TVIB News Subchapter M Updates

USCG: Update to Guidance for TSMS Option Vessels Under Subchapter M

Originally posted on the USCG Maritime Commons


The Office of Commercial Vessel Compliance recently updated work instruction CVC-WI-013(3), “Towing Vessel COI Inspections under TSMS Option.” Updates include but are not limited to adding annual and renewal Certificate of Inspection guidance for Towing Safety Management System (TSMS) option vessels inspected under 46 CFR Subchapter M.

Officers in Charge, Marine Inspection (OCMIs) should reference this guidance when issuing a COI under 46 CFR Subchapter M for inspected towing vessels choosing the TSMS option. A flow chart is included in the Work Instruction to illustrate the TSMS compliance process. 

For full details, view or download the Work Instruction

If you have any questions regarding this policy please contact the Office of Domestic Commercial Vessel Compliance (CVC-1) via

AWO: July 1 – FINAL Deadline to Harmonize TSMS Certificate and RCP Certification Dates

As a reminder, July 1 is the final deadline for an AWO RCP certified company to harmonize their RCP certification date with their TSMS certificate eliminating the need for duplicative audit cycles.

You must formally request this from AWO and submit a copy of your TSMS certificate with the request. Do not hesitate to contact us if you should have any questions.

USCG: Sub M COI Update


The Towing Vessel National Center of Expertise (TVNCOE) reports that approximately 750 COIs have been issued with another 450 currently in the queue. They believe this represents approximately 22% of the 25% of the fleet towing vessels needing COIs in by July 22, 2019 (year one of the four-year phase-in).

They estimate that 219 companies have received a TSMS certificate/DOC and are using an SMS for compliance that those companies represent roughly 3,250 towing vessels.