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)
- Subchapter M Auditor Certification – February 21-23 – Houston, TX
- Marine Internal Lead Auditor (MILA) – February 27-28 – Houston, TX – Meets the requirements of 46 CFR 138.310(d)(2) as a Coast Guard recognized equivalent
- Risk Management – March 1 – Houston, TX – May be taken alone or in conjunction with the MILA course
- Subchapter M TSMS Objectives for Management and Designated Person – March 2 – Houston, TX – May be taken alone or in conjunction with the MILA course
- TVIB ISO Lead Auditor Course – March 19-23 – Houston, TX – Meets the requirements of 46 CFR 139.130(b)(3)