TVIB News Subchapter M Updates

COVID-19 UPDATE: Sector Mobile

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On 04/07/2020 Sector Mobile sent out an email related to changes to their inspection protocols in light of the COVID-19 pandemic. The email stressed that crew safety is, as always, “…at the forefront of all operational risk management decisions…” Following are the key elements from this communication related to requirements for towing vessel companies:

  1. Leveraging video inspections utilizing GOOGLE DUO, when approved by Sector Mobile.  We will be sending out procedures on how this will be conducted.  Video inspections will need to be coordinated with the Coast Guard  marine inspectors prior to scheduling.
  2. For TSMS Vessel’s seeking their initial COI, and in addition to the items requested on our checklist, the TPO can send a statement of satisfactorily observing fire, abandon ship, and man over board drills. SECTOR Mobile will then be poised to issue the COI and issue a CG-835v worklist item to conduct drills in the presence of a Coast Guard Marine Inspector within 90 days.
  3. Coast Guard Option initial COI inspections for an existing vessel will require an onboard inspection.  These inspections will be conducted on a case by case basis due to latest COVID-19 guidance and resource availability.
  4. For on vessel inspections, the entire vessel will be cleared of all personnel, with the exception of the Inspection Party.
  5. Inspection Party will consist of; Coast Guard Marine Inspector, vessel Crew, and TPO, not to exceed 5 persons total.
  6. To reduce multiple trips, the vessel will be fully vetted on our end before we attend the inspection and the vessel shall be ready for inspection.
  7. If at any time CG inspectors are met by personnel that are not part of the Inspection party as outlined above, CG members will depart the vessel and require rescheduling of the inspection.

“With the current applications we have received, prior to the changes in operations due to COVID-19, we will continue to vet those packages and schedule an inspection based on the guidelines listed above.  For packages submitted to our office during the COVID-19 crisis, there will be delays in processing as we are operating at a reduced staff to minimize inspector exposure and maintain a healthy workforce.  However, we are still vetting packages and will decide which inspection option to use when scheduling the inspection.  Certificates of Inspections will be e-mailed, and followed up with the original being mailed via the post office. With regards to meeting the 50% deadline by July 20, SECTOR Mobile has not received any guidance on relaxing the enforcement actions that was set forth earlier this year. Nonetheless, our office will do its best to accommodate all requests, and will keep you posted on any changes with enforcement actions.”

The sector noted that the situation is fluid and changing rapidly. They will publish any modification to the list above as needed. You can direct any questions to Mr. York, Chief, Domestic Vessel Branch.

COVID-19 UPDATE: Subchapter M Compliance Deadline Guidance Docs Published

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Today we published a COVID-19 webpage as a resource for those in the industry during these unprecedented times. We have compiled our guidelines for addressing impending Subchapter M compliance deadlines, as well as critical information and resources for our TPO customers, auditors and surveyors. Additionally, we have shared additional documents from the U.S. Coast Guard and the American Waterways Operators. We will continue to update the page as we receive updates from the CDC and other federal agencies.

At this time we are postponing all scheduled training through May 31, 2020. We will reevaluate the schedule as additional information and guidance on COVID-19 is released. You can email info@thetvib.org for more information or stay tuned to the blog and education webpages on the TVIB website.

COVID-19 UPDATE: MSIB Number: 11-20 Maintaining Maritime Commerce and Identification of Essential Maritime Critical Infrastructure Workers

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On 03/27/2020 the USCG published MSIB Number: 11-20 Maintaining Maritime Commerce and Identification of Essential Maritime Critical Infrastructure Workers

The uninterrupted flow of commerce on our Marine Transportation System (MTS) is critical to both National Security and economic vitality. During the ongoing national emergency, it is paramount that we safeguard the continued operation of the MTS in the face of the acute and evolving threats posed by the COVID-19 pandemic. The MTS, which provides more than 90 percent of the domestic supply chain, is dependent on an extensive support network comprised of workers from both the private and public sectors.

On March 19, 2020, the Cybersecurity and Infrastructure Security Agency (CISA), within the Department of Homeland Security (DHS), issued a memorandum that developed an initial list of “Essential Critical Infrastructure Workers” to help State and local officials as they work to protect their communities while ensuring continuity of functions critical to public health and safety, as well as economic and national security (The most current version can be found: https://www.cisa.gov/identifying-critical-infrastructure-during-covid-19). The CISA memorandum and this MSIB are advisory in nature and quarantine orders and their enforcement are ultimately up to State and local officials. This MSIB should be used to provide further clarification when making determinations regarding which MTS workers are considered essential in regions impacted by COVID-19 quarantine and shelter-in-place orders.

Click here to download MSIB Number: 11-20 Maintaining Maritime Commerce and Identification of Essential Maritime Critical Infrastructure Workers