QUESTION: How do I know when a vessel’s COI anniversary date is?

RESPONSE:  Per 46 CFR 136.110, the anniversary date means the date and the month of each year that corresponds to the date of the expiration on the COI.

QUESTION: What inspections are required for an electric water heater on a towing vessel?

RESPONSE:  To answer this question, first you must identify some characteristics of the electric water heater.

46 CFR 136.110 defines a pressure vessel as “… a closed tank or cylinder containing gas, vapor, or liquid, or a combination thereof, under pressure greater than atmospheric pressure.”

An electric water heater is a closed tank that contains liquid and is under pressure greater than atmospheric pressure.

The following italicized text contains excerpts from the regulatory citations and not the language in its entirety.

§ 143.300 further defines requirements for pressure vessels as those that are greater than or equal to 37.4 gallons and over 15 pounds per square inch.  Under this set of requirements, there are some that are applicable to an electric water heater:

 (a) be equipped with a spring loaded relief valve that prevents pressure from exceeding the MAWP by more than 10 percent.

 (b) be externally examined annually and relief valve tested in accordance with § 143.245 (i.e., twice every 5 years with no more than 3 years between testing)

 (c) be marked with MAWP

 (d) if installed after July 20, 2018, must meet ABS rules (see § 143.540)

Since the water heater will operate at the pressure of the potable water system, the gauge requirement of § 143.300(a) is more commonly applied by having a pressure gauge on the output side of the potable water pump or thereafter in the piping system.

While not applicable to Subchapter M vessels, one can look at Subchapter T (46 CFR 182.320) and Subchapter K (§ 119.320) for similar regulatory guidance. Those regulations put specifications that apply to a water heater that is UL listed, under 120 gallons, and heat input is less than 200,000 BTU per hour.

Additionally, the water heater manufacturer likely provides documentation to guide the owner on maintenance. A quick web search of some major water heater manufacturers identified that at least annually the temperature pressure relief valve should be tested, and one was found to call for the relief valve to be reinspected once every three years and replaced if necessary. The vessel owner/operator should consult the manufacturer’s documentation for the make/model installed on the vessel.

QUESTION: How do I determine the window of dates to conduct an annual survey?

RESPONSE:

The window for the annual survey is based on the anniversary date of the Certificate of Inspection (COI). According to the Coast Guard definition in 46 CFR 136.110 “Anniversary date means the day and the month of each year that corresponds to the date of expiration on the COI…”

The annual survey must be conducted within 3 months of the anniversary date of the COI.  The annual survey may occur 90-day before or after the anniversary date, providing 180 days within which the annual survey may be conducted.

EXAMPLE: A COI that expires on 8/17/2027 has an annual survey window of May 19th (90 days before the anniversary date) to November 15th (90 days after the anniversary date) of each year.

If you have any questions about determining the date window for annual surveys please call 832-323-3992 or click here to send an email.

QUESTION: What do I do if I miss my annual survey window?

RESPONSE:

As soon as you realize you have missed the window for the annual survey you should do the following:

• Notify TVIB by contacting an Operations Coordinator by phone at 832-323-3992 or click here to send an email; and
• Notify the local OCMI as the COI was issued under the TSMS option and the vessel must comply with all elements for the COI to remain valid.
  • It is important to advise the local OCMI that the TPO was notified of the deficiency and there is a plan in place to have the survey conducted.

The annual survey must note this failure to comply as a deficiency that must be addressed in the Corrective Action Plan (CAP).

The CAP for this item should detail HOW the company will ensure this does not happen in the future. It is NOT sufficient to state “the annual survey was completed” as this does not address the initial failure to comply and provide a plan to prevent a recurrence on this vessel or any others in the fleet.

See the FAQ related to calculating the window for conducting an annual survey for additional information.

QUESTION: When do I need to amend a COI?

RESPONSE:

A COI must be amended if any of the following occur:

• Vessel is sold (new owner to apply for amended COI);
• Vessel’s operator changes (such as under a new charter contract);
• TPO covering the vessel changes;
• Vessel changes Subchapter M compliance options (such as moving from CG option to TSMS option);
• Vessel has a change in route, manning, exceptions, or alternative arrangements; or
• To correct errors (typographical, incorrect survey program, etc.)

Please work with the local OCMI and remember to send a copy of the amended COI to TVIB so we can update our records accordingly. If you have any questions about when to amend a COI please call 832-323-3992 or click here to send an email.

QUESTION: When do I need to alert TVIB that my vessel is going into drydock for repairs?

