July Training Opportunities – Space Is Limited

TVIB and ACTSafe Training are hosting a Subchapter M suite of courses in Houston the week of June 9th – Space is Limited.  You can register for all three courses or just the one(s) needed.  Each course builds upon the other.  If you’ve already taken the MILA course consider expanding your depth of knowledge and exposure to critical Subchapter M elements. See below for course descriptions and links for registration.

Marine Internal Lead Auditor (MILA) – July 9-10 – Houston, TX – Marine Internal Lead Auditor

TVIB has partnered with ACTSafe Training in this Coast Guard recognized Marine Internal Lead Auditor course, designed to teach the specific skills and knowledge necessary to conduct and lead internal audits for commercial marine companies.

The course meets the requirements of ANSI Z 490.1 Criteria for Accepted Practices in Safety, Health and Environmental Training and the requirements of 46 CFR 138.310(d)(2).

Course Information and Registration

Risk Management – July 11 – Houston, TX

The RCP requires risk a risk process and most companies are not providing training in how to conduct risk assessments. This course is written by the author of the RCP risk section (Rick Dunn). Persons taking this class will leave with simple risk tools that can be used in the workplace. With Subchapter M becoming law in 2018, it makes sense to ensure your risk process meets the ISO 31000 risk standard.

You will learn:

  • Risk management vs Risk Assessment
  • The Risk Pyramid
  • RCP, TMSA3, Sub M risk requirements
  • Review key risk tools and concepts of ISO 31000
  • Failure Effects Mode Analysis (FEMA) risk methodology
  • How to use risk tools to assist in creating a Permit to Proceed Process for COI discrepancies under Subchapter M
  • How to conduct hazard bases qualitative risk assessments (format provided)
  • How to implement a simple yet effective JSA process

This course is suitable for managers, safety personnel, vetting advisors (oil majors and operators), regulators, operations managers and Port Captains.

Course Information and Registration

Subchapter M TSMS Objectices for Designated Persons – July 12 – Houston, TX

As the industry enters into a “regulated management system” world, the TSMS becomes critical to managers and those serving as Designated Persons under RCP or the ISM Code. This course is designed to help management and individuals protect their interests while demonstrating they are meeting the TSMS objectives of Subchapter M. The current language in Sub M appears to expose management and DPAs should a major incident occur or if a third party challenges their TSMS methodology. This course explores how best to protect your interests while making the TSMS more effective.

You will learn:

  • The history of the DPA with a case study review
  • Understanding how to meet the purpose of a TSMS for USCG and Customer needs
  • Critical success factors for marine managers and operations personnel
  • Management of Change concepts
  • Importance of Hierarchy of Controls in a TSMS improvement process
  • Each TSMS objective in Sub M is reviewed and methods to demonstrate how to meet them are discussed and explained
  • How to improve your internal audits to demonstrate compliance with the objectives
  • How to use Management Reviews to maximize compliance and improve effectiveness
  • Details of how the best operators ensure that their TSMS meets the objectives and is effective

This course is suitable for managers, DPA’s, safety personnel, vetting advisors (oil majors and operators), regulators, operations managers and Port Captains.

Course Information and Registration


USCG: TVNCOE Updates the FAQs

06/06/2018 – The following content was published on the Coast Guard Maritime Commons blog. Reposted in its entirety.

The Towing Vessel National Center of Expertise recently published the latest additions and updates to the Frequently Asked Questions regarding Subchapter M, inspected towing vessels. As a convenience for our readers, in this post Maritime Commons is providing a compilation of those changes. To access the full library of FAQs regarding Subchapter M, be sure to visit TVNCOE’s website.

Subchapter M FAQs updated as of May 29, 2018:

Part 136 – Certifications

FAQ 136-023: How will the next drydock be determined when generating a COI?

The next drydock date will be determined by the vessel’s operations and the initial COI date:
For vessels in salt water service the date for the next drydock would need to be within 36 months of the initial COI.
For a vessel in fresh water service the next drydock would need to be within 5 years of the initial COI.
See 46 CFR 137.300 for additional details.

