TVIB News Subchapter M Updates

TVIB TALKS: Factors to Consider in TPO Selection

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Final Installment – At the 2017 International WorkBoat Show last December, Chris Parsonage, TVIB President, presented on a panel discussing the TSMS option versus the U.S. Coast Guard Inspection option for Subchapter M compliance.  Following is the fourth and final in a series of posts from that presentation.

Factors to consider in TPO selection:

  • What are the major costs that should be considered?
    • What does the TPO charge?
    • What happens after the introductory special disappears?
  • Is my TPO committed to the Commercial Towing Market?
    • Will the TPO be less responsive when the oil industry rebounds?
  • Can the TPO meet our schedules?
    • Can the TPO perform multiple compliance audits within one audit so that it will meet other audit requirements such as AWO RCP?
    • What is the anticipated vessel downtime waiting for inspections or audits to be completed?
  • Will the TPO work to understand my operation?
    • Will the TPO provide guidance to help answer compliance questions unique to my company?
    • Does the TPO offer training for employees of companies selecting the Internal Survey Option?
  • Does the TPO have an adequate number of trained auditors and surveyors?
    • Will there be auditors and surveyors in all the locations where my vessels operate, or will they need to travel a long distance to perform the services?
    • Auditor and surveyor travel costs can amount to 25-40% of the cost of this work.
  • Will the auditors and surveyors be familiar with commercial towing vessels and related regulatory requirements for the specific vessel, and their route and service?
  • How is the TPO going to interpret equipment repair or replacement?

USCG: Sub M – Contact Local OCMI to Schedule COI Inspection

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01/29/2018

The Coast Guard’s Office of Commerical Vessel Compliance (CVC) issued a letter to Towing Vessel Owners and Operators encouraging them to begin contacting their local OCMI to schedule the vessel’s initial COI Inspection.

Click here to download the letter.

As a TPO representing many vessel owners and managing operators that have been participating in a Coast Guard-accepted existing safety management system we recognize that many of our TPO Customers intend to take benefit of CG-CVC Policy Letter 17-02 (dated 05/24/2017) which may allow them to use a valid UTV Decal in lieu of the COI Inspection.  Acceptance of the UTV Decal in lieu of the COI Inspection is strictly at the discretion of each OCMI. We encourage you to reach out to each of the OCMIs where you will file an application for COI (CG-Form 3752) to determine their expectations.

Click here to download CG-CVC Policy Letter 17-02.

USCG: Vessel Response Plans and the New Subchapter M Towing Vessel Regulations

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01/23/2018

The Coast Guard published guidance on the integration of existing Vessel Response Plans (VRP) with the impending Subchapter M regulations. The piece focuses on the Certificate of Inspection (COI) that will be required on most towing vessels and what impacts this might have on a vessel listed in a VRP.

Click here to download the full document.