TVIB News Subchapter M Updates

TVIB TALKS: Top 10 Advantages of the TSMS Option

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At the 2017 International WorkBoat Show, 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 first in a series of posts from that presentation.

Top Ten Advantages of the TSMS Option

  1. Greater flexibility for scheduling audits and surveys to fit a companies operating schedules.
  2. Companies utilizing a TPO approved TSMS will be perceived as operating at a higher level of performance by their customers.
  3. Operators subject to the TMSA requirements or the AWO RCP are already required to have an audited TSMS regardless of compliance option selected.
    • Every Operator will eventually need a Health and Safety plan regardless of Coast Guard option or TSMS option selected.
  4. Internal Survey Option
    • The internal survey option provides the company an alternative to conduct annual compliance surveys and five-year drydock surveys and ISEs, utilizing company personnel (or contracted surveyors), versus having to use third-party surveyors.
    • Surveys can be conducted during normal maintenance operations.
    • Companies can determine in their TPO approved TSMS, how they intend to comply with vessel requirements.
  5. Properly drafted Permit to Proceed procedures will be defined by the company and should allow greater ability to continue operations when minor deficiencies occur during operations.
  6. The ability to use a Corrective Action process to correct non-conformities and deficiencies under the supervision of a TPO will allow greater flexibility to schedule repairs than might be available under Coast Guard inspections.
  7. Potential for a lower fee for each annual Coast Guard COI renewal.
    • The Coast Guard will be completing a rulemaking to align inspection and COI renewal fees to recognize the amount of work and costs related to Coast Guard inspections for towing vessels using the Coast Guard option vessels that required for the TSMS Option vessels under TPO supervision.
  8. One Coast Guard inspection in five years with the TSMS option, versus one every year with the Coast Guard option.
  9. A TSMS should create a culture of safety and continuous improvement, as opposed to a culture of compliance.
  10. The Coast Guard has given great latitude to TPOs to determine how an owner/operator can comply with Subchapter M.

 

Annual Survey of Towing Vessels Course – January 23-26, 2018 in Houston

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Our Annual Survey of Towing Vessels course 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.

Who Should Attend

Internal Surveyors: This course is designed for individuals seeking training on the requirements for Internal Surveyors as specified in section 137.315 Internal Survey Programs, and are looking to become proficient at conducting Subchapter M compliant internal surveys under the oversight of a Third Party Organization “TPO.”

Third Party Surveyors: This course is also for those surveyors who wish to become a TVIB Certified Subchapter M Surveyor for Annual Surveys. TVIB requires this credential for those individuals who plan to work through TVIB to offer annual surveys to TPO customers.

Shoreside Person(s) Responsible for Management of the Survey Program: This course is also ideal for those shoreside staff that may be tasked with managing the survey program. For those companies selecting the TSMS option, Subchapter M requires the owner or managing operator to specify in the TSMS the individual or individuals responsible for the management of the program (46 CFR 137.130(c)(4)).

Course Information and Registration

USCG: MSC Guidelines for Review of Stability for Towing Vessels (M)

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12/04/2017

The Coast Guard Marine Safety Center published a revision to MSC Guidelines for Review of Stability for Towing Vessels (M) (Procedure NumberL H1-04).  The document serves as the Plan Review Guideline that is applicable to stability calculations reviewed by the MSC for towing vessels with a keel laid on or after July 20, 2017; or underwent a major conversion on or after July 20, 2017.

Stability review for a towing vessel under Subchapter M does not need to be completed by MSC. The owner of the vessel has the following options:

  1. A registered professional engineer (P.E.) licensed by one of the states of the United States or the District of Columbia
  2. An authorized classification society that has been delegated the authority to issue the SOLAS Cargo Ship Safety Construction Certificate under 46 CFR 8.320
  3. The Coast Guard

Click here to download MSC Guidelines for Review of Stability for Towing Vessels (M)