The Coast Guard Maritime Commons published a two-piece post to help those operators that fall under Subchapter M (goes into effect July 20, 2018) to understand how the new regular may affect a towing vessel’s ability to be used as a resource provider in a Vessel Response Plan. The first part was written with the towing vessel owner/operator in mind, and the second part, immediately following, is written for the Vessel Response Plan holder. (Paraphrased from the original post)
Click here to access the full post on the Coast Guard Maritime Commons.
The Coast Guard office of Commercial Vessel Compliance issued CG-CVC Policy Letter 17-02 (CH-1) Use of Existing Safety Management Systems to Obtain an Initial Certificate of Inspection Under 46 CFR Subchapter M
Refer to 6d on page 4:
For the purposes of issuance of a vessel’s initial COi, 46 CFR 138.115 states, “the owners or managing operators selecting the TSMS option must obtain a TSMS Certificate at least six months before obtaining a COi for any of their vessels covered by the TSMS certificate”. In lieu of meeting 46 CFR 138.115, a company may submit objective evidence to the Coast Guard that it and its vessels have been operating under an existing safety management system per 46 CFR 138.225, for a minimum of three years, as an equivalent level of safety, and will not be required to have a TSMS Certificate 6 months prior to the issuance of a vessel’s initial COi. This objective evidence includes, but is not limited to, external management audit reports covering a minimum of three years prior to the date of the issuance of a vessel’s initial COi. The company must possess a TSMS Certificate prior to the date of the issuance of a vessel’s initial COi, if this “3-year objective evidence” equivalency is used by the company.
Click here to download CG-CVC Policy Letter 17-02 (CH-1)
Final Installment – At the 2017 International WorkBoat Show last December, Chris Parsonage, TVIB President, presented on a panel discussing the TSMS option versus the U.S. Coast Guard Inspection option for Subchapter M compliance. Following is the fourth and final in a series of posts from that presentation.
Factors to consider in TPO selection:
- What are the major costs that should be considered?
- What does the TPO charge?
- What happens after the introductory special disappears?
- Is my TPO committed to the Commercial Towing Market?
- Will the TPO be less responsive when the oil industry rebounds?
- Can the TPO meet our schedules?
- Can the TPO perform multiple compliance audits within one audit so that it will meet other audit requirements such as AWO RCP?
- What is the anticipated vessel downtime waiting for inspections or audits to be completed?
- Will the TPO work to understand my operation?
- Will the TPO provide guidance to help answer compliance questions unique to my company?
- Does the TPO offer training for employees of companies selecting the Internal Survey Option?
- Does the TPO have an adequate number of trained auditors and surveyors?
- Will there be auditors and surveyors in all the locations where my vessels operate, or will they need to travel a long distance to perform the services?
- Auditor and surveyor travel costs can amount to 25-40% of the cost of this work.
- Will the auditors and surveyors be familiar with commercial towing vessels and related regulatory requirements for the specific vessel, and their route and service?
- How is the TPO going to interpret equipment repair or replacement?