RESPONSE:

You need to alert TVIB when your vessel is going into drydock for the following:

• Any Credit Drydock
• Non-credit drydock that involves the following:
• Any repair to a fuel tank;
• A repair that crosses two or more frames; or
• Steel replacement of greater than 324 square inches.

If you have any questions please call 832-323-3992 during normal business hours or click here to send an email and the appropriate staff member will get back to you.

If you require assistance after hours please call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:

• URGENT: immediate assistance is needed, regardless of the time of day; or
• NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document.

QUESTION:
For an item that was corrected during the audit/survey and marked as such on the report, is a response required by the operator on the CAP?

RESPONSE:
The answer is no, provided that the following elements are satisfactory:

• The finding statement clearly articulates how the item was corrected; and
• The finding is NOT one of the following:
  • Major Non-conformity*
  • Unsafe Condition*
  • Repeat Finding**

* A major non-conformity or unsafe condition has mandatory reporting requirements, please reference the TVIB Notifications document for specifics.

** Repeat findings may indicate a failure of the TSMS.

If you have any questions please call 832-323-3992 or click here to send an email.

QUESTION: How do I add or remove a vessel from my fleet?

RESPONSE:

On 10/20/22, TVIB retired the PDF version of the TSMS Vessel Addendum Add/Remove form and replaced it with a web-based form.

• The TSMS Vessel Addendum Add/Remove form must be submitted electronically through the TVIB Member Portal, click here to access the form.
  • You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials please click here to send an email to request them.
• Once the form is submitted, the TVIB Operations team will receive a notification and an Operations Coordinator will process the request.
• The revised TSMS Vessel Addendum (TVA)will be forwarded to the individual listed as the Primary Contact for the organization as well as the Coast Guard’s Towing Vessel National Center of Expertise (TVNCOE).

If you have any questions or need assistance with completing the process call 832-323-3992 or click here to send an email to the Operations Team. Below is a video to walk you through the process of logging into the TVIB Member Portal and submitting the form.

QUESTION: Does TVIBs External Vessel Audit Program satisfy the requirement for all vessels to be randomly audited during the 5-year period of validity of the TSMS certificate?

RESPONSE:

Yes.  TVIB published the External Vessel Audits policy to meet the elements laid out in CG-CVC Policy Letter 18-01 CH.2 which clarifies the requirement for random vessel audits as noted in 46 CFR 138.315(b)(3). TVIB staff worked with the Audit Committed to develop the External Vessel Audits policy that takes into consideration the logistical issues related to scheduling random external vessel audits across a company’s entire fleet during the 5-year period of validity of the TSMS certificate.

Click here to access the TVIB Member Portal where you can log in and download the External Vessel Audits policy. Once you log in click on the drop-down menu in the upper right-hand corner and select Policies and Member Communications to locate the policy.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials please click here to send an email to request them.

QUESTION: If a company has more than one office, is there a requirement that defines which location must be audited as a part of an external management audit?

RESPONSE:  There are no requirements in Subchapter M that specify an external management audit must occur in a specific location or in multiple locations if a company has more than one office.

There is language in the AWOs RCP related to “managing office” which can be found in the table under RCP-II-G- 2.

QUESTION: What are the minimum requirements to become an external auditor?

RESPONSE:

46 CFR 139.130(b) Auditors must meet the following qualifications:

• High school diploma or equivalent.
• Four years of working on towing vessels or other relevant marine experience such as Coast Guard marine inspector, licensed mariner, military personnel with relevant maritime experience, or marine surveyor.
• Successful completion of an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) (incorporated by reference, see § 136.112 of this subchapter) lead auditor/assessor course or Coast Guard recognized equivalent.
• Successful completion of a training course for the auditing of a TSMS.
• Audit experience, as demonstrated by:
  • Documented experience in auditing the ISM Code or the American Waterways Operators Responsible Carrier Program, consisting of at least two management audits and six vessel audits within the past 5 years; or
  • Successful completion of an auditor apprenticeship, consisting of at least one management audit and three vessel audits under the direction of a lead auditor.

TVIBs requirements and the full process to become a TVIB-Certified Auditor are documented in the Auditor/Surveyor Membership Application. If you have any questions, please call 832-323-3992 or click here to send an email.

QUESTION: What are the minimum requirements to become a surveyor?

