TVIB News Subchapter M Updates

USCG: REVISIONS to NVIC 01-89 Change 1 Underwater Survey Guidance – UWILD Considerations

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Review of the Updated UWILD Policy

The updated UWILD policy has no direct impact on the brown water fleet. It emphasizes the importance of visibility during underwater surveys conducted by divers or remotely operated vehicles (ROVs).

Brown water operations—typically conducted in inland and coastal waterways such as rivers, canals, and bays—often involve confined waters and limited visibility. These conditions make it difficult to meet the policy’s visibility requirements, which state:

  • Water clarity must be sufficient for the diver or ROV to view the full height of the propeller and rudder in a single frame.

If this level of clarity cannot be achieved, operators must consider alternatives such as relocating the vessel, waiting for improved conditions, or drydocking.

Other key updates:

  • Expanded Eligibility:Vessels over 15 years old may qualify for UWILD with certain conditions and CG-CVC endorsement.
  • Third-Party Oversight:Unclassed ITVs operating under a TSMS can use their TPO to verify UWILDs without mandatory Coast Guard presence. Simplified documentation applies, and both the TPO and OCMI must be notified.
  • Harmonization:DD/ISE dates may now align with Load Line (LL) inspections for unclassed vessels.
  • Technology Use:ROVs equipped with advanced cameras and lighting may improve visibility in marginal conditions.

All other UWILD policy requirements remain unchanged.

TVIB FAQ – General Alarm Requirements – Subchapter M

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Where should audible and visual general alarm devices be positioned onboard Subchapter M towing vessels? 

We’ve published a new FAQ that explores the general alarm requirements under 46 CFR 143.235 and offers clear guidance on proper placement of alarms and supplemental flashing red lights. This resource includes helpful regulatory text and practical considerations for auditors, surveyors, and vessel operators. 

Take a few minutes to review the full FAQ to ensure your vessels meet all compliance expectations. 

Find Detailed Guidance in Our FAQ
For comprehensive answers and guidance visit the FAQ section on our website: TVIB FAQ. Use the search function with the term “general alarm” or navigate to 46 CFR Part 143 for relevant details. 

USCG: WI Update to Towing Vessel COI Inspections Under TSMS Option

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On November 6, 2023, CVC published revision (7) to CVC-WI-013. The revision is substantial, so we are highlighting some of the major changes for you. We strongly encourage all owners, managing operators, compliance personnel, auditors and surveyors for towing vessels to read this work instruction as it is the most comprehensive source of Coast Guard policy guidance for Subchapter M towing vessels. Changes include:

  • A new “reduced risk-based inspection and certification” program for TSMS option vessels, which allows an owner or managing operator the opportunity to request a reduced scope of the inspection for COI renewal to just essential systems. The O/MO may request a reduced risk inspection at the time of COI renewal if:
    • An O/MO provides objective evidence that a full TSMS survey was conducted that year;
    • The TPO provides objective evidence that the vessel has no major non-conformities in the last 5 years; and
    • The vessel has not been issued any code 30 deficiencies by the Coast Guard in the last 5 years.
  • Providing guidance for O/MO who wish to renew their COIs early, and when the Coast Guard should maintain the same COI month and day on the renewal COI, versus resetting the COI anniversary date.
  • Incorporating the information from Coast Guard Policy Letter 17-02 and Coast Guard Policy Letter 18-01 into WI-013, and subsequently cancelling both policy letters.
  • Clarifying the definition of “initial COI” as it relates to vessels that change inspection program options.
  • Clarifying expectations for a wide variety of situations that may call for inspection program changes, including vessels changing from CG option to TSMS option, or vice versa, vessels moving between TPOs, vessels being bought/sold, etc.

Click here to view and download the full work instruction.