TVIB News News and Updates

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.


Annual Survey of Towing Vessels (ASTV) Course – St. Louis, MO October 17-20

We are conducting the Annual Survey of Towing Vessels (ASTV) Course in St. Louis, Missouri, October 17th to the 20th.


“Very well laid out and demonstrated good examples and team exercises.”  Recent Student

Our four-day Annual Survey of Towing Vessels (ASTV) course provides surveyors with the knowledge and skills required to perform Subchapter M annual surveys of towing vessels. Students who successfully complete this course will have an in-depth understanding of both internal survey programs and external annual survey programs, the reporting requirements of each.

This course is for those seeking to perform annual internal surveys on behalf of their company or as a third-party contractor performing annual internal or external surveys and for those that will manage these programs. Please see the link below for more information or to register for the course.

More Information/Register


5-Day ISO Lead Auditor Class – September 11-15, Mandeville, LA

ISO Lead Auditor – 5-Day Course taught by Quality Management International, Inc. (QMII)

September 11-15 in Mandeville, LA

This course is intended for those persons seeking certification as a Lead Auditor for Subchapter M and the AWO RCP.

TVIB has partnered with QMII in this course designed to help you learn the requirements of ISO 9001 and how to relate the requirements to your business management system. This course gives the tools necessary to conduct and lead process and system audits to determine conformity to ISO 9001. It also provides an understanding of how process-based management systems are responsible for ensuring customer requirements are determined and consistently fulfilled over time. The instructor incorporates three basic principles: audits should benefit both parties; audits focus on process and system effectiveness (beyond mere conformity) with respected to agreed audit criteria; and auditors should use the process approach to audit both documented and undocumented processes to determine system effectiveness.

TVIB has negotiated a discounted rate of $1,256 per person to attend this course (the regular fee for this course is $1,795 per person) This course is not being offered directly through TVIB so the TVIB Member Discount does not apply. Registration will process through QMII directly.


Should the above direct register link not work please use the following link and be sure to enter the code TVIB9001_SEP17 for a TVIB discount on their regular course fees.

Alternate Registration Link

Registrants can also call the QMII office for any assistance with registration at 888-357-9001. If you do contact QMII directly, be sure to mention TVIB when registering for the course in Mandeville, LA.

TVIB has contracted with the Comfort Suites in Covington, LA to secure a group rate ($89 per night plus tax) for those who may need to make hotel arrangements. The hotel is located approximately 8 miles from the training facility at the following address: Comfort Suites, 30 Louis Prima Drive, Covington, LA 70433, 985-809-1234. Please call the hotel directly at the number listed above and ask for the front desk (NOT central booking) to book your room. You need to ask for the QMII ISO Course discounted rate. You must book your room no later than August 28, 2017 to take advantage of the group rate.