TVIB News Subchapter M Updates

USCG: WI Update to Towing Vessel COI Inspections Under TSMS Option

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.

USCG: Final Rule for Towing Vessel Firefighting Training

On October 23, 2023, the Office of Merchant Mariner Credentialing issued a final rule revising the training requirements for national Merchant Mariner Credential endorsements as master of towing vessels (limited) or mate (pilot) of towing vessels on inland waters (other than the Great Lakes) or Western Rivers routes.

The modified basic firefighting course is limited to towing vessel endorsements for Western Rivers and inland waters other than the Great Lakes. Mariners seeking towing vessel endorsements for other routes must complete a basic firefighting course.

The effective date of this rule is April 1, 2024.

Click here to download the full bulletin.

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!