TVIB News News and Updates

TVIB Staff News

We recently expanded our staff by adding an additional Operations Manager. We would like to welcome Clint Smith to the TVIB team. Clint will be working alongside Caleb King, focusing on the coordination of audits and surveys while working to support our TPO customers with CG-835V/Marine Casualty concerns and related TPO activities. 

Clint retired from the U.S. Coast Guard as a Lieutenant Commander in 2019. During his 20+ year Coast Guard career, he served in a wide variety of positions, including Deck Watch Officer and Coast Guard Boarding Officer, onboard several Coast Guard cutters engaged in search and rescue, law enforcement, and aids to navigation. 

He spent 14 years in the Marine Safety field as an Investigating Officer and Marine Inspector and held positions in the Gulf and Western Rivers Regions. As a Marine Safety Detachment Supervisor, he oversaw Coast Guard Marine Safety and Security Regulatory Compliance for all vessels and facilities in two states. As the Chief of Prevention, he managed both U. S. and foreign vessel inspections and regulatory compliance for 144 facilities in one of the Nation’s busiest ports. He’s conducted hundreds of safety and security inspections on U.S. and Foreign vessels, pollution investigations, marine casualty investigations, and container inspections. Clint’s most recent assignment was at Coast Guard Headquarters with the Mission Management Systems Staff, where he managed and audited the Coast Guard’s Prevention Quality Management System. Clint formed QCI Maritime Services in 2019 and performed surveying, auditing and consulting services to the towing industry. 

Clint holds a Bachelor of Arts in Communications and Information Sciences from The University of Alabama. He is certified by Exemplar Global as an ISO-9001 Quality Management System Lead Auditor and holds certifications as both a TVIB Lead Auditor for Vessels and Management and Subchapter M Annual Surveyor.     

Clint is located in Gonzales, LA. Please be sure to welcome him when you get a chance, you will find his contact info on the website under Contact Us and Our Staff.

USCG: CVC-WI-013(4) Towing Vessel COI Inspections Under TSMS Option

On 12/31/2019, we communicated with you the successful result of our appeal that resulted in the allowance of 90-days before and 90-days after the COI issue date for annual surveys performed under a company’s internal survey program. The USCG first communicated this revised interpretation in the TPO Guidebook (CVC-Policy Letter 17-04 change 2 on 12/31/2019).

Today the USCG issued change 4 to CVC-WI-013 Towing Vessel COI Inspections Under TSMS Option (dated 12/31/2019) that further confirms this position as a work instruction for use by USCG Marine Inspectors. You can find this revision on page two, item D 1 a. i. We have not completed an exhaustive review of the document yet to determine if there are additional changes but we’re proud to have been the leader on this issue with the USCG which resulted in a positive outcome for all companies that have elected to use an internal survey program under the TSMS option.

Click here to download CVC-WI-013(4) Towing Vessel COI Inspections Under TSMS Option

USCG: Sector Ohio Valley Issues MSIB 01-2020 Related to Non-Compliance with NTVRP Requirements

We’ve recently encountered issues with operators that have vessels that have been measured to both the “Regulatory” tonnage (GRT) and “Convention (International)” tonnage (ITC) that were surprised during COI inspections that the USCG was holding them to the ITC with regard to compliance with the Non-Tank Vessel Response Plan requirements.

Sector Ohio Valley has issued MSIB 01-2020 clarifying their position on the matter stating:

Vessels that actively operate in commercial operations without a NTVRP are subjected to, but not limited to, the following penalties; vessel detainment by the United States Coast Guard (USCG), denial of entry into a U.S. port, and/or civil penalties of more that $47,000 per day dependent upon type and scope of violation. The USCG encourages the maritime community to review the requirements and ensure their vessels meet the regulations outlined in 33 CFR Part 155 – Subpart J.

A point of confusion has arisen in terms of tonnage application for the 400 gross tons threshold. As discussed in the preamble of the regulation (Federal Register / Vol. 78, No. 189 / Monday, September 30, 2013 / Rules and Regulations), if a vessel is measured using “Convention (International)” tonnage and “Regulatory” tonnage, the greater of the two is used for determining applicability of the NTVRP requirements.

Have you looked at your CODs lately?

Click here to download Sector Ohio Valley MSIB 01-2020 Non-Compliance Trend with Non-Tank Vessel Response Plan Requirements