RESPONSE:  

46 CFR 139.130(c) Surveyors must meet the following qualifications:

• (1) High school diploma or equivalent.
• (2) At least one of the following:
  • (i) Four years of experience working on towing vessels as master, mate (pilot), or engineer; or
  • (ii) Other relevant marine experience such as Coast Guard marine inspector, military personnel with relevant maritime experience, marine surveyor, accredited marine surveyor, experience on vessels of similar operating and physical characteristics.

TVIB has two surveyor endorsements: (1) Annual Surveyor of Towing Vessels and (2) Drydock/Internal Structural Examinations. Additionally, we have a program to become an internal surveyor, for employees of our TPO Customers.

TVIBs requirements and the full process to become a TVIB-Certified Surveyor are documented in the Auditor/Surveyor Membership Application. If you have any questions, please call 832-323-3992 or click here to send an email.

QUESTION: What do I do if my vessel is involved in a marine casualty?

RESPONSE:

Refer to 46 CFR 4.05-1 to determine if the incident is considered a Reportable Marine Casualty. If it is a Reportable Marine Casualty then you must comply with all reporting requirements as noted in the CFR and incorporated by reference in 46 CFR 140.900 which begins with notification to the local OCMI.

Once the Coast Guard has been notified according to 46 CFR 4.05-1 you may receive a CG-835V.  If the 835V is issued with an action code of “A” please follow these steps to properly report the incident TVIB:

• Call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:
  • URGENT: immediate assistance is needed, regardless of the time of day; or
  • NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.
• Email the 835V to TVIB. Click here to submit the 835V via email.

The OCMI retains the sole authority to close out a CG-835V.

Incidents that are not considered a Reportable Marine Casualty according to 46 CFR 4.05-1 may be reviewed by the auditor during the course of the next management audit.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document. If you have any questions about this process you may call 832-323-3992 or click here to send an email and a staff member will get back to you.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials o click here to send an email to request them.

QUESTION: Are potable water tanks required to have protection such as a screen on the vents for safety or to prevent bugs from getting in?

RESPONSE: Yes. Vent screens are one of the measures that might be used to prevent contamination of potable water.

46 CFR 140.510(b) – As far as practicable, the owner or managing operator must implement other types of safety control measures before relying on Personal Protective Equipment. These controls may include administrative, engineering, source modification, substitution, process change or controls, isolation, ventilation, or other controls.

Further, the regulations also state:

21 CFR 1250.82(c) – Each potable water tank shall be provided with a means of drainage and, if it is equipped with a manhole, overflow, vent, or a device for measuring depth of water, provision shall be made to prevent entrance into the tank of any contaminating substance. No deck or sanitary drain or pipe carrying any nonpotable water or liquid shall be permitted to pass through the tank.

QUESTION: During a recent annual survey the lifebuoy was in overall good condition, the reflective tape was good, and it was marked in block capital letters with the vessel’s name. However, the identification label was worn off and I was unable to confirm if the lifebuoy was USCG-approved. Does this lifebuoy need to be replaced?

RESPONSE:

Yes. 46 CFR 141.360(b)(1) states that each lifebuoy “Be approved under approval series 160.050 or 160.150.”  If the labeling on the lifebuoy is unreadable and/or missing, and you are unable to verify the series of the lifebuoy it should be replaced.

Portable fuel containers are commonly found on towing vessels.  They are routinely used for fueling auxiliary equipment such as dewatering pumps, fire pumps, and auxiliary boats.

Subchapter M § 142.225 discusses the storage of flammable or combustible products, but there are other considerations in Part 147 of Subchapter N, which is probably the best place to start evaluating the question above.

Subchapter N:  46 CFR §147.1(b) – Applicability for Part 147 (Hazardous Ships’ Stores) indicates “This part applies to all vessels listed in 46 U.S.C. 3301…”.  The U.S.C. 3301 includes “(15) towing vessels”.  So, we know it is appropriate and acceptable to apply the requirements of § 147.45 (Flammable and combustible liquids) to a Subchapter M towing vessel.

46 CFR §147.45(f) specifies that fuel may be stored in a portable safety container meeting UL 30, UL 1313, or UL 1314.  Standard plastic consumer-use fuel containers are not allowed.

You may store portable safety container(s) in any of the three locations:

• A storage cabinet meeting UL 1275 or FM 6050; and
• A storage room (i.e., paint locker) that is free of ignition sources; and
• An open location designated by the master (see § 147.45(g))

ADDITIONAL CONSIDERATIONS:

• A location designated by the master should be identifiable through signage, TSMS reference(s), and crew knowledge.  It is also advisable to ensure the designated storage location adequately secures the portable safety containers from movement due to vessel maneuvers and environmental conditions.
• Refilling portable safety containers onboard the vessel requires a drip pan of adequate size and that a 10-B:C (former B-I) fire extinguisher be within 9.75 feet of the refilling location (see § 147.45(i)).

