TVIB News Subchapter M Updates


If your company has obtained COIs since the implementation of Subchapter M then you have two issues to consider upon the one-year anniversary mark:

  • Vessel Inspection Fees; and
  • Annual Surveys Deadlines for TSMS Options Vessels

Vessel Inspection Fees:

Coast Guard Vessel Inspection Fees are covered in 46 CFR 2.10 — Table 2.10-101—Annual Vessel Inspection Fees for U.S. and Foreign Vessels Requiring a Certificate of Inspection. 

  • These fees begin on the first anniversary of the issuance of the COI;
  • They will be due annually thereafter;
  • These fees apply to both Coast Guard option vessels and TSMS option vessels; and
  • AWO and others have been working with the Coast Guard in an effort address the issue to reduce the fees for TSMS option vessels. This effort is ongoing.

Annual Survey Deadlines for TSMS Option Vessels

External Survey Program

  • 46 CFR Subchapter M 137.205(a)(3) Ensure the survey is conducted within 3 months of the anniversary date of the COI.
  • This allows for the annual survey to occur up to 90-days before or after the anniversary date of the COI.

Internal Survey Program

  • 46 CFR Subchapter M 137.210(b) (b) The owner or managing operator is not required to survey the items as described in §137.220 as one event, but may survey items on a schedule over time, provided that the interval between successive surveys of any item does not exceed 1 year, unless otherwise prescribed.
  • The regulations are silent on the specific deadlines for companies that complete the survey as a single annual event under the internal survey program option. 
  • The premise of the internal survey program is that it must provide for equivalent practices as would be found under the external survey program.
  • 12/31/2019 UPDATE – removed language related to “unless otherwise prescribed” as it relates to TVIBs interpretation of timing for annual surveys performed under an internal survey program, see TVIBs blog post of 12/31/2019 related to same.

TVIB: Training Opportunity – FINAL OFFERING of 2019 Annual Survey of Towing Vessels (ASTV) Course


The ASTV Course is a requirement, if you are seeking TVIB Certification to become a Subchapter M Surveyor for conducting TVIB Third Party Organization annual surveys of towing vessels.

Are you performing surveys as part of an internal survey program? This course is ideal for you as well.

Since the inception of the training, TVIB has hosted more than 30 USCG personnel, including investigators and inspectors from across various sectors. 

The combination of students from both industry and the USCG has proven to be an invaluable mix for the course, resulting in dynamic and informative discussion and insights.

There are a limited number of seats available for the final course for the year.

DATES:October 8-11, 2019
TIME:8:00 am – 5:00 pm
LOCATION:15201 East Freeway, Ste.  214A, Channelview, TX 77530
ACTSafe Training Room

Contact us today to reserve your seat. Click the image below for course information and registration.

If you have any issues registering or have any further questions, please feel free to contact Cindy Hunsaker at

UPDATE – USCG: NVIC 01-16 CH2 – Use of Electronic Charts and Publications in Lieu of Paper Charts, Maps and Publications

UPDATE 09/23/2019Click here to download the advance copy of NVIC 01-16 Change 2 – Use of Electronic Charts and Publications in Lieu of Paper Charts, Maps and Publications.

Federal Register Notice – Vol. 84, No. 183 – 09/20/2019


SUMMARYThe Coast Guard announces the availability of Navigation and Vessel Inspection Circular (NVIC) 01–16 Change 2 together with a Deregulatory Savings Analysis. This NVIC provides that U.S. vessels may access navigation publications electronically, through underway connectivity, to meet domestic carriage and Safety of Life at Sea certification requirements.

DATESComments and related material must be received by the Coast Guard on or before November 4, 2019.

ADDRESSESYou may submit comments identified by docket number USCG– 2019–0346 using the Federal eRulemaking Portal at https:// See the ‘‘Public Participation and Request for Comments’’ portion of the

Click her to download the Federal Register notice.