TVIB News Subchapter M Updates

USCG: CG-CVC Policy Letter 20-01 Subchapter M Enforcement Posture for Certificate of Inspection (COI) Phase-In Requirements

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Excerpt from Coast Guard Maritime Commons – originally posted 02/21/2020

The Office of Commercial Vessel Compliance announced the publication of CG-CVC Policy Letter 20-01, “Subchapter M Enforcement Posture for Certificate of Inspection (COI) Phase-In Requirements,” dated February 20, 2020.  

This policy letter provides guidance regarding the enforcement posture for towing vessels’ COI phase-in requirements within 46 CFR §136.202. As of July 20, 2018, towing vessels subject to inspection under 46 CFR Subchapter M must be in compliance with the requirements of the subchapter, even if the vessel has not yet received a Coast Guard-issued COI. With each subsequent scheduled phase-in date, regardless of inspection option chosen, companies with vessels selected in accordance with this policy that have not been issued a COI in accordance with the regulations, will be issued a Coast Guard Form CG-835V, for non-compliance.  

Read the policy letter for full details.

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

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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: Guidance on Overspeed Protection and Testing of Electronically-Controlled Engines

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On 12/30/2019 the USCG issued a work instruction outlining enforcement guidance related to the verification and testing of overspeed protection by the USCG.

Excerpt from CVC-WI-011(1)

D.Enforcement Guidance.

a.Coast Guard Marine Inspectors should continue to verify mechanical engine overspeed deviceoperation as specified per reference (d) Section B, Chapter 1.

b.Verification of the electronic overspeed protection device should be conducted not less thanonce every five years. This test should be conducted in accordance with the manufacturer’stest procedures. Completion of verification shall be recorded in the MISLE narrative.

Click here to download CVC WI-011(1) Guidance on Overspeed Protection and Testing of Electronically-Controlled Engines