TVIB News Subchapter M Updates

Subchapter M – Are You Talking About It Yet?

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Sub M 314 Days
Sub M 314 Days

Does your organization own or operate towing vessels?  Yes, how much do you know about and understand 46 CFR Subchapter M – Towing Vessels?  We are 314 days out from the July 20, 2018 deadline for compliance.

Have you thought about how your company plans to obtain Certificates of Inspection for your vessels? Have you decided if your company will be using the TSMS option (§136.130(a)(2)) or the Coast Guard options (§136.130(a)(1)).

TSMS Option
For those choosing the TSMS option, TVIB stands ready to provide the full portfolio of services needed to demonstrate compliance with Subchapter M. We have auditors and surveyors dispersed geographically throughout the US in major ports along the different coasts and along the river systems and their tributaries.  Our pool of auditors can provide the following:

  • Audit Towing Safety Management Systems
  • Audit Towing Vessels
  • Survey Towing Vessels
    • Annual Survey
    • 5-Year Drydock/Internal Structural Examination (ISE)

Coast Guard Option
If your company is planning to use the Coast Guard option have you started conversations with your local OCMI?  Do you have a sense of their resource availability?

Certificates of Inspection (COI)
Do you have a sense of how many vessels you will apply for COI in the first year of compliance? Will you be using a UTV decal to obtain a COI in accordance with CG-CVC Policy Letter 17-01?? If so, are all of your UTV Decals valid now and will they still be valid when you apply for a COI? Do you plan to apply for COIs on more than 25 percent of your vessels in a given year as noted in CG-CVC Policy Letter 17-03? Have you talked with the local OCMI about their process for applying for a COI?

Relationships
Relationships will be critical to a smooth and successful implementation of Subchapter M in your organization.  If you haven’t started conversations with your TPO or the local OCMI yet, it’s time to get the ball rolling.  Find out now whether or not your TPO has the resources to service your operation. Talk to the local OCMI in the port where you operate vessels to find out what the resources and processes for obtaining COIs will be. Find out how far in advance of July 20, 2018 you can apply for a COI. Find out if it’s possible to obtain a COI on a vessel before the implementation date.  If you have vessels that meet the definition of workboats operating within a worksite (§136.105(a)(3)) talk with your OCMI about requesting a worksite designation. What will you do with vessels that are not operating, up for sale, or may be “moth balled” or “cold stacked.”

Have you started forecasting out your TSMS audit and vessel audits and surveys? Remember to look beyond the initial issuance of the COI and look forward to five years from that date at the renewal.  While the boat business may be slow today and your vessels seem easy to get to, will those same conditions be present in five years? We certainly hope not, but be sure to look beyond today and forecast out for the budgeting and logistics of scheduling external vessel audits and surveys.

Let us help you navigate Subchapter M.  We are here as industry partners to serve your needs.

TVIB – THE TPO YOU KNOW AND TRUST

USCG: Sub M FAQs Updated

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08/21/2017

The USCG Towing Vessel National Center of Expertise (TVNCOE) recently updated the FAQs (Frequently Asked Questions).

Click here to link directly to the TVNCOEs FAQ page.

SNAME MT – Flexibility and Complexity – Subchapter M Strategy for Compliance

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Flexibility and Complexity: Operators Need to Select their Subchapter M Strategy for Compliance
written by Chris Parsonage, published in the July 2017 edition of SNAME MT (The Society of Naval Architects and Marine Engineers – Marine Technology) Magazine

Excerpt 

“…path that the USCG has suggested will be best for many operators and the key to successful implementation of Subchapter M—the towing safety management system (TSMS) option. Under the TSMS, operators develop a comprehensive set of policies and procedures that cover all relevant aspects of managing their towing vessels. Instead of working solely with the USCG, operators select a third-party organization (TPO) to conduct periodic audits and surveys to verify the company is in compliance with the policies and procedures outlined in their TSMS and Subchapter M. Instead of annual USCG inspections, operators choosing the TSMS option and successfully operating under their TSMS will potentially have much less USCG involvement in their operations and on their vessels.

Companies that have been operating under a recognized existing TSMS, such as the AWO Responsible Carrier Program or the ISM code, are generally well prepared to comply with Subchapter M, particularly if they choose the TSMS option. They should expect to find their TSMSs might only need a few, if any, additional elements to be implemented before their TPO can verify their systems meet the Subchapter M requirements. Therefore, the gap for these operators will be significantly less than those starting from scratch. Those operators that do not currently have a TSMS in place, or have not begun the process to write a Subchapter M-compliant TSMS, have a steep hill to climb if they want to take advantage of the TSMS option by July 2018.”

“…there is a great deal of f lexibility written into Subchapter M for those who do choose the TSMS route. Generally speaking, operators are able to write their TSMS so that it fits their unique operation. One example of this flexibility is in the survey program option. Subchapter M provides operators selecting the TSMS option flexibility in choosing how to conduct the survey elements of their TSMS. Operators can choose to have their annual surveys and less frequent drydock and internal structural examinations “ISE,” either conducted by an independent third-party surveyor from a TPO, or they can develop their own internal survey program. Operators choosing the internal survey program can use a qualified company employee or hire an outside contractor with proper experience and training to conduct their annual vessel surveys and/or their drydock and ISE. The TPO will work with the operator to supervise the internal survey program.”

Click here to download the full article.