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TVNCOE Compare Differences Between TSMS-Option Vessels and Coast Guard-Option

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Deficiency Trends: A Crucial Comparison Between TSMS and Coast Guard-Option Vessels

Subchapter M compliance remains a cornerstone of safe and efficient towing operations. One of the most telling indicators of compliance health is the rate of serious deficiencies—those that can halt operations or signal unsafe conditions. Understanding how different oversight models impact vessel performance is critical as the industry continues to evolve. Insights from the September 2025 TPO meeting, hosted by the Coast Guard’s Towing Vessel National Center of Expertise (TVNCOE) highlight clear performance differences between TSMS-option vessels and those using the Coast Guard-option.

Fleet Composition: The Foundation for Comparisons

Understanding the makeup of the U.S. towing vessel fleet is essential for interpreting deficiency trends. CWO Jimmy Collins of the TVNCOE states that the fleet currently includes 4,869 towing vessels. Of these, 3,512 operate under a TSMS certificate or Document of Compliance (DOC) issued by a TPO or Responsible Organization (RO), with 2,875 specifically under the TSMS-option. This means approximately 72% of the fleet is managed through third-party oversight, while the remaining 28% falls under the Coast Guard inspection option. This disparity in oversight models provides a meaningful context for comparing serious deficiency rates.

 

 

Trends in Serious Deficiencies

At the September 2025 meeting, Mr. Dave Phillips, Gulf Technical Advisor at the TVNCOE, presented metrics covering serious deficiencies from September 1, 2024, to September 1, 2025. These metrics focused on CG-835V action codes: Code 17 (Rectify deficiencies prior to departure), Code 30 (Restriction/No-Sail Condition), and Code 60 (Detention due to Unsafe Condition). The data was normalized to reflect ‘per vessel inspected’ rates for both TSMS-option and Coast Guard-option vessels.

Key findings from Mr. Phillips’ presentation include:

  • Coast Guard-option vessels incurred more serious deficiencies per vessel inspected than TSMS-option vessels.
  • The divergence is particularly notable for CG-835V codes 17, 30, and 60.
  • TSMS-option vessels demonstrated a relatively steady or slightly declining deficiency rate over successive quarters, while CG-option vessels showed greater volatility and higher peaks.

 

TVIB’s Perspective on this Disparity

From the industry’s viewpoint, several factors contribute to the consistent outperformance of TSMS-option TPO/RO-overseen vessels in managing serious deficiencies:

  • Proactive vs. reactive oversight: TSMS-option helps catch problems early, before they grow into bigger issues. This early action builds safety and confidence. Coast Guard-option vessels, however, may not discover issues until an inspection takes place.
  • Slow fixes: When vessels aren’t regularly audited, problems can linger and get worse by the time inspectors find them.
  • Inspection exposure: Annual Coast Guard inspections can uncover problems that have built up over time, while TSMS-option vessels benefit from continuous oversight that prevents issues from piling up. Ongoing monitoring gives operators confidence that potential problems are caught early.
  • Structural differences among operators: Factors such as company size, maturity of management systems, and staffing levels influence how effectively deficiencies are identified and resolved.
  • Policy and reporting: TSMS-option operators undergo a greater number of compliance activities overall, increasing the likelihood that deficiencies are identified and corrected before being noted by the Coast Guard.

 

Takeaways and Industry Implications

The data presented at the recent TPO meeting reinforces the value of the TSMS-option and provides actionable insights for operators:

  • Shows why choosing the TSMS-option makes sense: The difference in serious deficiencies highlights the benefits of operating under TSMS-option with TPO/RO oversight.
  • Applying data to support decisions: TVIB is gathering and sharing data on deficiency ratios so members can compare performance and keep improving.
  • Focus on root cause and trend analysis: Beyond counting deficiencies, TVIB encourages members to “follow the audit trail”, investigating root causes, identifying common failure modes, and sharing lessons learned.
  • Avoid complacency in TSMS-option fleets: Maintaining high performance requires ongoing vigilance, auditing, training, and management support.

The consistent trend of higher serious deficiency ratios among Coast Guard-option vessels underscores the effectiveness of the TSMS-option model. Every deficiency avoided translates to reduced downtime, fewer corrective actions, improved safety performance, and more substantial justification for choosing the TSMS-option path. TVIB’s unwavering commitment to supporting its members with tools, training, and resources instills optimism about the future of Sub M, driving continuous improvement across the industry.

For TVIB members, this is more than just a statistic—it’s a license to press forward. Every deficiency avoided means less downtime, fewer corrective actions, better safety performance, and more substantial justification for the TSMS-option path.

USCG: MSA – GAS FIRE SUPPRESSION SYSTEMS ON VESSELS

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The Coast Guard has issued Marine Safety Alert 12-25 highlighting a recurring and dangerous issue involving fixed gas fire extinguishing systems aboard vessels. On multiple occasions, the Coast Guard has discovered the safety pins being left in place after servicing, which prevents the system from being activated during an emergency.

Understanding the Issue:

• SAFETY PIN – Used during maintenance to prevent accidental discharge. Must be removed after servicing for the system to operate.
• RETAINING COTTER PIN – Holds the manual activation pull cable in place. Must remain installed for manual operation.

Confusing the two pins or failing to remove the safety pin can leave a vessel vulnerable in a fire emergency.

The Coast Guard’s Marine Safety Alert includes eight (8) strong recommendations for vessel owners and operators. The Coast Guard cites two specific incident examples in the Marine Safety Alert, which was issued May 12, 2025.

Fire suppression systems are only as effective as their readiness. Taking a proactive role in system maintenance can help ensure these systems are ready in case of an emergency.

 Click here to download a copy of Marine Safety Alert 12-25.

USCG: REVISIONS to NVIC 01-89 Change 1 Underwater Survey Guidance – UWILD Considerations

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Review of the Updated UWILD Policy

The updated UWILD policy has no direct impact on the brown water fleet. It emphasizes the importance of visibility during underwater surveys conducted by divers or remotely operated vehicles (ROVs).

Brown water operations—typically conducted in inland and coastal waterways such as rivers, canals, and bays—often involve confined waters and limited visibility. These conditions make it difficult to meet the policy’s visibility requirements, which state:

  • Water clarity must be sufficient for the diver or ROV to view the full height of the propeller and rudder in a single frame.

If this level of clarity cannot be achieved, operators must consider alternatives such as relocating the vessel, waiting for improved conditions, or drydocking.

Other key updates:

  • Expanded Eligibility:Vessels over 15 years old may qualify for UWILD with certain conditions and CG-CVC endorsement.
  • Third-Party Oversight:Unclassed ITVs operating under a TSMS can use their TPO to verify UWILDs without mandatory Coast Guard presence. Simplified documentation applies, and both the TPO and OCMI must be notified.
  • Harmonization:DD/ISE dates may now align with Load Line (LL) inspections for unclassed vessels.
  • Technology Use:ROVs equipped with advanced cameras and lighting may improve visibility in marginal conditions.

All other UWILD policy requirements remain unchanged.