Subchapter M – Are You Talking About It Yet?

Sub M 314 Days
Sub M 314 Days

Does your organization own or operate towing vessels?  Yes, how much do you know about and understand 46 CFR Subchapter M – Towing Vessels?  We are 314 days out from the July 20, 2018 deadline for compliance.

Have you thought about how your company plans to obtain Certificates of Inspection for your vessels? Have you decided if your company will be using the TSMS option (§136.130(a)(2)) or the Coast Guard options (§136.130(a)(1)).

TSMS Option
For those choosing the TSMS option, TVIB stands ready to provide the full portfolio of services needed to demonstrate compliance with Subchapter M. We have auditors and surveyors dispersed geographically throughout the US in major ports along the different coasts and along the river systems and their tributaries.  Our pool of auditors can provide the following:

  • Audit Towing Safety Management Systems
  • Audit Towing Vessels
  • Survey Towing Vessels
    • Annual Survey
    • 5-Year Drydock/Internal Structural Examination (ISE)

Coast Guard Option
If your company is planning to use the Coast Guard option have you started conversations with your local OCMI?  Do you have a sense of their resource availability?

Certificates of Inspection (COI)
Do you have a sense of how many vessels you will apply for COI in the first year of compliance? Will you be using a UTV decal to obtain a COI in accordance with CG-CVC Policy Letter 17-01?? If so, are all of your UTV Decals valid now and will they still be valid when you apply for a COI? Do you plan to apply for COIs on more than 25 percent of your vessels in a given year as noted in CG-CVC Policy Letter 17-03? Have you talked with the local OCMI about their process for applying for a COI?

Relationships will be critical to a smooth and successful implementation of Subchapter M in your organization.  If you haven’t started conversations with your TPO or the local OCMI yet, it’s time to get the ball rolling.  Find out now whether or not your TPO has the resources to service your operation. Talk to the local OCMI in the port where you operate vessels to find out what the resources and processes for obtaining COIs will be. Find out how far in advance of July 20, 2018 you can apply for a COI. Find out if it’s possible to obtain a COI on a vessel before the implementation date.  If you have vessels that meet the definition of workboats operating within a worksite (§136.105(a)(3)) talk with your OCMI about requesting a worksite designation. What will you do with vessels that are not operating, up for sale, or may be “moth balled” or “cold stacked.”

Have you started forecasting out your TSMS audit and vessel audits and surveys? Remember to look beyond the initial issuance of the COI and look forward to five years from that date at the renewal.  While the boat business may be slow today and your vessels seem easy to get to, will those same conditions be present in five years? We certainly hope not, but be sure to look beyond today and forecast out for the budgeting and logistics of scheduling external vessel audits and surveys.

Let us help you navigate Subchapter M.  We are here as industry partners to serve your needs.


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