Part 138 – Towing Safety Management System

FAQ 138-024: Will the Coast Guard document deficiencies found while onboard inspected towing vessels utilizing a Third Party Organization and Towing Safety Management System, and if so, how?

Documentation of deficiencies by the Coast Guard will depend on the type of inspection and presence of the vessel’s TPO.
• Deficiencies identified by a vessel’s TPO will be documented by the TPO in accordance with the vessel’s TSMS.
• Deficiencies identified when both the TPO and Coast Guard are present will be documented by the TPO in accordance with the vessel’s TSMS, with the exception of an inspection for certification.
• Deficiencies identified during an inspection for certification, which will occur once every five years, will be documented by the Coast Guard.
• The Coast Guard will document all marine casualties and may document major non-conformities or an unsafe condition as per the definitions provided in § 136.110.

Coast Guard inspectors will typically inspect TSMS vessels only once in five years, unless involved in a marine casualty. However, when deficiencies are found during those inspections, it may be indicative of a failed or failing system. To ensure effective oversight of vessels that utilize a TSMS and effective oversight of their Third Party Organizations, deficiencies issued to towing vessels during Coast Guard inspections must be documented and tracked. The CG-835V, Notice of Merchant Marine Inspection Requirements, is the method to document deficiencies identified during Coast Guard inspections onboard U.S. vessels. Marine Safety Manual Volume II, Section A, Chapter 3, requires all outstanding deficiencies issued on a CG-835V to be entered into MISLE.

Refer to CG-CVC Policy Letter 17-10, Deficiency Recording and Reporting for Vessels Using a TSMS Option.

Part 139 – Third Party Organizations

FAQ 139-011: When will the Coast Guard publish a list of Third Party Organizations?

Once a Third Party Organizations is approved, it will be listed and shared on the TVNCOE website. Currently, all Authorized Classification Societies are automatically approved to act as TPOs as permitted by the Subchapter M requirements. As part of an initiative to support a smooth rollout of Subchapter M, the Coast Guard is drafting additional implementation guidance for TPOs. See also CG-CVC Policy Letter 17-04, Subchapter M TPO Guidance. This line of effort should facilitate the TSMS Option and the 24-month phased-in compliance timeline.

FAQ 139-026: Some organizations will wish to apply to the Coast Guard to become a Subchapter M third-party organization to be able to provide Subchapter M compliance verification services immediately upon publication of the final rule. Will the Coast Guard offer additional guidance on this application process, and if so, when will this guidance be issued?

Yes. Section 139.120 of this rule sets out third-party organization (TPO) application requirements. Amplifying guidance, including an application checklist for TPOs can be found in CG-CVC Policy Letter 17-04, Subchapter M TPO Guidance, posted on the Towing Vessel National Center of Expertise’s website. We expect to update this guidebook frequently based on lessons learned as the TPO program is established.

FAQ 139-027: Who may do business as an “approved third party?”

Recognized and Authorized Classification Societies, and other private commercial companies that meet the requirements and are approved by the Coast Guard, may conduct work as prescribed in Subchapter M as a TPO. Part 139 of Subchapter M sets the requirements for TPOs. CG-CVC Policy Letter 17-04, Subchapter M TPO Guidanceprovides further information.

Part 140 – Operations

FAQ 140-001: What are the PIC requirements and when will they be implemented, considering that no one other than the Master or mate/Pilot typically holds an MMC?

PIC requirements have been outlined in CG-MMC Policy Letter 01-17, Guidelines for Issuing Endorsements for Tankerman PIC Restricted to Fuel Transfers on Towing Vessels.

FAQ 140-002: OSHA Coverage – Do OSHA requirements still apply to working conditions on towing vessels covered by Subchapter M of Chapter I of 46 CFR?

