TVIB News Subchapter M Updates

USCG: NPRM Person In Charge of Fuel Transfers

08/14/2019 Federal Register Vol. 84, No . 157 Proposed Rules

SUMMARYThe Coast Guard is proposing to amend the requirements regulating personnel permitted to serve as a person in charge (PIC) of fuel oil transfers on an inspected vessel by adding the option of using a letter of designation (LOD) in lieu of a Merchant Mariner Credential (MMC) with a Tankerman-PIC endorsement. Thousands of towing vessels are currently transitioning from being uninspected vessels to becoming inspected vessels. This proposal would allow a PIC currently using the LOD option on one of those uninspected vessels to continue to use that option to perform the same fuel oil transfers once the vessel receives its initial Certificate of Inspection. Under this proposal, obtaining a MMC with a Tankerman-PIC endorsement would become optional for PICs of fuel oil transfers on inspected vessels. 

DATESComments and related material must be received by the Coast Guard on or before October 15, 2019. Comments sent to the Office of Management and Budget (OMB) on collection of information must reach OMB on or before October 15, 2019. 

ADDRESSESYou may submit comments identified by docket number USCG– 2018–0493 using the Federal eRulemaking Portal at https:// See the ‘‘Public Participation and Request for Comments’’ portion of the SUPPLEMENTARY INFORMATION section for further instructions on submitting comments. 

Click here to read the full Federal Register notice.

USCG: Update to Guidance for TSMS Option Vessels Under Subchapter M

Originally posted on the USCG Maritime Commons


The Office of Commercial Vessel Compliance recently updated work instruction CVC-WI-013(3), “Towing Vessel COI Inspections under TSMS Option.” Updates include but are not limited to adding annual and renewal Certificate of Inspection guidance for Towing Safety Management System (TSMS) option vessels inspected under 46 CFR Subchapter M.

Officers in Charge, Marine Inspection (OCMIs) should reference this guidance when issuing a COI under 46 CFR Subchapter M for inspected towing vessels choosing the TSMS option. A flow chart is included in the Work Instruction to illustrate the TSMS compliance process. 

For full details, view or download the Work Instruction

If you have any questions regarding this policy please contact the Office of Domestic Commercial Vessel Compliance (CVC-1) via

AWO: July 1 – FINAL Deadline to Harmonize TSMS Certificate and RCP Certification Dates

As a reminder, July 1 is the final deadline for an AWO RCP certified company to harmonize their RCP certification date with their TSMS certificate eliminating the need for duplicative audit cycles.

You must formally request this from AWO and submit a copy of your TSMS certificate with the request. Do not hesitate to contact us if you should have any questions.