TVIB News News and Updates

SUB M: Is your internal auditor properly trained and free from conflicts of interest?

46 CFR Subchapter M 138.310(d)(2) requires those performing internal audits to have completed an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) (incorporated by reference, see § 136.112 of this subchapter) internal auditor/assessor course or Coast Guard-recognized equivalent.


This is NOT the same as an ISO 9001 Lead Auditor course. The curriculum of an Internal Auditor course is different than a Lead Auditor course, just as an internal audit should be very different than an external/third-party audit.

TVIB has worked with ACTSafe Training for the past several years to support the Marine Internal Lead Auditor (MILA) course that is a Coast Guard-recognized equivalent that meets the requirements of §138.310(d)(2).




Additionally, in accordance with §138.310(d)(3) internal auditors may not be the designated person, or any other person, within the organization that is responsible for development or implementation of the TSMS; and §138.310(d)(4) requires that the internal auditor must be independent of the procedures being audited, unless this is impracticable due to the size and the nature of the organization.

It is in an organization’s best interest to use an auditor that is independent of the procedures being audited to avoid a case of “the fox watching the hen house.” The objectivity of the internal auditor is critical to an unbiased review of the organization’s TSMS. The purpose of the internal audit is to ensure the organization has the proper controls, governance and risk management processes in place, according to the Institute of Internal Auditors.

An easy or insufficient internal audit does the operator no favors. The internal activity, on the vessel and in the office, is designed to identify any gaps or deficiencies, to ensure compliance and improve the TSMS.


Please feel to reach out to our staff if you would like to discuss the differences between internal and external audits and the required training for those auditors.

Phone: 832-323-3992

REMINDER: LAST CALL ASTV Virtual Training Course Mar 14-16

This is a friendly reminder that there are a few spots available for our Annual Survey of Towing Vessels course *and* registration is open for the Subchapter M Auditor (TSMS) course.

Annual Survey of Towing Vessels Course-  March 14-16

Our Annual Survey of Towing Vessels course provides surveyors with the knowledge and skills required to perform TVIB TPO Subchapter M annual surveys of towing vessels. It has been designed to teach those who will be performing surveys as a part of an internal survey program, as well as those surveyors who wish to hold the credential to perform external surveys for TVIB.

Who Should Attend

Internal Surveyors: This course is designed for individuals seeking training on the requirements for Internal Surveyors as specified in section 137.315 Internal Survey Programs and are looking to become proficient at conducting Subchapter M compliant internal surveys under the oversight of a Third Party Organization “TPO.”

Third Party Surveyors: This course is also for those surveyors who wish to become a TVIB Certified Subchapter M Surveyor for Annual Surveys. TVIB requires this credential for those individuals who plan to work through TVIB to offer annual surveys to TPO customers. If you are interested in obtaining this credential, you will need to complete and submit the Surveyor Membership Application and application fee PRIOR to coming to class. 

  • Those individuals who want the training without becoming certified are not required to submit a TVIB membership application.
  • This course is open to TVIB members and non-members alike.

Register Now

Subchapter M Auditor (TSMS) Course-  April 11-12

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.
  • 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.


Register Now

TVIB Presenting at Marine Log’s Tugs, Towboats & Barges Conference – Sub M, Beyond COI: What Next?

I will be moderating a panel discussion at Marine Log’s Tugs, Towboats & Barges conference on March 8th in Mobile, AL. Come out to see this panel and many more.

Following is a repost from an article Marine Log published on February 6th, 2023

Sub M, Beyond COI: What Next?

TTB 2023 has a lineup of engaging presentations from industry leaders discussing advancements in technology and design, as well as methods of meeting environmental and economic goals

On March 8, a panel of owners, operators and third-party organizations will discuss crucial aspects of Subchapter M and the Certificate of Inspection (COI) process.

Talking points will include Certificate of Inspection renewal, new construction, incident reporting, the drydock credit process, the submission of internal survey reports to the U.S. Coast Guard, buying/selling/leasing vessels, and more. The group will also discuss lessons learned as they went or continue to go through the process.

Panelists include Tava Foret of the Towing Vessel Inspection Bureau; Sean Reilly from Southern Towing; Brian Khey of Marquette Transportation; Mark McManus, Lebeouf Bros. Towing; Jason Soutiere, ABS; and Robert Keister from Sabine Surveyors.

Join us for this discussion and so much more at TTB 2023. Remember, discounted registration rates end February 17!