TVIB News Subchapter M Updates

USCG: MSC Updated Plan Review Guidelines – Stability Test Procedures


Excerpt from the Coast Guard Maritime Commons

The Marine Safety Center revised the GEN-05 Review of Stability Test Procedures on 10/16/2018.

This Plan Review Guideline provides general guidance and information for conducting successful stability tests and submitting stability test procedures to the MSC. It applies to vessels certificated under any subchapter of 46 CFR.

Plan Review Guidelines were developed by MSC staff and are provided as an aid in the preparation and review of vessel plans and submissions. They were developed to supplement existing guidance and are not intended to substitute or replace laws, regulations, or other official Coast Guard policy documents. For more information about PRG, contact the MSC at or 703-872-6730. When contacting MSC, reference the PRG by procedure number, e.g. GEN 05.

GEN-05 Review of Stability Test Procedures

Click here to access the full post from the Coast Guard Maritime Commons

USCG: Eighth District Cancels Towing Vessel Inspections Field Notice, D8-TVIFN 18-1 Operational Enforcement Discretion

On 10/03/2018, the USCG Eighth District (D8) issued a memorandum canceling its Towing Vessel Inspections Field Notice, D8-TVIFN 18-1 Operational Enforcement Discretion, dated 01/24/2018, commonly referred to as “Deferred Enforcement,” with the publication of the national policy document CVC-WI-010(1) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels, dated 10/02/2018. Download links for both documents can be found below.


If you have findings (non-conformities and/or deficiencies) from audits, surveys, self-reporting, etc. related to areas previously addressed by the D8 letter or the new national policy document and have developed corrective action plans (CAP) that were consistent with the deferred enforcement language you may need to update your CAP to address the findings in a manner that is consistent with the national policy (CVC-WI-010(1)).

The national policy work instruction document removes the “deferred enforcement” option and leaves operators with three options for addressing the following items:

  • Use of Type II/III PFDs in lieu of work vests §140.430, 141.340
  • Storage of Flammable/Combustible products §142.225
  • Fire pump pitot-tube pressure testing §142.325(a)
  • Length of fire hose §142.325(d) and (e)(2)
  • Pressure vessel (PV) maximum allowable working pressure (MAWP) §143.300(c)
  • Ventilation: Means to stop fans and close openings §144.605

NOTE:The national policy work instruction did not address all items from the D8 letter such as Visual Distress Signals. With the field notice cancelled by D8, the option for deferred enforcement is no longer a viable option for compliance. This does not prevent the operator from requesting special consideration from the OCMI or an equivalency from the MSC as noted below.


  1. Bring the vessel into full compliance with the regulation as written;
  2. Request “Special Consideration” from the OCMI when applying for the COI; or
  3. Request an “Equivalency” from the Marine Safety Center.

If you have open findings on a CAP where the “deferred enforcement” was referenced as the corrective action with plans to correct prior to the first renewal of the COI or when USCG provides additional guidance you MUST update the CAP to be consistent with the national policy by choosing one of the three options above.

As a reminder, the corrective action process is an ongoing activity. During annual internal audits, annual surveys (internal or external) and external management and vessel audits the relevant corrective action plans will be reviewed to determine if findings have been closed along with reviewing open items for their progress.

Towing Vessels Field Notice Cancellation Memorandum of D8-TVIFN 18-1 Operational Enforcement Discretion (both documents included)

CVC-WI-010(1) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels

USCG: D8 MSIB 18-01 USCG OCMI Contact List: Subchapter M External Notifications


The USCG Eighth District published MSIB 18-01: Coast Guard Officer in Charge, Marine Inspection (OCMI) Contact List: Subchapter M External Audit Notifications

Purpose: In accordance with 46 CFR §138.500(a), the owner or managing operator of a towing vessel must notify the local OCMI at least 72 hours prior to an external audit conducted under this part. Third Party Organizations (TPOs) and towing vessel owner/operators are encouraged to use the below contacts for submitting external audit notifications. 

Click here to download USCG D8 MSIB: 18-01