the NVDC website here. 

Sign up to receive updates to the Case Processing Report via email.

USCG: Guidance On the Enforcement of Radar Observer requirements prior to July 22, 2019

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Originally posted on the USCG Maritime Commons blog:

POSTED BY LT AMY MIDGETT ON JULY 12, 2019 • ( LEAVE A COMMENT )

The Office of Commerical Vessel Compliance published a policy letter July 12, 2019, to provide clarification and guidance regarding the enforcement of radar observer requirements. 

The final rule titled Amendments to the Marine Radar Observer Refresher Training Regulations published June 7, 2019 revised merchant mariner credentialing and vessel manning requirements to remove obsolete portions of the radar observer requirements and harmonize the radar observer endorsement with the merchant mariner credential. The Coast Guard also published Policy Letter 03-19, which outlines the National Maritime Center’s guidance for the evaluation of continued mariner radar observer proficiency. Editor’s note: Read our recent post about the final rule and policy letter. 

Some mariners hold radar course completion certificates that have expired, or will expire before July 22, 2019. Under strict interpretation of regulations, these mariners may be required to provide a course completion certificate to prove the validity of their existing radar observer endorsement. This potential action would go against the purpose and intent of this rulemaking. 

Mariners will be considered in compliance with radar observer requirements if they hold a valid Merchant Mariner Credential containing the appropriate endorsement as Radar Observer. Mariners should not be required to provide training certificates to show their Radar Observer endorsement is current and valid. 

This policy letter will expire on July 22, 2019, which is the implementation date of the Amendments to the Marine Radar Observer Refresher Training Regulations final rule. 

For full details, download or view the policy letter. Questions concerning this policy letter and guidance should be directed to the Coast Guard Domestic Vessel Compliance Division at CG-CVC@uscg.mil.