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TVIB TALKS: Factors to Consider in TPO Selection

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?

TVIB TALKS: Coast Guard Option – Reasons You Should Think Twice

Installment 3 – 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 third in a series of posts from that presentation.

Coast Guard Option – Reasons to Think Twice

Questions to consider before going down the path of selecting the Coast Guard Option over the TSMS Option

  • Availability of qualified Coast Guard Marine Inspectors
    • Does Coast Guard have enough qualified personnel to perform inspections?
    • Uncertainty on the availability of Coast Guard marine inspectors to meet demand if industry chooses Coast Guard option.
    • Much discussion surrounding their current staffing levels and whether or not they will have the ability to keep up with additional workloads of inspecting towing vessels.
  • Cost of Coast Guard Inspection
    • $1,030 per year for all vessels but may increase for Coast Guard inspected vessels after completion of pending rulemaking to review charges.
  • The Coast Guard has not determined how they will deal with the audit portion of annual inspections to verify companies have Health and Safety plans that meet requirements.
    • Does Coast Guard have enough trained personnel to perform audits of required Health and Safety Plans?
  • How will an operator schedule the annual COI inspection for linehaul vessels that pass thru multiple OCMI zones when they do not know where the vessel will be 30 days in advance?
  • Will COI inspections be impacted by shifting Coast Guard priorities?
    • Interruptions due to Coast Guard Resources required for other priorities such as natural disaster recovery (hurricanes, floods, etc.).
  • Coast Guard Marine Inspectors may be lacking experience and knowledge of towing vessels.
    • Recent UTV exams for renewal stickers have created concerns with threatened Captain of the Port Orders for items that aren’t required or were arbitrary.

Be sure to check out our upcoming courses: (click on the course name for information and registration)

 

TVIB TALKS: What should my company do now, if choosing the TSMS option?

Installment 2 – At the 2017 International WorkBoat Show, 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 second in a series of posts from that presentation.

What should my company do now, if choosing the TSMS option for Subchapter M compliance?

  • Pick a TPO soon
  • Evaluate my TPOs requirements for issuing the initial TSMS Certificate
    • Can I utilize previous management and vessel audits or do I need to start over?
  • Obtain a TSMS certificate at least 6 months prior to first COI application
  • Survey all vessels and prepare a gap analysis to ensure all vessels can be in compliance by July 20, 2018
  • Develop a plan for conducting all required management and vessel audits needed for initial COI issuance
  • Talk to your local OCMI
  • Apply for initial COIs

Questions? – Contact us at 832-323-3992