TVIB News Subchapter M Updates

USCG: CG-CVC Policy Letter 21-03 Guidance Concerning the Use of Doubler Plates for Repairs Involving Towing Vessels Subject to 46 CFR Subchapter M

The office of Commercial Vessel Compliance has published its guidance on the use of Doubler Plates, dated 05/19/2021.

Click here to download CG-CVC Policy Letter 21-03.

USCG: D8 Policy on Bulwark Height for Rivers Routes

Bulwark/handrail height has become a hot-button issue with the USCG during COI inspections, at least in one OCMI zone within D8.  District 8 and the Office of Commercial Vessel Compliance (CVC) have upheld the Marine Inspector’s finding on every appeal. Some customers have even been denied the vessel’s COI as a result of this finding.  As a result, we reached out to D8 Towing Vessel Coordinator, Jill Bessetti, and obtained the following information.

At issue is a vessel’s bulwarks and/or handrails being less than the OSHA recommended height of 39.5”- 40”.  In an appeal determination letter, D8 Chief of Prevention stated the minimum height that would provide equivalent protection would be 30” from the deck. If non-compliant bulwarks/handrails are found on the vessel, the Marine Inspector should issue a CG-835v and should mark the deficiency as a work list item, meaning it would not be visible in PSIX.  The company would then submit their proposal for bringing the vessel into compliance.  According to District 8, no COI should be held up as a result of this deficiency.  In instances where space or the vessel’s operations make installing compliant bulwarks/handrails not feasible, hand grabs would be accepted as an acceptable alternative.

SUB M: Audit and Survey Timelines

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