46 CFR 142.330(a)(7)

QUESTION:
What is required as evidence of a fire detection system being certified and inspected by a registered professional engineer (PE) or National Institute for Certification in Engineering Technologies (NICET) Level IV fire alarm engineering technician?

RESPONSE:
Commonly referred to as a PE Letter, auditors, surveyors, or Coast Guard inspectors will ask for documentary evidence of the certification and inspection of the vessel’s installed fire detection system.  This documentation should adequately document the certification and inspection of the system.  The content and layout of these letters vary among the individuals that make these attestations.  TVIB has communicated with the TVNCOE, and various PE/NICET individuals, and reviewed multiple versions of these letters.  While no specification for the content of these letters can be pointed to, we have been able to identify what a towing vessel owner/operator should reasonably expect to see in these letters.

Expected content of PE/NICET letters for an installed fire detection system:

• Vessel Name and Official Number
• Date of Inspection
• A statement that the system complies with 46 CFR 142.330 or individually lists each of the requirements under §142.330
• Identify the control panel make/model and serial number
• A list of smoke and/or heat detectors installed throughout the vessel including the make/model and location and/or a basic diagram indicating the same
• A letter produced on the letterhead of the PE/NICET that bears the printed name, signature, and stamp of the PE/NICET

WHAT TO DO IF THE PE/NICET LETTER DOES NOT CONTAIN THE ABOVE INFORMATION:
It is not required to have your PE/NICET letter reissued.  However, at such time any change or modification to the system is performed a new PE/NICET letter is required so that the system is certified and inspected to verify compliance.  This would be the time to discuss with your hired PE/NICET your expectations for their letter.

QUESTION: During an annual survey a question was raised on whether a vessel must have flame screens on vent pipes for fuel oil. I thought was a requirement for all Sub M vessels, where can I this requirement?

RESPONSE: 46 CFR 143.265

46 CFR 143.265 Additional fuel system requirements for towing vessels built after January 18, 2000.

(c) Vent pipes for integral fuel tanks. Each integral fuel tank must have a vent that connects to the highest point of the tank, discharges on a weather deck through a bend of 180 degrees, and is fitted with a 30-by- 30-mesh corrosion-resistant flame screen. Vents from two or more fuel tanks may combine in a system that discharges on a weather deck. The net cross-sectional area of the vent pipe for the tank must be not less than 312.3 square millimeters (0.484 square inches), for any tank filled by gravity. The cross-sectional area of the vent pipe, or the sum of the vent areas when multiple vents are used, must not be less than that of the fill pipe cross-sectional area for any tank filled by pump pressure.

QUESTION: I have a regulatory interpretation question regarding generators.

A generator fails on a vessel equipped with 3 generators while the other two generators are fully operable. Only one generator is needed to carry the load for the vessel.  Are we required to report this to the Coast Guard and TVIB?

RESPONSE:  Short answer is yes, based on the following:

Guidance concerning reportable marine casualties was taken from NVIC 01-15 title 46, code of federal regulations (CFR), part 4 marine casualty reporting procedures guide with associated standard interpretations 46 CFR 4.05-1.

The loss of an online generator IS considered a reportable marine casualty no matter the duration. However, if you have the required 2 operational power supplies, you continue to meet the requirements under Subchapter M.

The benefit of this setup is that the vessel still has the required power supplies so you can schedule repairs to the affected generator later and continue operations without lost time.

Once reported, this may be handled differently from one Coast Guard unit to another since it does not affect operations. These would be the 2 most likely and agreed-upon options but they do not preclude an alternate path not discussed in this FAQ under the direction of the OCMI.

• CG-835V not issued, Notify TPO IAW companies TSMS for repairs. Continue operations
• CG-835V issued, Action Code A, Self-reported Worklist item, not fwd. facing. Notify TPO IAW Companies TSMS. Continue operations.

QUESTION: What inspections are required for an electric water heater on a towing vessel?

RESPONSE:  To answer this question, first you must identify some characteristics of the electric water heater.

46 CFR 136.110 defines a pressure vessel as “… a closed tank or cylinder containing gas, vapor, or liquid, or a combination thereof, under pressure greater than atmospheric pressure.”

An electric water heater is a closed tank that contains liquid and is under pressure greater than atmospheric pressure.

