TVIB News Caleb King

CG D8 – Policy Letter Regarding Towing Vessel Sidelight Placement

CG D8(dp) Policy Letter 02-2022 establishes that towing vessel sidelights located on outer edge of pilothouse or superstructure are considered compliant.  Lighting requirements under the International Navigation Rules state that power-driven vessels of 20m or more shall have side lights place “at or near the side of the vessel”.  The Coast Guard’s Marine Safety Manual interprets “at or near the side of the vessel” to mean not more than 10% of the breadth of the vessel inboard from the side, up to a maximum of 2 meters.

This policy along with D8 communication clarifies that a Certificate of Alternative Compliance (COAC) is not required when a towing vessels’ sidelights are located on the outer edge of the pilothouse or superstructure.

For full details, see the policy letter here.

TVIB: Introducing Bi-monthly “TVIB Talks” Series

TVIB is kicking off a new series of bi-monthly “TVIB Talks” with the first session being next week on Thursday, January 27th.  This series will offer TVIB staff the opportunity to share the latest developments, issues, and trends related to Subchapter M and our perspective on those topics.  Equally important will be the opportunity for TVIB Members (TPO Customers and their staff along with TVIB Certified Auditors and Surveyors) to participate in the conversation by talking with us about the information presented and sharing topics of interest to them.

These 1-hour sessions will follow a bi-monthly schedule occurring at 2:00 pm on the fourth Thursday starting next week.

TVIB Talks will be open to all TVIB Members.  Prior to each session, TVIB Members will receive an email link to register. Please save the date for these sessions and we look forward to this new method of interacting with our members.

2022 TVIB Talks Dates

January 27th
March 24th
May 23rd – Info Session in conjunction with Spring Board Meeting
July 28th
September 22nd
November 15th – Info Session in conjunction with tentatively scheduled Fall Board Meeting



Reporting Inoperable Navigation and Communication Equipment

Did you know the current supply chain disruption has made radars and radar parts difficult to obtain? So, what happens if you can’t get your radar repaired within 96-hours? Currently, radar units and radar parts are experiencing up to a 5-month back-order. This blog is being published to remind you of some regulation outside of Subchapter M that must be followed for navigational equipment.

Subchapter M brought about some new reporting requirements, but there are still plenty of pre-Subchapter M regulations that have reporting requirements for towing vessel related issues. Some of those notifications include marine casualties (46 CFR Part 4), vessel security (33 CFR Parts 101 and 104), and inoperable navigation safety equipment (33 CFR Part 164). The focus of this writing is on the requirement for reporting inoperable navigation safety equipment.

Subpart G (Navigation and Communication Equipment) of Subchapter M starts at 46 CFR 140.700. Within Subpart G you will find the equipment requirements for radar, VHF radio, fathometer, search light, electronic position-fixing device, and magnetic compass/swing meter. The same equipment is found under 33 CFR 164.72(a) along with some additional details (i.e., applicability and specifications).

So, what happens when one of these required items fails? This is where you turn your attention to 33 CFR 164.82, the requirements on maintenance, failure, and reporting. Let’s look a little further at each of these three aspects.

  • Maintenance – This one is simple. If the vessel is required to carry the equipment, it must be maintained operable.
  • Failure – If the equipment fails, it is to be repaired as early as practicable and an entry made in the vessel’s log. As the rule states, failure of the equipment does not constitute the vessel is unseaworthy or that the voyage must be halted. However, the master/operator must consider the failed equipment as part of the navigational assessment [see 46 CFR 140.635] and decide if it is safe for vessel to proceed.
  • Reporting – If operating within a Vessel Traffic Service (VTS), the master/operator is to report the inoperable equipment condition to the VTS.
  • Radars – There are special provisions for deviation from the radar requirement. If you experience a radar failure, and can’t achieve repairs within 96-hours, the owner/master/operator must notify the Captain of the Port (COTP) and seek both a deviation from the radar requirement and authorization for continued operation.

We suggest you share this information with your crews and remind them to review the applicable components within your Towing Safety Management System (TSMS) that may be related to navigational safety equipment and notifications.

This blog contains abbreviated descriptions of regulatory text. Please consult the cited regulations for full context. Regulatory text can be found at