08/04/2017 – Reproduced from notice written by Captain Kirsten R. Martin
The Coast Guard is now accepting applications for Tankerman PIC Restricted to Fuel Transfers on Towing Vessels. A new checklist and sample sea service letter are available on the NMC website to assist mariners with these applications.
CG-MMC Policy Letter 01-17, Guidelines for Issuing Endorsements for Tankerman PIC Restricted to Fuel Transfers on Towing Vessels, was published on March 10, 2017, and provides additional information for employers and mariners. Endorsements will be issued in accordance with the provisions for a restricted tankerman endorsement (46 CFR 13.111(a)), in order to meet the requirement of 33 CFR 155.710(e)(1).
Questions or feedback on the policy should be directed to MMCPolicy@uscg.mil. The status of individual applications can be determined by contacting the NMC Customer Service Center using Live Chat, by calling 1-888-IASKNMC (427-5662), or via e-mail to IASKNMC@uscg.mil.
Today, we begin the one-year countdown to Subchapter M. On July 20, 2018, towing vessels are required to be in full compliance with Subchapter M.
Have you taken the initial steps towards compliance with Subchapter M? Are you ready for Subchapter M?
As a Coast Guard Approved Third Party Organization (TPO), TVIB has a comprehensive solution for those companies choosing the TSMS option. We have a geographically dispersed group of auditors and surveyors from the west coast to the east coast, the gulf and the inland river system. Our auditors and surveyors have been working in the brown water segment of the industry for many years right alongside you. They understand your business, operational parameters and are poised to offer the greatest flexibility in performing services to fit your schedule and needs.
If your company is AWO RCP certified we are an AWO-recognized Third Party Auditing Organization approved to conduct RCP Management and Vessel Audits. We have a clear solution developed for those companies to utilize their RCP Management Certification as a path to receive their TSMS Certificate, consistent with CG-CVC Policy Letter 17-02. We believe we can expedite this process as the overwhelming majority of RCP audits completed were performed by TVIB Certified AWO-RCP Auditors. We stand on the competence of our auditors and do not see that a company that has had a successful RCP Management audit performed by a TVIB Certified AWO-RCP Auditor within the past 3 years would have to undergo additional audits of their shoreside operation or onboard their vessels that also have completed a successful RCP Vessel Audit within the past 3 years.
For those companies that are not participating in the AWO RCP we have a documented process for a TSMS gap analysis, audit of the TSMS and vessel assessments and/or audits in order for a company to obtain their TSMS Certificate.
Companies choosing the TSMS option must operate under a TSMS Certificate at least 6 months before obtaining a COI for any of the vessels covered by the TSMS certificate.
Do your vessels have a valid Towing Vessel Bridging Program UTV decal? CG-CVC Policy Letter 17-01 allows you to utilize a valid UTV decal to receive full credit for an initial inspection for certification. This means that those vessels can be issued a COI without an additional visit from a Coast Guard inspector. Plan to update those decals if any have expired, they are good for 3 years.
Are you planning to have an internal or external survey program? Maybe you’ve considered a hybrid approach of annual internal surveys with the five-year drydock/ISE performed by an external surveyor as a “check” on the system. TVIB has developed a Model Internal Survey program that a company can modify and tailor to their specific needs.
We are expanding our staff and our Houston operation to address the increasing administrative responsibilities of our TPO activities. We are working with developers on a software solution to manage all aspects of our oversight responsibilities. Presently we are completing the phase one implementation strategy and will be rolling this out to our TPO customers, auditors and surveyors in the coming days. We are building this solution to warehouse your TSMS, audit and survey reports, and track events. The system will provide alerts and reminders for upcoming events. TPO customers will have a portal built specifically for their organization.
TVIB is THE TPO YOU KNOW AND TRUST
For More Information Contact:
Tava S. Foret, Executive Vice President, Operations
832.323.2155 tavaf@thetvib.org
June 23, 2017, TVIB issued its first TSMS certificate to Crounse Corporation. Crounse successfully completed a full Subchapter M TSMS audit including a review of its operations for compliance with Subchapter M.
Crounse is the first of a number of companies that have chosen TVIB as their U.S. Coast Guard Approved Third-Party Organization (TPO) for Subchapter M compliance. We are very appreciative of the confidence Crounse showed in TVIB and look forward to a long relationship. Reaching this important milestone in the development of TVIB is a significant achievement for our staff and our members.
We are working with a number of TPO customers to take advantage of the recent Coast Guard policy letter CG-CVC Policy Letter 17-02 and the AWO Alert issued on June 8th, that provided guidance on how a company can use their previous RCP Management Audit towards the issuance of their initial TSMS Certificate. Additionally, we are preparing those same customers to take the necessary steps to apply for and obtain COIs for their vessels in the coming year.
We have a broad geographic dispersion of Subchapter M Auditors and Surveyors throughout the inland river system, the gulf and from the west coast to the east coast. Our auditors and surveyors are some of the most experienced available. They have a keen understanding of the industry, as many started out their career on deck, moving up to the wheelhouse and on to shoreside operations and management. We know your business and you know our auditors and surveyors. Contact us to learn how our TPO services can help your organization achieve Subchapter M compliance ahead of the July 20, 2018 deadline.
TVIB is THE TPO YOU KNOW AND TRUST
Tava S. Foret, Executive Vice President, Operations
832.323.2155 tavaf@thetvib.org