The following italicized text contains excerpts from the regulatory citations and not the language in its entirety.

§ 143.300 further defines requirements for pressure vessels as those that are greater than or equal to 37.4 gallons and over 15 pounds per square inch.  Under this set of requirements, there are some that are applicable to an electric water heater:

 (a) be equipped with a spring loaded relief valve that prevents pressure from exceeding the MAWP by more than 10 percent.

 (b) be externally examined annually and relief valve tested in accordance with § 143.245 (i.e., twice every 5 years with no more than 3 years between testing)

 (c) be marked with MAWP

 (d) if installed after July 20, 2018, must meet ABS rules (see § 143.540)

Since the water heater will operate at the pressure of the potable water system, the gauge requirement of § 143.300(a) is more commonly applied by having a pressure gauge on the output side of the potable water pump or thereafter in the piping system.

While not applicable to Subchapter M vessels, one can look at Subchapter T (46 CFR 182.320) and Subchapter K (§ 119.320) for similar regulatory guidance. Those regulations put specifications that apply to a water heater that is UL listed, under 120 gallons, and heat input is less than 200,000 BTU per hour.

Additionally, the water heater manufacturer likely provides documentation to guide the owner on maintenance. A quick web search of some major water heater manufacturers identified that at least annually the temperature pressure relief valve should be tested, and one was found to call for the relief valve to be reinspected once every three years and replaced if necessary. The vessel owner/operator should consult the manufacturer’s documentation for the make/model installed on the vessel.

QUESTION: As I prepare for upcoming Drydock and Internal structural examinations what standards should I reference for hull thickness?

RESPONSE:

Existing Vessels: DD/ISE Planning and Hull Thickness NVIC 7-68 Inspection and Repair of Steel Hulls. This will provide you with minimum hull requirements and maximum wastage allowances.

New Vessels: Reference 46 CFR 144.205(a) Structural standards for a new vessel.

For a new vessel to be certificated for service on –

(1) Lakes, bays and sounds, limited coastwise, coastwise and oceans routes – follow ABS Rules for Building and Classing – Steel Vessel Under 90 Meters (295 feet) in Length; or

(2) Rivers and Intercoastal waterways – follow Steel Vessels for Service on Rivers and Intracoastal Waterways

These are both incorporated by reference, see 46 CFR 136.112.

46 CFR 144.205(d) The structural standard selected must be applied throughout the vessel including design, construction, installation, maintenance, alteration, and repair. Deviations are subject to approval by the Commanding Officer, Marine Safety Center.

For further guidance or discussion always feel free to reach out to an Operations Manager at TVIB by calling 832-323-3992 or click here to send an email.

QUESTION: Who do I contact if my login credentials aren’t working?

RESPONSE:

Please call the office at 832-323-3992 or click here to send an email.

QUESTION: Who can access checklists on Form.com?

RESPONSE:

Currently, only TVIB-Certified Auditors have been provided user access to Form.com checklists. Links to access the system are provided to the individual user when login credentials are issued.

TPO Customers can download PDFs of all audit and survey checklists by logging in to the TVIB Member Portal. Click here to access the TVIB Member Portal.  Once you have successfully logged in, you will be able to access all TVIB documents by making a selection from the “What would you like to do?” dropdown menu.  You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials please click here to send an email to request them.

QUESTION: If I am experiencing an issue with Form.com or have a question who do I contact?

RESPONSE:

If you are experiencing an issue with an item on the checklist such as you believe the login isn’t working properly or have an item on the checklist that is consistently resulting in a finding when it should not, first check to see that you have answered all questions in red. These questions drive the logic and if they are skipped or answered incorrectly it may result in an issue with the checklist.

If you are still experiencing an issue or have any questions please contact an Operations Coordinator by calling 832-323-3992 or click here to send an email.

QUESTION: How do I access the TVIB Member Portal?

RESPONSE:

Click here to access the TVIB Member Portal and you will be prompted to enter your login credentials. Once you have successfully logged in, you will be able to access all TVIB documents by making a selection from the “What would you like to do?” dropdown menu.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials or have any questions please click here to send an email or call 832-323-3992.

QUESTION:
For an item that was corrected during the audit/survey and marked as such on the report, is a response required by the operator on the CAP?

RESPONSE:
The answer is no, provided that the following elements are satisfactory:

• The finding statement clearly articulates how the item was corrected; and
• The finding is NOT one of the following:
  • Major Non-conformity*
  • Unsafe Condition*
  • Repeat Finding**

* A major non-conformity or unsafe condition has mandatory reporting requirements, please reference the TVIB Notifications document for specifics.

