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SUB M: Audit and Survey Timelines

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Subchapter M has now been in effect for two years and nine months. There have been many audits and surveys, as well as a few drydock/internal structural exams during this timeframe. It is no secret, tracking these Subchapter M events is far from easy. We would like to focus on a few high-level dates, that are significantly important related to audits and surveys for those operators that selected the TSMS option. Some of this information may be specific to TVIB, and there may be slight variances in expectations for other TPOs.

While the tables (linked here and below) present information in a logical manner, it is important to establish what constitutes meeting the compliance deadline. TVIB considers a deadline to be met on the date that TVIB distributes the final report. Performing the activity does not in itself achieve the deadline. For a report to be marked final, the auditor/surveyor must perform the activity, draft the report and submit it to TVIB staff for review. Once TVIB has reviewed the report and accepts the corrective action plan, the report is marked final and is distributed.

Therefore, a vessel owner/operator and auditor/surveyor must allow sufficient time for the review process to take place, including any necessary clarifications or revisions. In most cases, a report can be reviewed and finalized within 3-4 business days, but occasionally the review process may take longer. The tables contain our recommendations on timing for submitting audit/survey reports for review. These recommendations are designed to help the vessel owner/operator ensure a compliance deadline for an audit/survey is not missed.

While there are multiple factors that should be considered before the Coast Guard deems a TSMS Certificate or COI invalid, it is TVIB’s goal that a missed audit/survey compliance date is not among those factors.

Lastly, TVIB has established a working group that is looking at ways to improve the process for identifying, acting on, and verifying corrective actions. It is possible this working group’s recommendations create slight adjustments to timeframes for submitting reports to TVIB. Should any change occur, we will update the tables as necessary.

Download TVIBs Subchapter M Audit and Survey Timelines tables.

We hope you find the above information and below tables helpful. If there is a topic you would like us to consider for our blog, please contact one of our staff members or submit it to info@thetvib.org.

 

TVIB: Upcoming Drydock/Internal Structural Examination Course

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As our Spring training schedule wraps up, TVIB is offering one final Virtual Drydock/Internal Structural Examination Course May 4th-6th, 2021. Register today as seats are limited.

Subchapter M requires all inspected towing vessels that have obtained a Certificate of Inspection (COI) to undergo a drydock and internal structural examination (DD/ISE) at least once for freshwater vessels and twice for saltwater vessels every five years.

This three-day course will provide those surveyors who plan to conduct drydock and internal structural examinations of inspected towing vessels for compliance with Subchapter M the tools, skills and knowledge to complete these examinations, and provides a path toward an industry-recognized credential. *Pre-course online work is also required.

*Registration link at the bottom of the page.

Who should attend:

  • Marine surveyors
  • Naval architects/naval engineers
  • Coast Guard Marine Inspectors and Investigators
  • Shipyard personnel involved in vessel repairs
  • Port engineers
  • Survey program managers
  • Individuals who intend to conduct drydock and internal structural examinations of ITVs

What will I learn in this course?

  • Learn how to conduct drydock examinations of towing vessels and internal structural examinations
  • Learn how to write examination reports that satisfy Subchapter M requirements
  • Understand the relationships between the third-party organization (TPO), surveyor, vessel owner/managing operator, Coast Guard and shipyard along with the expectations for each party involved
  • Understand how the vessel’s TSMS affects the DD/ISE process
  • Learn how to apply guidance from multiple reference materials to assist in making determinations of whether an item’s condition is suitable for route and service
  • Learn how to approve corrective action plans (CAP) that will meet TPO and Coast Guard expectations

* Following the successful completion of this course, individuals seeking to become credentialed DD/ISE surveyors must complete the application process and complete a practical demonstration of surveying skills, which may include a “check ride” with a certified TVIB Drydock/ISE Surveyor.

Individuals who do not intend to conduct drydock and internal structural examinations may attend the course to obtain a better understanding of what is entailed in these compliance activities.

Register–  May 4-6, 2021 – VIRTUAL

TVIB: Date Change for Subchapter M Auditor Certification Course

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The Subchapter M Auditor Course has been rescheduled for April 13th-14th. Register for the April training at the link below or contact Danielle Munoz at: 832-323-4175 — daniellem@thetvib.org for assistance.

Our Subchapter M Auditor Certification Course is for auditors who wish to become certified by TVIB to perform audits of Towing Safety Management Systems to verify compliance with Subchapter M. The American Waterways Operators (AWO) Responsible Carrier Program (RCP) has been approved by the Coast Guard as an approved existing safety management system, and as such, this auditing course will cover some elements of the RCP. This is the appropriate class to complete in order to obtain a TVIB certified auditor credential. It is open to both TVIB members and non-members alike.

The course focuses on training external (third-party) auditors how to use the TVIB audit process, which was developed to meet ISO 19011 Guidelines for Auditing Management Systems, and tailored for the unique situations auditing under Subchapter M and the RCP. It covers auditing both management systems and the vessels that operate under those systems.  It is a hybrid of online and in-classroom learning, with many practical exercises designed to allow students to practice all aspects of auditing. The online pre-course portion MUST be completed prior to attending class.

This course meets the requirements of 46 CFR 139.130(b)(4) for those seeking to perform external audits under a TPO.

*If you are a TVIB member please register through the member portal to receive your member discount.

**If you are a TPO customer employee or a Supporting Organization employee, please contact your company’s representative for log in information to obtain the member discount for this course.

Register- April 13-14

Who Should Attend

  • Auditors who wish to become certified by TVIB to perform American Waterways Operators (AWO) Responsible Carrier Program (RCP) audits and Subchapter M TSMS audits. If you’re interested in certification, you will need to complete and submit the auditor member application and application fee. Your application must be screened by the TVIB Certification Committee and approved prior to attending the course. Those individuals who want the training without becoming certified are not required to submit a TVIB membership application.
  • Marine executives, HSE managers, operations managers, safety consultants and regulators seeking more in-depth information about the AWO RCP and Subchapter M.
  • Individuals who are interested in obtaining Subchapter M and/or the RCP training without becoming a certified auditor are welcome to attend the class.

Please note that TVIB reserves the right to cancel this course based on enrollment numbers and/or instructor availability no later than two weeks before the first day of class.  TVIB will not be responsible for reimbursements to course registrants for travel/accommodation expenses.