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TVIB TALKS: Coast Guard Option – Reasons You Should Think Twice

Installment 3 – 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 third in a series of posts from that presentation.

Coast Guard Option – Reasons to Think Twice

Questions to consider before going down the path of selecting the Coast Guard Option over the TSMS Option

  • Availability of qualified Coast Guard Marine Inspectors
    • Does Coast Guard have enough qualified personnel to perform inspections?
    • Uncertainty on the availability of Coast Guard marine inspectors to meet demand if industry chooses Coast Guard option.
    • Much discussion surrounding their current staffing levels and whether or not they will have the ability to keep up with additional workloads of inspecting towing vessels.
  • Cost of Coast Guard Inspection
    • $1,030 per year for all vessels but may increase for Coast Guard inspected vessels after completion of pending rulemaking to review charges.
  • The Coast Guard has not determined how they will deal with the audit portion of annual inspections to verify companies have Health and Safety plans that meet requirements.
    • Does Coast Guard have enough trained personnel to perform audits of required Health and Safety Plans?
  • How will an operator schedule the annual COI inspection for linehaul vessels that pass thru multiple OCMI zones when they do not know where the vessel will be 30 days in advance?
  • Will COI inspections be impacted by shifting Coast Guard priorities?
    • Interruptions due to Coast Guard Resources required for other priorities such as natural disaster recovery (hurricanes, floods, etc.).
  • Coast Guard Marine Inspectors may be lacking experience and knowledge of towing vessels.
    • Recent UTV exams for renewal stickers have created concerns with threatened Captain of the Port Orders for items that aren’t required or were arbitrary.

Be sure to check out our upcoming courses: (click on the course name for information and registration)

 

USCG: Federal Register – Drug Testing Rates

01/19/2018

The US Coast Guard issued a bulletin announcing that it is testing a new delivery method for marine safety information. Initially, the test involves the Mid-Atlantic region (CCGD5). Free subscription information is provided.

Click here to download the Federal Register notice.

USCG: Proceedings Publication – “Game Changers”

01/23/2018

The Coast Guard released the May-December 2017 edition of The Coast Guard Journal of Safety & Security at Sea Proceedings. This is a special Leadership Section with a look back on past, current, and recent happenings.

Click here to download the latest edition of Proceedings