** Repeat findings may indicate a failure of the TSMS.

If you have any questions please call 832-323-3992 or click here to send an email.

QUESTION: How do I add or remove a vessel from my fleet?

RESPONSE:

On 10/20/22, TVIB retired the PDF version of the TSMS Vessel Addendum Add/Remove form and replaced it with a web-based form.

• The TSMS Vessel Addendum Add/Remove form must be submitted electronically through the TVIB Member Portal, click here to access the form.
  • You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials please click here to send an email to request them.
• Once the form is submitted, the TVIB Operations team will receive a notification and an Operations Coordinator will process the request.
• The revised TSMS Vessel Addendum (TVA)will be forwarded to the individual listed as the Primary Contact for the organization as well as the Coast Guard’s Towing Vessel National Center of Expertise (TVNCOE).

If you have any questions or need assistance with completing the process call 832-323-3992 or click here to send an email to the Operations Team. Below is a video to walk you through the process of logging into the TVIB Member Portal and submitting the form.

QUESTION: Does TVIBs External Vessel Audit Program satisfy the requirement for all vessels to be randomly audited during the 5-year period of validity of the TSMS certificate?

RESPONSE:

Yes.  TVIB published the External Vessel Audits policy to meet the elements laid out in CG-CVC Policy Letter 18-01 CH.2 which clarifies the requirement for random vessel audits as noted in 46 CFR 138.315(b)(3). TVIB staff worked with the Audit Committed to develop the External Vessel Audits policy that takes into consideration the logistical issues related to scheduling random external vessel audits across a company’s entire fleet during the 5-year period of validity of the TSMS certificate.

Click here to access the TVIB Member Portal where you can log in and download the External Vessel Audits policy. Once you log in click on the drop-down menu in the upper right-hand corner and select Policies and Member Communications to locate the policy.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials please click here to send an email to request them.

QUESTION: What do I do if I miss my annual survey window?

RESPONSE:

As soon as you realize you have missed the window for the annual survey you should do the following:

• Notify TVIB by contacting an Operations Coordinator by phone at 832-323-3992 or click here to send an email; and
• Notify the local OCMI as the COI was issued under the TSMS option and the vessel must comply with all elements for the COI to remain valid.
  • It is important to advise the local OCMI that the TPO was notified of the deficiency and there is a plan in place to have the survey conducted.

The annual survey must note this failure to comply as a deficiency that must be addressed in the Corrective Action Plan (CAP).

The CAP for this item should detail HOW the company will ensure this does not happen in the future. It is NOT sufficient to state “the annual survey was completed” as this does not address the initial failure to comply and provide a plan to prevent a recurrence on this vessel or any others in the fleet.

See the FAQ related to calculating the window for conducting an annual survey for additional information.

QUESTION: What do I do if my vessel is involved in a marine casualty?

RESPONSE:

Refer to 46 CFR 4.05-1 to determine if the incident is considered a Reportable Marine Casualty. If it is a Reportable Marine Casualty then you must comply with all reporting requirements as noted in the CFR and incorporated by reference in 46 CFR 140.900 which begins with notification to the local OCMI.

Once the Coast Guard has been notified according to 46 CFR 4.05-1 you may receive a CG-835V.  If the 835V is issued with an action code of “A” please follow these steps to properly report the incident TVIB:

• Call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:
  • URGENT: immediate assistance is needed, regardless of the time of day; or
  • NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.
• Email the 835V to TVIB. Click here to submit the 835V via email.

The OCMI retains the sole authority to close out a CG-835V.

Incidents that are not considered a Reportable Marine Casualty according to 46 CFR 4.05-1 may be reviewed by the auditor during the course of the next management audit.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document. If you have any questions about this process you may call 832-323-3992 or click here to send an email and a staff member will get back to you.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials o click here to send an email to request them.

QUESTION: When do I need to alert TVIB that my vessel is going into drydock for repairs?

RESPONSE:

You need to alert TVIB when your vessel is going into drydock for the following:

• Any Credit Drydock
• Non-credit drydock that involves the following:
• Any repair to a fuel tank;
• A repair that crosses two or more frames; or
• Steel replacement of greater than 324 square inches.

If you have any questions please call 832-323-3992 during normal business hours or click here to send an email and the appropriate staff member will get back to you.

If you require assistance after hours please call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:

• URGENT: immediate assistance is needed, regardless of the time of day; or
• NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document.