TVIB News Subchapter M Updates

AWO: RCP Revisions Effective 01/01/2021

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On 01/26/2021, the American Waterways Operations (AWO) published the revised Responsible Carrier Program (RCP) that incorporates the RCP Standards Board recommendations and board approved changes designed to make it easier for their members to meet the membership requirement to maintain third party audited compliance with a safety management system (SMS). Following are a few of the key areas of change:

  • Members may use any SMS that meets the minimum requirements of 46 CFR Part 138 to meet AWO’s SMS membership requirement and secure certification as a Responsible Carrier.
  • Companies using the TSMS option for Subchapter M compliance can simply supply AWO with a copy of their TSMS Certificate to demonstrate compliance.
  • Companies using the RCP as their SMS will benefit from the removal of unduly constraining RCP deadlines for provisional audits and the revision of internal audit and corrective action plan due dates.

The staff will be reviewing the changes and working with our leadership in the coming days to determine what, if any, impacts there are to TVIB processes for our TPO TSMS option customers currently using the RCP for compliance with 46 CFR Subchapter M as well as for those customers that have elected the USCG option and are AWO members that must maintain compliance with the RCP to meet AWO membership requirements.

Click the following hyperlinks to download the revised RCP standard with the changes that became effective 01/01/2021, along with the Frequently Asked Questions (FAQs) published by the AWO.

Additional information about the RCP may be found on the AWO RCP webpage.

TRAINING UPDATE: 2021 Training Calendar Finalized

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We have finalized the training calendar through June 2021.  Due to the continued issues related to the COVID-19 pandemic, we will continue to offer our courses in a virtual format through the first half of the year.  As we move into the second quarter, we will assess the situation and finalize the delivery method (classroom or virtual) and dates for the second half of 2021. Each of the course headings will link you directly to the course description and registration links.  Virtual courses are limited in size and registration will be on a first-come, first-served basis.

Drydock/Internal Structural Examination Certification Course (DD/ISE)

  • February 9-11; virtual
  • May 4-6; virtual
  • August – TBD; classroom or virtual
  • November – TBD; classroom or virtual

Annual Survey of Towing Vessels (ASTV)

  • March 9-11; virtual
  • September – TBD; classroom or virtual

Subchapter M Auditor Certification Course

  • April 13-14; virtual
  • October – TBD; classroom or virtual

Marine Internal Lead Auditor (MILA) – taught by ACTSafe Training

  • TENTATIVE – April; virtual
  • TENTATIVE – October; classroom or virtual

Stayed tuned for exciting news on three new course offerings this year:

  • TSMS Writing for DD/ISE
  • Subchapter M 101 for Management
  • Corrective Action Plans/Process

USCG: Drydock Examinations (DE), Underwater Survey in Lieu of Drydocking (UWILD) and Drydock Extension (DDE) Policy Clarifications CVC-WI-029(1)

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Published 01/08/2021

This work instruction (CVC-WI-029(1)) provides guidance to District Prevention Staffs (dp), Officers in Charge, Marine Inspection (OCMIs), and the Towing Vessel National Center of Expertise (NCOE) concerning matters relating to drydock exams (DEs), underwater surveys in lieu of drydocking (UWILD), and drydock extensions (DDEs) for all inspected vessels, including vessel inspected under 46 CFR Subchapter M.

Click here to download USCG: Drydock Examinations (DE), Underwater Survey in Lieu of Drydocking (UWILD) and Drydock Extension (DDE) Policy Clarifications CVC-WI-029(1)