TVIB News Subchapter M Updates

USCG: New Form CG-3752 Application for Inspection of U.S. Vessel

Posted 05/04/2020 on Maritime Commons

The Office of Commercial Vessel Compliance (CG-CVC) has posted an updated CG-3752 Application for Inspection of U.S. Vessel which combines CG form CG-3752 – Application for Inspection of U.S. Vessel and CG-3752A – Application for Inspection of U.S. Vessel (New Construction) into a new single two-page form.

The second page of the form is only needed to be completed in addition to the first page if a U.S. vessel is New Construction or Entering Certificated Service. The updated Application for Inspection reduces redundancy, increases efficiency, and streamlines form completion with necessary values to align with the Coast Guard’s database. It includes embedded hyperlinks, dropdowns, electronic signatures, and manual entry options if needed. 

The form can be found on the Office of Information Management’s (CG-61) forms website by searching CG-3752. 

Any questions, please contact CG-CVC at CGCVC@uscg.mil.

COVID-19 UPDATE: Sector Mobile

On 04/07/2020 Sector Mobile sent out an email related to changes to their inspection protocols in light of the COVID-19 pandemic. The email stressed that crew safety is, as always, “…at the forefront of all operational risk management decisions…” Following are the key elements from this communication related to requirements for towing vessel companies:

  1. Leveraging video inspections utilizing GOOGLE DUO, when approved by Sector Mobile.  We will be sending out procedures on how this will be conducted.  Video inspections will need to be coordinated with the Coast Guard  marine inspectors prior to scheduling.
  2. For TSMS Vessel’s seeking their initial COI, and in addition to the items requested on our checklist, the TPO can send a statement of satisfactorily observing fire, abandon ship, and man over board drills. SECTOR Mobile will then be poised to issue the COI and issue a CG-835v worklist item to conduct drills in the presence of a Coast Guard Marine Inspector within 90 days.
  3. Coast Guard Option initial COI inspections for an existing vessel will require an onboard inspection.  These inspections will be conducted on a case by case basis due to latest COVID-19 guidance and resource availability.
  4. For on vessel inspections, the entire vessel will be cleared of all personnel, with the exception of the Inspection Party.
  5. Inspection Party will consist of; Coast Guard Marine Inspector, vessel Crew, and TPO, not to exceed 5 persons total.
  6. To reduce multiple trips, the vessel will be fully vetted on our end before we attend the inspection and the vessel shall be ready for inspection.
  7. If at any time CG inspectors are met by personnel that are not part of the Inspection party as outlined above, CG members will depart the vessel and require rescheduling of the inspection.

“With the current applications we have received, prior to the changes in operations due to COVID-19, we will continue to vet those packages and schedule an inspection based on the guidelines listed above.  For packages submitted to our office during the COVID-19 crisis, there will be delays in processing as we are operating at a reduced staff to minimize inspector exposure and maintain a healthy workforce.  However, we are still vetting packages and will decide which inspection option to use when scheduling the inspection.  Certificates of Inspections will be e-mailed, and followed up with the original being mailed via the post office. With regards to meeting the 50% deadline by July 20, SECTOR Mobile has not received any guidance on relaxing the enforcement actions that was set forth earlier this year. Nonetheless, our office will do its best to accommodate all requests, and will keep you posted on any changes with enforcement actions.”

The sector noted that the situation is fluid and changing rapidly. They will publish any modification to the list above as needed. You can direct any questions to Mr. York, Chief, Domestic Vessel Branch.

COVID-19 UPDATE: Subchapter M Compliance Deadline Guidance Docs Published

Today we published a COVID-19 webpage as a resource for those in the industry during these unprecedented times. We have compiled our guidelines for addressing impending Subchapter M compliance deadlines, as well as critical information and resources for our TPO customers, auditors and surveyors. Additionally, we have shared additional documents from the U.S. Coast Guard and the American Waterways Operators. We will continue to update the page as we receive updates from the CDC and other federal agencies.

At this time we are postponing all scheduled training through May 31, 2020. We will reevaluate the schedule as additional information and guidance on COVID-19 is released. You can email info@thetvib.org for more information or stay tuned to the blog and education webpages on the TVIB website.