TVIB News Subchapter M Updates

AWO: RCP Certificaiton​ Alignment with TSMS Certificates

June 3, 2019

The AWO Standards Board recently shared two memos and guidance to clarify the alignment of a member’s RCP certification dates with their TSMS certificate dates for RCP certified companies that elected the TSMS option.

The two memos cover the following:

  1. The first clarifies that correspondence shared by AWO with its members in 2015 which contained an audit transition plan for AWO members implementing the AWO Board-approved changes to the RCP which were designed to ensure its acceptance by the USCG as an existing TSMS under Subchapter M. The memo notes that for those members who have aligned their RCP certification date with that of their company’s initial TSMS Certificate issuance date, the audit transition plan shared in 2015 conflicts and is therefore no longer applicable. This memo directs those companies – who have aligned their compliance dates – to follow the five-year audit schedule from that date forward.
  2. The second memo deals with the alignment of RCP certification dates and initial TSMS Certificate issuance dates (mentioned above). The RCP Standards Board is extending the date by which companies who already have already received their initial TSMS Certificate and have had it for more than 90 days to still request alignment no later than July 1, 2019. This will allow companies who perhaps have not taken the opportunity to align their dates, and still want to, to do so.

For TVIB TPO customers that are RCP certified, please confirm that you have aligned your RCP certification date to your TSMS certificate date. If you have NOT done, please take benefit of the final extension and do so NO LATER than July 1, 2019.

After this deadline you will not be allowed to align your two certifications and will likely have duplicative audit cycles.

Click here to download both memos (we have packaged them together in a singled PDF).

USCG: CG-ENG 01-18 Equivalency Determination – Fire Pumps for Subchapter C and Subchapter M Towing Vessels

May 31, 2019 – CG – Engineering issued a new policy letter. Following are some excerpts from that letter that are specific to Subchapter M towing vessels under 65 feet long. Please click on the link below to download the full policy letter.

(1) Purpose.This policy letter provides guidance on the acceptance of fixed fire pump size requirements for towing vessels 65 ft or less to provide a level of safety that is equivalent to the requirements of reference (a) and (b), uninspected and inspected towing vessels, respectively. 

(3) Discussion. When developing references (c) and (d), the Coast Guard assumed smaller vessels would utilize portable fire pumps, while larger vessels would utilize fixed fire pumps; therefore, vessel size was not associated with fire pump requirements. This assumption imposed a larger burden on smaller vessels that opted to install fixed fire pumps. Generally, the fixed pump is required to have a higher capacity to accommodate the greater hydraulic losses expected from the extensive fire main systems used in larger vessels. In small vessels, however, the hydraulic losses of the smaller fire main systems are negligible, and the fixed fire pump need be of no higher capacity than the portable pump. Thus, in small vessels, fixed and portable pumps of similar capacity will provide similar fire streams affording an equivalent level of safety. Accordingly, for towing vessels 65 ft or less, the Coast Guard has determined a fixed pump that meets the portable pump capacity and pressure requirements meets an equivalent level of performance to the requirements in references (a) and (b). 

(4) Action.

b.   Subchapter M: For towing vessels 65 ft or less subject to 46 CFR 142.325, vessels may use a fixed pump that meets the performance requirements of 46 CFR 142.325(e)(1), instead of 46 CFR 142.325(a)(1). These towing vessels must also meet the requirements in 46 CFR 142.325 (a)(2), (b)-(d). 

Click here to download CG-ENG Policy Letter 01-19 Equivalency Determination – Fire Pumps for Subchapter C and Subchapter M Towing Vessels

USCG: Sub M – Health and Safety Plan

May 9, 2019 – the USCG sent out the following notice via the GovDelivery

This is a reminder of a key 46 CFR Subchapter M implementation milestone that is quickly approaching. On or before July 22, 2019, owners and managing operators of Subchapter M towing vessels must implement a Health and Safety Plan (HSP) and the associated recordkeeping procedures regardless of whether or not the vessel has been issued a Certificate of Inspection (COI). Requirements include general health and safety procedures, identification and mitigation of health and safety hazards, and health and safety training for crewmembers and non-crewmembers.

Towing vessels operating under a Safety Management System (SMS) may already have the elements of the HSP covered within the SMS. For towing vessels that have not incorporated the HSP elements into their SMS, and for towing vessels utilizing the Coast Guard Inspection Option, the HSP would likely be a stand-alone document.

There is no requirement to submit the HSP to the Coast Guard or TPO for approval; however, the plan is subject to review during inspections and audits. Minimum health and safety requirements can be found in 46 CFR Part 140 Subpart E.

For more Coast Guard news, visit their online newsroom here.