TVIB News Subchapter M Updates

USCG: 4/18/2019: Subchapter M – Only a few days left to schedule inspections to meet July 22, 2019 compliance requirements

Reposted from USCG Maritime Commons

4/18/2019: Subchapter M – Only a few days left to schedule inspections to meet July 22, 2019 compliance requirements

Posted by LT Amy Midgett, Thursday, April 18, 2019

From the desk of Rear Adm. John Nadeau, assistant commandant for prevention policy

As of July 20, 2018, towing vessel owners and operators are responsible for ensuring that their vessels comply with the provisions of 46 CFR Subchapter M, even if they have not received a Certificate of Inspection (COI). Additionally, in accordance with 46 CFR 136.202, owners and operators are responsible for ensuring that 25 percent of their fleet has received a COI before July 22, 2019.

46 CFR 136.210 requires the owner or operator to schedule inspections for initial certification with the local OCMI at least 3 months in advance of the desired inspection date. Consequently, towing vessel owners and operators must schedule a vessel’s inspection before April 22, 2019 if the COI is expected to be received in the first year. In addition, at least 30 days before the inspection, the owner or operator must submit a completed CG-Form CG-3752, “Application for Inspection of a U.S. Vessel,” (new construction vessels use CG-3752A) to the OCMI indicating if the Coast Guard or Towing Safety Management System (TSMS) option will be used to meet these requirements.

Given that COIs must be issued to approximately 1,250 towing vessels during this first year of the phase-in period, and another 2,000 during the 2019-2020 phase, close coordination between owners and operators, Third Party Organizations (TPOs), and the OCMIs is necessary to reduce delays to the towing industry. If you have not already done so, I highly encourage you to make contact now with the local OCMI that will be conducting the vessel’s initial COI and schedule an inspection date. While we understand the dates may shift due to operational obligations, a tentative date will help the Coast Guard manage resources to ensure a marine inspector is available. When scheduling an inspection, please indicate whether the vessel will be using the Coast Guard or TSMS option.

Please use this link to view the “Towing Vessel Certificate of Inspection (COI) Phase-In Date Guidance” and determine the number of vessels in a fleet that must be inspected each year of the phase-in period. The phone number for each OCMI can be found here, or at the end of this post.

The phase-in period is provided to spread the workload and cost over time, and mitigate impacts on vessel owners and operators, TPOs, OCMIs, and other stakeholders. Failure to meet the regulatory phase-in schedule could result in vessel and other operational delays, civil penalties, or other possible enforcement actions.

Lastly, owners and operators are reminded of their ability to use a TPO to help them obtain a COI in accordance with Subchapter M and, as provided by CG-CVC Policy Letter 17-01, to take advantage of the uninspected towing vessel decal they may have previously obtained as part of the bridging program. Possession of a decal may eliminate the need for a Coast Guard inspection prior to the issuance of a COI. Owners and operators are strongly encouraged to contact their local OCMI and discuss these matters further.

Graphic showing Contact information for Coast Guard Officers in Charge, Marine Inspection

Contact information for Coast Guard Officers in Charge, Marine Inspection

USCG: CG-CVC Policy Letter 19-01 Enforcement Guidance for Assist Towing Vessels When Operating Beyond the Boundary Line

The Coast Guard’s office of Commercial Vessel Compliance issued CG-CVC Policy Letter 19-01, dated April 5, 2019, for purpose of providing enforcement guidance to the Towing Vessel National Center of Expertise (NCOE), Officers in Charge, Marine Inspection (OCMI), and Marine Inspectors (MI) regarding the manning, credentialing, and watchkeeping requirements, applicable to harbor assist towing vessels inspected under 46 CFR Subchapter M that travel outside the Boundary Line. This policy letter will expire on July 22, 2023, unless otherwise rescinded.

As a reminder, “harbor assist” means the use of a towing vessel during maneuvers to dock, undock, moor, or unmoor a vessel, or to escort a vessel with limited maneuverability.

Click here to download CG-CVC Policy Letter 19-01

USCG: Marine Safety Alert – Ensuring Adequate Maneuvering Space

03/28/2019 – Reposted from Coast Guard Maritime Commons: Marine Safety Alert – Ensuring Adequate Maneuvering Space

The Inspections and Compliance Directorate published Marine Safety Alert 03-19, “Have a regime when the current’s abeam: Ensure adequate maneuvering space,” to educate mariners following three recent marine casualties that resulted in the sinking of towing vessels on the Lower Mississippi River. One of the casualties resulted in a fatality. These cases are all under investigation by the Coast Guard, but the preliminary fact finding indicates there are some similarities between the three incidents. In all three cases towing vessels became pinned against another object in an aspect that exposed the vessel broadside to very strong currents. Once in that position, the vessels could not recover and sank.

The high water conditions on the Mississippi River present numerous risks for towing vessels, including unusually strong river currents and dynamic eddies. These river currents are often different from one section of the river to another; therefore it is absolutely essential that vessel operators provide a wide berth when maneuvering around any other vessel or object. For reference, when a river current is flowing at 1 knot, the water is moving at 1.7 feet per second, or approximately 100 feet per minute. This means that in a 6-knot current, the water is moving about the length of a football field in just 30 seconds. Additionally, the faster the current, the greater the forces acting on a vessel when it’s pinned against a stationery object.

The Coast Guard strongly recommends that towing vessel owners, operators, and other responsible parties take the following measures:

• Avoid transiting between two anchored vessels, between two barge fleets, or between any other set of stationary objects.
• Minimize the number of operations that require the vessel to be positioned beam-to the river current.
• Establish minimum distances between the towing vessel and another vessel/object prior when conducting any operation that requires the vessel to be positioned beam-to the current.
• Recognize the risks involved in operating under high current conditions and weigh those risks before attempting to cross in front of stationary objects or attempting an operation that requires the vessel to be positioned beam-to the current.

This safety alert was created by U.S. Coast Guard Sector New Orleans and is provided for informational purposes only and does not relieve any domestic or international safety, operational or material requirement. Questions regarding this safety alert may be sent to the Sector New Orleans Waterways Management
Division at or the Sector New Orleans Inspections Division at

Click here to download Marine Safety Alert 03-19

Click here to access the original post from the Coast Guard Maritime Commons.