TVIB News Subchapter M Updates

USCG: D8 Sub M Towing Vessel Inspections Field Notice

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January 24, 2018

The U.S Coast Guard Eighth District published a policy letter related to Towing Vessel Inspections Field Notice that addresses a number of items that have been deemed to pose a minimal risk to the operational safety of the towing vessel fleet. The letter provides enforcement guidance to Operational Commanders when considering deficiencies or non-conformities during the implementation of Subchapter M throughout the Eighth Coast Guard District.

Click here to download D8-TVIFN 18-1.

TRAINING: Upcoming Classes – Limited Space

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We have the following upcoming classes:

Annual Survey of Towing Vessels (ASTV) – March 13-16 – Pittsburgh, PA 

Our Annual Survey of Towing Vessels course provides surveyors with the knowledge and skills required to perform TVIB TPO Subchapter M surveys. It is designed to teach those who will be performing surveys as a part of an internal survey program, as well as those who will be performing external surveys for TVIB.

Course attendees who want the TVIB Annual Surveyor or Drydock/ISE Surveyor credential must submit an application PRIOR to attending the course.

Course Information and Registration

Subchapter M Auditor Certification – February 21-23 – Houston, TX
This course trains both internal and third party auditors how to use the TVIB audit process developed to meet ISO 19011 Guidelines for Auditing Management Systems and tailored for unique situations under Subchapter M and the RCP. It covers auditing management systems and the vessels that operate under those systems.

Course attendees who wish to receive a TVIB Auditor credential must submit an application prior to attending the course.

Course Information and Registration

Marine Internal Lead Auditor (MILA) – February 27-28 – Houston, TX – Marine Internal Lead Auditor

TVIB has partnered with ACTSafe Training in this Coast Guard recognized Marine Internal Lead Auditor course, designed to teach the specific skills and knowledge necessary to conduct and lead internal audits for commercial marine companies.

The course meets the requirements of ANSI Z 490.1 Criteria for Accepted Practices in Safety, Health and Environmental Training and the requirements of 46 CFR 138.310(d)(2). 

Course Information and Registration

See below for details and open registration on two additional courses offered following the MILA course. These two newest course offerings can be taken on their own or as an add-on to the MILA course:

  • Risk Management – March 1 – Houston, TX
    • The one day course covers Qualitative Risk Assessments (QRA), Risk Assessment vs. Risk Management, overview of the ISO 31000 Risk Management standard, best practices in JSAs and the “Risk Pyramid”. Participants will leave this course with a better understanding of what risk tools are and how to use select risk tools in a marine organization. Participants will be provided with a process to conduct Qualitative Risk Assessments and Job Safety Analysis. Principles of risk management including risk strategies will be covered.

Course Information and Registration

  • Subchapter M TSMS Objectives for Management & Designated Persons- March 2 – Houston, TX
    • This course covers: the history of Designated Person (DP), understanding the importance of TSMS purpose, design, implementation issues, DP requirements for RCP, Sub M & ISM Code, critical success factors for successful management systems, advanced view of James Reasons’ causation model, Management of Change, Hierarchy of Controls, what should generate corrective and preventive actions, effective Management Review practices for high performing organizations and more. These subjects and more are explored using case studies, videos, group discussions and practical exercises. This course is critical for managers and DPs in a regulated world.

Course Information and Registration

TVIB TALKS: Top 10 Advantages of the TSMS Option

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At the 2017 International WorkBoat Show, Chris Parsonage, TVIB President, presented on a panel discussing the TSMS option versus the U.S. Coast Guard Inspection option for Subchapter M compliance.  Following is the first in a series of posts from that presentation.

Top Ten Advantages of the TSMS Option

  1. Greater flexibility for scheduling audits and surveys to fit a companies operating schedules.
  2. Companies utilizing a TPO approved TSMS will be perceived as operating at a higher level of performance by their customers.
  3. Operators subject to the TMSA requirements or the AWO RCP are already required to have an audited TSMS regardless of compliance option selected.
    • Every Operator will eventually need a Health and Safety plan regardless of Coast Guard option or TSMS option selected.
  4. Internal Survey Option
    • The internal survey option provides the company an alternative to conduct annual compliance surveys and five-year drydock surveys and ISEs, utilizing company personnel (or contracted surveyors), versus having to use third-party surveyors.
    • Surveys can be conducted during normal maintenance operations.
    • Companies can determine in their TPO approved TSMS, how they intend to comply with vessel requirements.
  5. Properly drafted Permit to Proceed procedures will be defined by the company and should allow greater ability to continue operations when minor deficiencies occur during operations.
  6. The ability to use a Corrective Action process to correct non-conformities and deficiencies under the supervision of a TPO will allow greater flexibility to schedule repairs than might be available under Coast Guard inspections.
  7. Potential for a lower fee for each annual Coast Guard COI renewal.
    • The Coast Guard will be completing a rulemaking to align inspection and COI renewal fees to recognize the amount of work and costs related to Coast Guard inspections for towing vessels using the Coast Guard option vessels that required for the TSMS Option vessels under TPO supervision.
  8. One Coast Guard inspection in five years with the TSMS option, versus one every year with the Coast Guard option.
  9. A TSMS should create a culture of safety and continuous improvement, as opposed to a culture of compliance.
  10. The Coast Guard has given great latitude to TPOs to determine how an owner/operator can comply with Subchapter M.