The Coast Guard’s office of Commercial Vessel Compliance (CVC) has issued Change 2 (CH 2) revision to CVC-PL 18-01 Guidance On the Audit Scheme for Vessels Using a Towing Safety Management System (TSMS) Option.
TVIB, along with other TPOs, initiated focused conversations immediately after CVC-PL 18-01 CH 1 was published with CVC. We met with CVC staff in May and again with Admiral Arguin and his staff in late July to share our concerns with two key issues: (1) the random vessel audits requirement and (2) the need for an entry point to the TSMS option for new companies, or companies that change from the USCG option to the TSMS option. We want to thank the Admiral and his team for providing us this important opportunity to share our concerns; we feel that we were heard and this revision is a result of these important conversations.
PL 18-01 CH 2 addresses the regulation’s requirement for vessel audits to be conducted randomly. The Coast Guard has clarified their intent that the TPO issuing the TSMS Certificate will be the entity to develop the random vessel audit program. TPOs will be developing their own expectations for scheduling, the selection of vessels to be audited and the audit notification required. The policy letter makes it clear that this program should be “distinctly different” than an audit program with a fixed schedule. The goal to spread the audits out as evenly as possible over the 5-year period of validity of the TSMS certificate.
Two points made clear in this letter are:
- All vessels covered by the TSMS certificate must be audited at least once in the 5-year period of validity of the TSMS certificate; and
- The vessel is not required to complete an audit prior to renewing the COI
We will be working with our Audit Committee members to create the framework for TVIB’s random vessel audit program over the coming days. We will be taking into account the need to remain as flexible as possible to account for operational constraints that impact the logistics of securing an auditor and boarding the vessel at a time to create the least disruption to our TPO customer’s operation. Once the framework has been established, we will be communicating this to all of our TPO customers and auditors. Please remember that the random vessel audit program begins after an owner/operator renews their TSMS certificate, so while some companies have already begun to renew their TSMS Certificate, many still have months or even years before this will apply to them.
We will send out a secondary correspondence regarding the other topic addressed in this policy letter – Issuing initial TSMS certificates, initial COIs for vessels under a new TSMS certificate, and external audits for initial COIs under the TSMS option.