TVIB News Industry Press

USCG: Eighth District Cancels Towing Vessel Inspections Field Notice, D8-TVIFN 18-1 Operational Enforcement Discretion

On 10/03/2018, the USCG Eighth District (D8) issued a memorandum canceling its Towing Vessel Inspections Field Notice, D8-TVIFN 18-1 Operational Enforcement Discretion, dated 01/24/2018, commonly referred to as “Deferred Enforcement,” with the publication of the national policy document CVC-WI-010(1) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels, dated 10/02/2018. Download links for both documents can be found below.


If you have findings (non-conformities and/or deficiencies) from audits, surveys, self-reporting, etc. related to areas previously addressed by the D8 letter or the new national policy document and have developed corrective action plans (CAP) that were consistent with the deferred enforcement language you may need to update your CAP to address the findings in a manner that is consistent with the national policy (CVC-WI-010(1)).

The national policy work instruction document removes the “deferred enforcement” option and leaves operators with three options for addressing the following items:

  • Use of Type II/III PFDs in lieu of work vests §140.430, 141.340
  • Storage of Flammable/Combustible products §142.225
  • Fire pump pitot-tube pressure testing §142.325(a)
  • Length of fire hose §142.325(d) and (e)(2)
  • Pressure vessel (PV) maximum allowable working pressure (MAWP) §143.300(c)
  • Ventilation: Means to stop fans and close openings §144.605

NOTE:The national policy work instruction did not address all items from the D8 letter such as Visual Distress Signals. With the field notice cancelled by D8, the option for deferred enforcement is no longer a viable option for compliance. This does not prevent the operator from requesting special consideration from the OCMI or an equivalency from the MSC as noted below.


  1. Bring the vessel into full compliance with the regulation as written;
  2. Request “Special Consideration” from the OCMI when applying for the COI; or
  3. Request an “Equivalency” from the Marine Safety Center.

If you have open findings on a CAP where the “deferred enforcement” was referenced as the corrective action with plans to correct prior to the first renewal of the COI or when USCG provides additional guidance you MUST update the CAP to be consistent with the national policy by choosing one of the three options above.

As a reminder, the corrective action process is an ongoing activity. During annual internal audits, annual surveys (internal or external) and external management and vessel audits the relevant corrective action plans will be reviewed to determine if findings have been closed along with reviewing open items for their progress.

Towing Vessels Field Notice Cancellation Memorandum of D8-TVIFN 18-1 Operational Enforcement Discretion (both documents included)

CVC-WI-010(1) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels

USCG: Harmonization of Fire Protection Equipment Standards for Towing Vessels


The Coast Guard is finalizing an interim final rule that applied the changes made by the 2016 final rule, “Harmonization of Standards for Fire Protection, Detection, and Extinguishing Equipment,” to inspected towing vessels. The interim final rule, published February 26, 2018 in the Federal Register, aligned fire protection and equipment regulations for inspected towing vessels with other commercial vessel regulations.

Click here to download the Federal Register Notice 2018-23314 83 FR 53818


TVIB TRAINING: Remaining Training Opportunities for 2018

Marine Internal Lead Auditor (MILA) – Nov 5-6 in Houston, TX

TVIB has partnered with ACTSafe Training in this Coast Guard Recognized Marine Internal Lead Auditor course (2-day course) , which is designed to teach the specific skills and knowledge necessary to conduct and lead internal audits for commercial marine companies. This fast-paced, informative course requires active participation and successfully completing practical exercises, quizzes, and a final exam in order to earn a certificate.

This course meets the requirement of ANSI Z 490.1 Criteria for Accepted Practices in Safety, Health and Environmental Training and 46 CFR 138.310(d)(2) for those individuals performing internal audits under Subchapter M. This is NOT the appropriate course for those individuals seeking certification to perform TSMS audits for TVIB as a TPO.

More Info/Registration


Sub M Auditor Certification – Nov 13-15 in Houston, TX

The Subchapter M Auditor Certification course (3-day course) teaches external (third-party) auditors how to audit a company’s TSMS, with an emphasis on those companies using the American Waterways Operators’ Responsible Carrier Program as the framework for their TSMS. Students who successfully complete this course will have an in-depth understanding of auditing both safety management systems and the vessels that operate under those systems and what compliance means under Subchapter M. This is the appropriate course for those individuals seeking certification to become an approved TPO Auditor, as well as an RCP Lead Auditor/Vessel Auditor.  This course is also ideal for company personnel who want to better understand the expectations of their external auditor.

This course meets the requirements of 46 CFR 139.130(b)(4) for those seeking to perform external audits under a TPO.

More Info/Registration


Annual Survey of Towing Vessels (ASTV)Dec 4-7 in Houston, TX

The Annual Survey of Towing Vessels course (4-day course) provides surveyors with the knowledge and skills required to perform TVIB TPO Subchapter M annual surveys of towing vessels. It has been designed to teach those who will be performing surveys as a part of an internal survey program, as well as those surveyors who wish to hold the credential to perform external surveys for TVIB. Everyone who successfully completes the course will receive a course completion certificate. This course is the surveying course required for those individuals seeking the TVIB Certified Subchapter M Surveyor for Annual Surveys credential.

More Info/Registration


Make sure to stop by Booth 3944 at the International Workboat Show in New Orleans – November 28-30. We look forward to seeing you there.
Upcoming TVIB Board Meeting in New Orleans November 27th. Stay tuned for details and registration. We will host an info session that same morning.