TVIB News Subchapter M Updates

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: 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.    

TRAINING: TVIB Launches Drydock and Internal Structural Examination (DD/ISE) Certification Course

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Subchapter M brought many new changes to the towing vessel industry, and now that we are two and a half years removed since the Coast Guard issued the first Certificates of Inspection (COIs), towing vessel operators are beginning to address compliance with another key component of the regulation – periodic drydock and internal structural examinations for credit.  46 CFR 137.300 requires all towing vessels to undergo a drydock and internal structural examination at least once in five years for vessels that are not exposed to salt water more than six months in any 12-month period. Alternatively, vessels exposed to salt water more than six months in any 12-month period must undergo these examinations at least twice in five years, with no more than 36 months between intervals. That means vessels operating in salt water who obtained their COIs early in the implementation process are coming due for their first credit drydock and internal structural examination.

TVIB recognized the need to train surveyors on Subchapter M’s expectations for compliance regarding these events, as there is not currently another course available to the market that focuses on drydock and internal structural examinations. Additionally, TVIB knew that vessel owners and managing operators would need guidance on how their vessel’s TSMS would tie into this set of surveys, for those that chose the TSMS option for obtaining a COI. Over the course of a year, TVIB staff worked alongside a committee made up of TVIB-certified surveyors, NAMS and SAMS surveyors, recently retired Coast Guard marine inspectors, port engineers and other stakeholders with extensive backgrounds in vessel maintenance and repairs, to create course content that is relevant, engaging and provides a consistent, comprehensive process to conducting drydock and internal structural examinations. Mike Rushing, of Rushing Marine Service in Jackson, MO, is the primary course instructor.  He and staff spent many hours in shipyards during course development, creating a rich library of photo and video images that help drive student/instructor conversations about vessel conditions and suitability.

The core content of this three-day course, which is currently being held virtually but plans to transition back into a classroom setting when COVID-19 restrictions have been eased, focuses primarily on establishing the role of the surveyor, TPO and Coast Guard during survey activities, how to assess vessel hull structure damage both inside and out, assessing hull thickness, how to apply ABS Rules and NVIC 07-68, among other currently available published resources, and how to write acceptable drydock and internal structural examination reports, while adhering to Subchapter M requirements. There are practical exercises for utilizing the TSMS during the examinations as well. While the course was designed to train towing vessel surveyors, towing vessel owners and managing operators, shipyard personnel and other stakeholders will gain valuable insights into this piece of the Subchapter M compliance puzzle as well. Feedback from the attendees at the first courses has been overwhelmingly positive. One attendee noted “Illustrations that were provided were what you would actually see out in the field. The DD-ISE course explained things for someone on any level of experience, and the dialog with other attendees was excellent.”

The next course offering is scheduled to be held virtually on February 9-11, and again on May 4-6. Registration is now open and can be found at www.thetvib.org.

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