TVIB News Subchapter M Updates

TVIB Issues Its First TSMS Certificate

June 23, 2017, TVIB issued its first TSMS certificate to Crounse Corporation. Crounse successfully completed a full Subchapter M TSMS audit including a review of its operations for compliance with Subchapter M.

Crounse is the first of a number of companies that have chosen TVIB as their U.S. Coast Guard Approved Third-Party Organization (TPO) for Subchapter M compliance. We are very appreciative of the confidence Crounse showed in TVIB and look forward to a long relationship. Reaching this important milestone in the development of TVIB is a significant achievement for our staff and our members.

We are working with a number of TPO customers to take advantage of the recent Coast Guard policy letter CG-CVC Policy Letter 17-02 and the AWO Alert issued on June 8th, that provided guidance on how a company can use their previous RCP Management Audit towards the issuance of their initial TSMS Certificate.  Additionally, we are preparing those same customers to take the necessary steps to apply for and obtain COIs for their vessels in the coming year.

We have a broad geographic dispersion of Subchapter M Auditors and Surveyors throughout the inland river system, the gulf and from the west coast to the east coast. Our auditors and surveyors are some of the most experienced available. They have a keen understanding of the industry, as many started out their career on deck, moving up to the wheelhouse and on to shoreside operations and management. We know your business and you know our auditors and surveyors.  Contact us to learn how our TPO services can help your organization achieve Subchapter M compliance ahead of the July 20, 2018 deadline.


Tava S. Foret, Executive Vice President, Operations

Chris Parsonage, President

USCG Policy Letter: Phase-In Period for Existing Towing Vessels Using the TSMS Option Under Title 46, Code of Federal Regulations (CFR) Subchapter M

June 14, 2017

The Coast Guard published CG-CVC Policy Letter 17-03

The purpose of this policy letter is to provide guidance to the Officer(s) in Charge, Marine Inspection (OCMI) and the marine industry on the applicability of 46 CFR 136.202, Certificate of Inspection (COI) phase-in period, to existing towing vessels using the Towing Safety Management System (TSMS) option to obtain an initial COI under 46 CFR Subchapter M.

Click here to download CG-CVC Policy Letter 17-03

Subchapter M  TSMS Certificates – Compliance Dates Are Fast Approaching

Have you selected your Third-Party Organization for Subchapter M Compliance?  Have you entered into a formal agreement yet?  Don’t wait until July 20, 2018 to start planning for your External Management Audit for a TSMS Certificate. You must be operating under a valid TSMS Certificate for a minimum of 6 months prior to the issuance of a COI for a vessel.

If you are AWO RCP Certified and have a Mid-Period Management Audit due this year, you should consider having your External Management Audit for a TSMS Certificate completed in conjunction with your RCP Mid-Period Management Audit.  Your Mid-Period Management Audit will need to review the gap between your last certification audit and the 2016 revisions to the RCP, in addition to the requirements for a Mid-Period Management Audit. The delta between that audit and a TSMS Compliance audit is not that great.

If your company is AWO RCP Certified, have you considered what you audit rotation cycle will look like?  There could be an overlap of audit cycles for RCP and TSMS compliance. TVIB stands ready to work with your organization to set up a plan to give you the greatest value in your upcoming audits while lessening the burden of overlapping audit cycles or “audit creep.”

TVIB will be releasing the External TSMS Management Process and Audit Checklist to its members in the coming days. Make certain that you have updated your contact information on the Member Portal so you can access these documents as soon as they are published. We will send out an announcement when they are available for download from the Member Portal on the TVIB website.

For more information on selecting TVIB as your TPO or if you have questions related to Subchapter M compliance, contact Tava Foret at 832-323-2155 or or Chris Parsonage at 832-323-2188 or