TVIB News Subchapter M Updates

USCG POLICY ALERT: Revision CVC-WI-010 (CH 3) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels

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02/07/2023

CVC-WI-010(3) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels has been revised to add guidance on the use of alternative visual distress signals (eVDSD) and the use of alternative line throwing appliances. The new guidance on VDS applies to vessels that operate on the following: Rivers routes, Lakes, Bays and Sounds, Great Lakes or Coastwise.

Click here to access the revised work instruction.

*UPDATE /MSU-Houma to Host Industry Day

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UPDATE: Due to overwhelming response and limited venue space, MSU-Houma is asking that only Internal/ External Auditors, Surveyors, and legal representation attend the event. They will be hosting a separate event for owners and operators later on in the year. 

Coast Guard Marine Safety Unit-Houma is hosting a Third Party Oversight Industry Day event. We would like to encourage our Auditors, Surveyors, and TPO customers to attend if they’re in the area.

Date: January 26, 2023

Location: Houma Public Library @ 151 Library Drive, Houma, LA 70360

Agenda:

  • 9:00 – 9:15am: Meet and Greet
  • 9:15 – 9:45am: Command Remarks
  • 9:45 – 11:00am: General Presentation (FY21 Stats, UWILD, Reportable Marine Casualties, Manning)
  • 11:00 – 11:10: Break / Move to break out sessions
  • 11:10 – 12:00pm: Break Out Sessions
    • ACP
    • TSMS
    • TBSIP

Click here to download flyer 

 

For the individuals hoping to attend:

If you have any industry questions or want more information, please join us for our TVIB Talks Webinar on January 26th, 2023 @ 2:00pm CST

Register Now

SUB M: DOCUMENTING OWNER OR OPERATOR CHANGE FOR SUBCHAPTER M TOWING VESSELS

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Adding a vessel to your fleet? Do you know what to do next to be compliant with Subchapter M?  The days of late-night or hand-shake charter agreements are no longer an option for a vessel with a Certificate of Inspection (COI).  The biggest challenge for operators, TPOs, and OCMIs is processing operator changes on COIs for very short-term charters.  Owner or operator changes for certificated vessels requires pre-planning and certain actions before, during and after the transition.

If the ownership of the vessel will change along with the operator, the first step is to contact the Coast Guard’s National Vessel Documentation Center (NVDC) to process the change in ownership and issue a new Certificate of Documentation (COD). Coast Guard field units do not have the authority to change vessel ownership information in MISLE as the NVDC is the only entity that processes CODs.  Changes in vessel operator only do not require a change to the COD.

A COI cannot be amended if the COD is not accurate. You should consider the following to facilitate a smooth transition:

  • Utilize a written procedure or checklist that documents your process for adding a vessel to the fleet to ensure compliance with your TSMS and Subchapter M requirements (e.g., minimum firefighting and lifesaving equipment).
  • Include language in your charter agreements to specify that vessel compliance-related documents must be provided, such as vessel surveys and open findings.
    • You need to know about any open non-TSMS findings related to the vessel, as well as any open CG-835V deficiencies.
    • You need copies of annual surveys and drydock/internal structural examination reports for the current COI period.
  • The vessel must be covered by a TSMS Certificate prior to or concurrently with communicating with the OCMI to amend the COI.
  • Ensure that other documents/approvals have been updated (e.g., NTVRP, VSP, COFR, FCC Station License, etc.) prior to operating the vessel.

Lastly, it is vital for you to note the required timeframes for the next annual survey, drydock/internal structural examination, and external vessel audit.  The operator listed on the COI is responsible for ensuring that these activities occur as required.