On November 6, 2023, CVC published revision (7) to CVC-WI-013. The revision is substantial, so we are highlighting some of the major changes for you. We strongly encourage all owners, managing operators, compliance personnel, auditors and surveyors for towing vessels to read this work instruction as it is the most comprehensive source of Coast Guard policy guidance for Subchapter M towing vessels. Changes include:
- A new “reduced risk-based inspection and certification” program for TSMS option vessels, which allows an owner or managing operator the opportunity to request a reduced scope of the inspection for COI renewal to just essential systems. The O/MO may request a reduced risk inspection at the time of COI renewal if:
- An O/MO provides objective evidence that a full TSMS survey was conducted that year;
- The TPO provides objective evidence that the vessel has no major non-conformities in the last 5 years; and
- The vessel has not been issued any code 30 deficiencies by the Coast Guard in the last 5 years.
- Providing guidance for O/MO who wish to renew their COIs early, and when the Coast Guard should maintain the same COI month and day on the renewal COI, versus resetting the COI anniversary date.
- Incorporating the information from Coast Guard Policy Letter 17-02 and Coast Guard Policy Letter 18-01 into WI-013, and subsequently cancelling both policy letters.
- Clarifying the definition of “initial COI” as it relates to vessels that change inspection program options.
- Clarifying expectations for a wide variety of situations that may call for inspection program changes, including vessels changing from CG option to TSMS option, or vice versa, vessels moving between TPOs, vessels being bought/sold, etc.
Click here to view and download the full work instruction.