TVIB News Subchapter M Updates

TRAINING: Launch of the 2020 Training Calendar

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We’re pleased to share with you the 2020 Training Calendar, showcasing the first ten courses scheduled for the year.  We have added the new Drydock/Internal Structural Examination Certification and Confined Space Shipyard Competent Person courses to our course offerings this year (click here to link to the DD/ISE course information). We will continue to add more courses as details are set.

Annual Survey of Towing Vessels April 14 – 16Channelview, TX
Drydock/ISE Certification May 4 – 6Channelview, TX
Confined Space Shipyard Competent PersonMay 7 – 8Channelview, TX
Auditor Certification June 2 – 3Channelview, TX
Drydock/ISE CertificationJuly 21 – 23Pittsburgh, PA
Drydock/ISE CertificationAugust 4 – 6Hebron, KY (Cincinnati)
Drydock/ISE CertificationAug 31 – Sep 2New Orleans, LA
Auditor Certification October 6 – 7Channelview, TX
Annual Survey of Towing Vessels November 3 – 5New Orleans, LA
Drydock/ISE CertificationNov 30 – Dec 2Paducah, KY

Click here for course information and registration.

MORE TRAINING NEWS: We’ve been listening and are developing online course offerings. First up for our online courses will be an Overview of DD/ISE for Compliance Personnel course. This course is intended to communicate the expectations of the DD/ISE program requirements for those that elected to use an internal survey program.  We will walk through how to structure the TSMS to ensure compliance and what to expect from USCG interaction with the TPO, the DD/ISE surveyor and the organization.  We will be developing additional online course offerings and are welcome to hear suggestions and discuss topics that are well suited for the online learning environment.

If you have any questions, please call (832) 323-3992

USCG: CG-CVC Policy Letter 20-01 Subchapter M Enforcement Posture for Certificate of Inspection (COI) Phase-In Requirements

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Excerpt from Coast Guard Maritime Commons – originally posted 02/21/2020

The Office of Commercial Vessel Compliance announced the publication of CG-CVC Policy Letter 20-01, “Subchapter M Enforcement Posture for Certificate of Inspection (COI) Phase-In Requirements,” dated February 20, 2020.  

This policy letter provides guidance regarding the enforcement posture for towing vessels’ COI phase-in requirements within 46 CFR §136.202. As of July 20, 2018, towing vessels subject to inspection under 46 CFR Subchapter M must be in compliance with the requirements of the subchapter, even if the vessel has not yet received a Coast Guard-issued COI. With each subsequent scheduled phase-in date, regardless of inspection option chosen, companies with vessels selected in accordance with this policy that have not been issued a COI in accordance with the regulations, will be issued a Coast Guard Form CG-835V, for non-compliance.  

Read the policy letter for full details.

USCG: CVC-WI-013(4) Towing Vessel COI Inspections Under TSMS Option

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On 12/31/2019, we communicated with you the successful result of our appeal that resulted in the allowance of 90-days before and 90-days after the COI issue date for annual surveys performed under a company’s internal survey program. The USCG first communicated this revised interpretation in the TPO Guidebook (CVC-Policy Letter 17-04 change 2 on 12/31/2019).

Today the USCG issued change 4 to CVC-WI-013 Towing Vessel COI Inspections Under TSMS Option (dated 12/31/2019) that further confirms this position as a work instruction for use by USCG Marine Inspectors. You can find this revision on page two, item D 1 a. i. We have not completed an exhaustive review of the document yet to determine if there are additional changes but we’re proud to have been the leader on this issue with the USCG which resulted in a positive outcome for all companies that have elected to use an internal survey program under the TSMS option.

Click here to download CVC-WI-013(4) Towing Vessel COI Inspections Under TSMS Option