TVIB News Subchapter M Updates

USCG: CG-CVC Policy Letter 18-04 Guidance on Implementation of New Standards for Fire Protection, Detection, and Extinguishing Equipment

Written by

04/03/2018

The Coast Guard office of Commercial Vessel Compliance issued CG-CVC Policy Letter 18-04 Guidance on Implementation of New Standards for Fire Protection, Detection, and Extinguishing Equipment.

This policy letter provides information and guidance to the Officer(s) in Charge, Marine Inspection (OCMI) on recent changes to regulatory requirements for fire protection, detection and extinguishing equipment used on inspected and uninspected vessels, Outer Continental Shelf facilities, deepwater ports and mobile offshore drilling units per reference (a).

Reference:

(a) “Harmonization of Standards for Fire Protection, Detection, and Extinguishing Equipment,” 81 Fed. Reg. 48220-48303, July 22, 2016
(b) National Fire Protection Association (NFPA) 10; Standard for Portable Fire Extinguishers (2010 Edition)

(c) “Harmonization of Fire Protection Equipment Standards for Towing Vessels,” 83 Fed. Reg. 8175-8181, February 26, 2018

USCG: Subchapter M Regulations and Marine Firefighting Requirements – Two Perspectives

Written by

03/15/2018

The Coast Guard Maritime Commons published a two-piece post to help those operators that fall under Subchapter M (goes into effect July 20, 2018) to understand how the new regular may affect a towing vessel’s ability to be used as a resource provider in a Vessel Response Plan. The first part was written with the towing vessel owner/operator in mind, and the second part, immediately following, is written for the Vessel Response Plan holder. (Paraphrased from the original post)

Click here to access the full post on the Coast Guard Maritime Commons.

USCG: CG-CVC Policy 17-02 (CH-1) Use of Existing Safety Management Systems to Obtain an Initial Certificate of Inspection Under 46 CFR Subchapter M Change 1

Written by

03/07/2018

The Coast Guard office of Commercial Vessel Compliance issued CG-CVC Policy Letter 17-02 (CH-1) Use of Existing Safety Management Systems to Obtain an Initial Certificate of Inspection Under 46 CFR Subchapter M

Refer to 6d on page 4:

For the purposes of issuance of a vessel’s initial COi, 46 CFR 138.115 states, “the owners or managing operators selecting the TSMS option must obtain a TSMS Certificate at least six months before obtaining a COi for any of their vessels covered by the TSMS certificate”. In lieu of meeting 46 CFR 138.115, a company may submit objective evidence to the Coast Guard that it and its vessels have been operating under an existing safety management system per 46 CFR 138.225, for a minimum of three years, as an equivalent level of safety, and will not be required to have a TSMS Certificate 6 months prior to the issuance of a vessel’s initial COi. This objective evidence includes, but is not limited to, external management audit reports covering a minimum of three years prior to the date of the issuance of a vessel’s initial COi. The company must possess a TSMS Certificate prior to the date of the issuance of a vessel’s initial COi, if this “3-year objective evidence” equivalency is used by the company.

Click here to download CG-CVC Policy Letter 17-02 (CH-1)