Yes. OSHA’s requirements for these towing vessels will remain in effect until July 20, 2018, or when the vessel obtains its COI, whichever date is earlier. See 29 C.F.R. 136.172. However, the Coast Guard remains the lead agency and continues to receive reports of marine casualties for injuries, death, etc. as currently required by 46 CFR part 4. Beginning July 20, 2018 or the date of the issuance of a COI for a towing vessel, whichever comes earlier, existing towing vessels covered by Subchapter M will be “inspected vessels” within the meaning of the1983 memorandum of understanding between the Coast Guard and OSHA and thus the working conditions of seamen on those vessels will not be covered by OSHA. Therefore, beginning on July 20, 2018, OSHA will cover seamen only on those towing vessels that will remain uninspected vessels. See 29 CFR 1936.105 for the types of towing vessels which will remain uninspected vessels.

A further delineation of the authorities of each agency and applicable requirements is provided in OSHA’s Directive: CPL 02-01-047 (Effective date: 02/22/2010) – Subject: OSHA Authority Over Vessels and Facilities on or Adjacent to U.S. Navigable Waters and the Outer Continental Shelf (OCS).

Part 143 – Machinery and Electrical Systems and Equipment

FAQ 143-036: 1) Can tachometers and the direction of the throttle be used as thrust monitoring? This seems reasonable for smaller vessels with traditional propeller propulsion. The preamble leads me to believe the Coast Guard is looking for something more sophisticated but virtually no small vessel operators I have encountered see the value in adding more instruments (at least on smaller vessels under 65’).

1.a.) Similarly, is the Coast Guard going to accept the position of the tiller on vessel equipped with tiller style steering as an acceptable means for rudder angle indication? Again, the preamble suggests that a Rudder Angle Indicator is needed even on tiller style steering systems, but the smaller operators that I am speaking with aren’t convinced of the value.

1) In part. Tachometers and throttles must be able to accurately and continually be capable of displaying direction and relative amount of thrust of an engine and/or propulsor in the ahead or astern mode. A tachometer is one example of a method to monitor thrust. Other methods may be used to monitor thrust to comply with §143.225.

1.a) Mechanical position of the steering tiller can be used as an alternative means of rudder angle indication if the position of the tiller and rudder can be directly and physically seen by the operator at each operating station. The direction of off-centerline thrust can be displayed by the use of mechanical or electronic rudder angle indicators. The use of vessel swing meters or swing of a compass card is another example.

Part 144 – Construction and Arrangement

FAQ 144-014: Guidance is needed as to what is necessary to demonstrate vessel stability if it is questioned by a TPO or the Coast Guard.

If the stability of the vessel is questioned by either the TPO or the Coast Guard, §144.300(b)(1) cannot be satisfied and the owner or operator must be able to show compliance with either §144.300(b)(2) or §144.300(b)(3). §144.300(b)(2) allows OCMIs to witness operational testing, to determine whether the vessel has adequate stability and handling characteristics. §144.300(b)(3) offers owners and managing operators an opportunity to present documentation, records, and/or calculations to the Coast Guard to prove adequate stability.

Click here to read the full post on the Coast Guard Maritime Commons blog.

Nautical Institute – Gulf Branch Technical Seminar: Subchapter M

The Nautical Institute – Gulf Branch 
Technical Seminar: Subchapter M
The NI-Gulf Branch Committee is excited to announce its final program for Spring 2018. In an effort to reach out to, and to serve the Gulf Mexico uninspected vessel maritime community, the next technical seminar will focus on Subchapter M.
Here are the details:
The Event: NI-Gulf Branch 
Subchapter M Technical Seminar
Place: West Gulf Maritime Association
Cost: Free
Registration Link: 
We wish to thank the four Third Party Organizations, who will be providing experts for our seminar:
  • Towing Vessel Inspection Bureau: Tava Foret
  • American Bureau of Shipping: Joshua LaVire
  • Decatur Marine Audit & Survey: Kevin Wakefield
  • Sabine Surveyors: Robert Keister
Register today, and please share this newsletter with the broader maritime community, especially those who will be impacted by Subchapter M.
For more information: