TVIB News

USCG: D8 Policy on Bulwark Height for Rivers Routes

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Bulwark/handrail height has become a hot-button issue with the USCG during COI inspections, at least in one OCMI zone within D8.  District 8 and the Office of Commercial Vessel Compliance (CVC) have upheld the Marine Inspector’s finding on every appeal. Some customers have even been denied the vessel’s COI as a result of this finding.  As a result, we reached out to D8 Towing Vessel Coordinator, Jill Bessetti, and obtained the following information.

At issue is a vessel’s bulwarks and/or handrails being less than the OSHA recommended height of 39.5”- 40”.  In an appeal determination letter, D8 Chief of Prevention stated the minimum height that would provide equivalent protection would be 30” from the deck. If non-compliant bulwarks/handrails are found on the vessel, the Marine Inspector should issue a CG-835v and should mark the deficiency as a work list item, meaning it would not be visible in PSIX.  The company would then submit their proposal for bringing the vessel into compliance.  According to District 8, no COI should be held up as a result of this deficiency.  In instances where space or the vessel’s operations make installing compliant bulwarks/handrails not feasible, hand grabs would be accepted as an acceptable alternative.

SUB M: Audit and Survey Timelines

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Subchapter M has now been in effect for two years and nine months. There have been many audits and surveys, as well as a few drydock/internal structural exams during this timeframe. It is no secret, tracking these Subchapter M events is far from easy. We would like to focus on a few high-level dates, that are significantly important related to audits and surveys for those operators that selected the TSMS option. Some of this information may be specific to TVIB, and there may be slight variances in expectations for other TPOs.

While the tables (linked here and below) present information in a logical manner, it is important to establish what constitutes meeting the compliance deadline. TVIB considers a deadline to be met on the date that TVIB distributes the final report. Performing the activity does not in itself achieve the deadline. For a report to be marked final, the auditor/surveyor must perform the activity, draft the report and submit it to TVIB staff for review. Once TVIB has reviewed the report and accepts the corrective action plan, the report is marked final and is distributed.

Therefore, a vessel owner/operator and auditor/surveyor must allow sufficient time for the review process to take place, including any necessary clarifications or revisions. In most cases, a report can be reviewed and finalized within 3-4 business days, but occasionally the review process may take longer. The tables contain our recommendations on timing for submitting audit/survey reports for review. These recommendations are designed to help the vessel owner/operator ensure a compliance deadline for an audit/survey is not missed.

While there are multiple factors that should be considered before the Coast Guard deems a TSMS Certificate or COI invalid, it is TVIB’s goal that a missed audit/survey compliance date is not among those factors.

Lastly, TVIB has established a working group that is looking at ways to improve the process for identifying, acting on, and verifying corrective actions. It is possible this working group’s recommendations create slight adjustments to timeframes for submitting reports to TVIB. Should any change occur, we will update the tables as necessary.

Download TVIBs Subchapter M Audit and Survey Timelines tables.

We hope you find the above information and below tables helpful. If there is a topic you would like us to consider for our blog, please contact one of our staff members or submit it to info@thetvib.org.

 

TVIB: Upcoming Drydock/Internal Structural Examination Course

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As our Spring training schedule wraps up, TVIB is offering one final Virtual Drydock/Internal Structural Examination Course May 4th-6th, 2021. Register today as seats are limited.

Subchapter M requires all inspected towing vessels that have obtained a Certificate of Inspection (COI) to undergo a drydock and internal structural examination (DD/ISE) at least once for freshwater vessels and twice for saltwater vessels every five years.

This three-day course will provide those surveyors who plan to conduct drydock and internal structural examinations of inspected towing vessels for compliance with Subchapter M the tools, skills and knowledge to complete these examinations, and provides a path toward an industry-recognized credential. *Pre-course online work is also required.

*Registration link at the bottom of the page.

Who should attend:

  • Marine surveyors
  • Naval architects/naval engineers
  • Coast Guard Marine Inspectors and Investigators
  • Shipyard personnel involved in vessel repairs
  • Port engineers
  • Survey program managers
  • Individuals who intend to conduct drydock and internal structural examinations of ITVs

What will I learn in this course?

  • Learn how to conduct drydock examinations of towing vessels and internal structural examinations
  • Learn how to write examination reports that satisfy Subchapter M requirements
  • Understand the relationships between the third-party organization (TPO), surveyor, vessel owner/managing operator, Coast Guard and shipyard along with the expectations for each party involved
  • Understand how the vessel’s TSMS affects the DD/ISE process
  • Learn how to apply guidance from multiple reference materials to assist in making determinations of whether an item’s condition is suitable for route and service
  • Learn how to approve corrective action plans (CAP) that will meet TPO and Coast Guard expectations

* Following the successful completion of this course, individuals seeking to become credentialed DD/ISE surveyors must complete the application process and complete a practical demonstration of surveying skills, which may include a “check ride” with a certified TVIB Drydock/ISE Surveyor.

Individuals who do not intend to conduct drydock and internal structural examinations may attend the course to obtain a better understanding of what is entailed in these compliance activities.

Register–  May 4-6, 2021 – VIRTUAL