TVIB News Subchapter M Updates

USCG: Update to Policy Letter 17-04, “Subchapter M Third Party Organization Guidance”

02/05/2019 – Reposted from Coast Guard Maritime Commons:

The Office of Commerical Vessel Compliance issued Change 1 to Policy Letter 17-04, “Subchapter M Third Party Organization (TPO) Guidance” Jan. 31, 2019.

CG-CVC Policy Letter 17-04 is here by cancelled and superseded by Change 1. Updates are limited to the Subchapter M Third Party Organization Guidebook enclosure and include:

a. Updated multiple parts of Section 5 that address the main responsibilities of a TPO;
b. Updated Section 7 to include more information pertaining to actions a TPO auditor or surveyor should take when they identify a problem;
c. Updated Section 8 to address the validity of TSMS certificates if a TPO’s approval is voluntarily surrendered;
d. Updated Section 9 to address the process for a third party developed course to gain Coast Guard acceptance;
e. Updated Appendix 1: Third Party Organization Application Job Aid to included previously missed regulations; and
f. Added two new appendices: Appendix 2: Audit Result Submissions and Appendix 3: Aid for Processing, Recording, and Reporting Deficiencies.

Policy Letter 17-04 (Change 1) provides guidance to the Towing Vessel National Center of Expertise, Officer(s) in Charge, Marine Inspection, and the marine industry on TPO requirements as discussed in reference the Inspection of Towing Vessels Final Rule published June 20 2016. It is intended for use by the NCOE, OCMIs, and entities within the maritime industry that are or want to become TPOs.

For full details, view or download Policy Letter 17-04 (Change 1), or contact the Office of Commercial Vessel Compliance, Domestic Compliance Division at

Click here to access original post.

USCG: Commercial Vessel Safety during Lapse in Coast Guard Appropriations

MSIB 01-19, issued 1/23/2019 by CG-CVC, provides guidance to assist vessel owners, operators, and other affected parties during the lapse in appropriations. The MSIB covers the USCG’s plans for addressing the following items during the partial government shutdown:

  • COFRs – Certificates of Financial Responsibility
  • CODs – Certificates of Documentation (impacts on COIs)
  • MMCs – Merchant Mariner Credentials

EXCERPT – “In the absence of enacted appropriation or continuing resolution, the Coast Guard is required to execute an orderly suspension of some operations and activities. In general, the Coast Guard will continue operations authorized by law that provide for national security, or that protect life and property. However, certain administrative functions will be limited.”

Click here to download MSIB 01-19


SUB M: Parsonage to Speak at Int’l WorkBoat Show 11/29 – Subchapter M Has Arrived. Now What?

Come out and see TVIB at the 2018 International WorkBoat Show. Stop by and visit with our staff, auditors and surveyors.

Located in Booth 3944

Chris Parsonage, Executive Director and President of TVIB will be speaking on a panel at this year’s International WorkBoat Show next week in New Orleans. The panel, Subchapter M Has Arrived. Now What?, will be Thursday, November 29th from 11:00 am to 12:00 pm in the Think Tank, Collaboration Zone.  Chris will be joined by Kevin Gilheany of Maritime Compliance International, LLC, and David Kapf, Editor of WorkBoat magazine.

The session will focus on the Certificate of Inspection (COI), requirements, inspector checklists, what to do before, during and after an inspection and the early lessons learned from the issuance of the initial COIs.

The TVIB staff wish you a safe and happy Thanksgiving. We look forward to seeing you all next week in New Orleans.