PREFERRED:  Company to identify testing frequency within TSMS. During the annual survey the surveyor visually inspects system components and has a crew member perform a function test with the vessel safely secured at a dock, fleet, or mooring.

ALTERNATIVE:  During annual survey the surveyor visually inspects system components.  If vessel is underway and not able to secure at a dock, fleet, or mooring, a function test WILL NOT be performed.  If documentation can be provided showing fuel shutoff valves have been tested as indicated in the TSMS, the surveyor can accept this as objective evidence of successful function testing.  If there is no documentation of testing IAW the companies TSMS the surveyor will issue a finding that successful function testing was not able to be performed due to operating conditions and that there was no current documentation of testing as required by the TSMS. The anticipated corrective action plan from the vessel operator would be to have system function tested within 30 days and documentation of same provided to TVIB as objective evidence.

In either case, if the visual inspection of the Fuel Shutoff valves reveals a deficient condition, a finding will be issued and may affect the vessel’s ability to operate until a successful function test is completed to the satisfaction of the attending surveyor.

IN ALL CASES:  A non-operational Fuel shutoff valve is a major non-conformity, which requires notification to TVIB within 24 hours (real-time is preferred).

NOTE: A valve is a device not a system. The operation of the valve does not act to suppress the fire. §142.240(a) specifically references “machinery shutdowns”, which requires testing every 12 months. TSMS testing frequency should identify testing frequency IAW either of the below associated references:

ASSOCIATED REFERENCES:

• §142.240 (a): All portable fire extinguishers, semi-portable fire-extinguishing systems, fire-detection systems, and fixed fire-extinguishing systems, including ventilation, machinery shutdowns, and fixed fire-extinguishing system pressure-operated dampers on board the vessel, must be inspected or tested at least once every 12 months, or more frequently if otherwise required by the TSMS applicable to the vessel.
• Table 46 CFR 143.245 (b): identifies “All other essential systems” as having a testing frequency of at least once every 3 months.
• §136.110 includes systems for suppression of fire as an essential system.

QUESTION: What inspections are required for an electric water heater on a towing vessel?

RESPONSE:  To answer this question, first you must identify some characteristics of the electric water heater.

46 CFR 136.110 defines a pressure vessel as “… a closed tank or cylinder containing gas, vapor, or liquid, or a combination thereof, under pressure greater than atmospheric pressure.”

An electric water heater is a closed tank that contains liquid and is under pressure greater than atmospheric pressure.

The following italicized text contains excerpts from the regulatory citations and not the language in its entirety.

§ 143.300 further defines requirements for pressure vessels as those that are greater than or equal to 37.4 gallons and over 15 pounds per square inch.  Under this set of requirements, there are some that are applicable to an electric water heater:

 (a) be equipped with a spring loaded relief valve that prevents pressure from exceeding the MAWP by more than 10 percent.

 (b) be externally examined annually and relief valve tested in accordance with § 143.245 (i.e., twice every 5 years with no more than 3 years between testing)

 (c) be marked with MAWP

 (d) if installed after July 20, 2018, must meet ABS rules (see § 143.540)

Since the water heater will operate at the pressure of the potable water system, the gauge requirement of § 143.300(a) is more commonly applied by having a pressure gauge on the output side of the potable water pump or thereafter in the piping system.

While not applicable to Subchapter M vessels, one can look at Subchapter T (46 CFR 182.320) and Subchapter K (§ 119.320) for similar regulatory guidance. Those regulations put specifications that apply to a water heater that is UL listed, under 120 gallons, and heat input is less than 200,000 BTU per hour.

Additionally, the water heater manufacturer likely provides documentation to guide the owner on maintenance. A quick web search of some major water heater manufacturers identified that at least annually the temperature pressure relief valve should be tested, and one was found to call for the relief valve to be reinspected once every three years and replaced if necessary. The vessel owner/operator should consult the manufacturer’s documentation for the make/model installed on the vessel.

QUESTION: When do I need to alert TVIB that my vessel is going into drydock for repairs?

RESPONSE:

You need to alert TVIB when your vessel is going into drydock for the following:

• Any Credit Drydock
• Non-credit drydock that involves the following:
• Any repair to a fuel tank;
• A repair that crosses two or more frames; or
• Steel replacement of greater than 324 square inches.

If you have any questions please call 832-323-3992 during normal business hours or click here to send an email and the appropriate staff member will get back to you.

If you require assistance after hours please call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:

• URGENT: immediate assistance is needed, regardless of the time of day; or
• NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document.

QUESTION: What do I do if I miss my annual survey window?

RESPONSE:

As soon as you realize you have missed the window for the annual survey you should do the following:

• Notify TVIB by contacting an Operations Coordinator by phone at 832-323-3992 or click here to send an email; and
• Notify the local OCMI as the COI was issued under the TSMS option and the vessel must comply with all elements for the COI to remain valid.
  • It is important to advise the local OCMI that the TPO was notified of the deficiency and there is a plan in place to have the survey conducted.

The annual survey must note this failure to comply as a deficiency that must be addressed in the Corrective Action Plan (CAP).

The CAP for this item should detail HOW the company will ensure this does not happen in the future. It is NOT sufficient to state “the annual survey was completed” as this does not address the initial failure to comply and provide a plan to prevent a recurrence on this vessel or any others in the fleet.

See the FAQ related to calculating the window for conducting an annual survey for additional information.

QUESTION: Does TVIBs External Vessel Audit Program satisfy the requirement for all vessels to be randomly audited during the 5-year period of validity of the TSMS certificate?

RESPONSE:

Yes.  TVIB published the External Vessel Audits policy to meet the elements laid out in CG-CVC Policy Letter 18-01 CH.2 which clarifies the requirement for random vessel audits as noted in 46 CFR 138.315(b)(3). TVIB staff worked with the Audit Committed to develop the External Vessel Audits policy that takes into consideration the logistical issues related to scheduling random external vessel audits across a company’s entire fleet during the 5-year period of validity of the TSMS certificate.

Click here to access the TVIB Member Portal where you can log in and download the External Vessel Audits policy. Once you log in click on the drop-down menu in the upper right-hand corner and select Policies and Member Communications to locate the policy.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials please click here to send an email to request them.

QUESTION: If a company has more than one office, is there a requirement that defines which location must be audited as a part of an external management audit?

RESPONSE:  There are no requirements in Subchapter M that specify an external management audit must occur in a specific location or in multiple locations if a company has more than one office.

There is language in the AWOs RCP related to “managing office” which can be found in the table under RCP-II-G- 2.

QUESTION:
For an item that was corrected during the audit/survey and marked as such on the report, is a response required by the operator on the CAP?

RESPONSE:
The answer is no, provided that the following elements are satisfactory:

• The finding statement clearly articulates how the item was corrected; and
• The finding is NOT one of the following:
  • Major Non-conformity*
  • Unsafe Condition*
  • Repeat Finding**

* A major non-conformity or unsafe condition has mandatory reporting requirements, please reference the TVIB Notifications document for specifics.

** Repeat findings may indicate a failure of the TSMS.

If you have any questions please call 832-323-3992 or click here to send an email.

Q: What is a Third Party Organization (TPO)?

A: A Third Party Organization (TPO) is an independent entity authorized by the U.S. Coast Guard to conduct certain inspection, audit, and compliance functions on behalf of vessel owners and operators. Under 46 CFR Subchapter M, which governs the safety of towing vessels, a TPO may be engaged by a company to:

· Perform management system audits of a Towing Safety Management System (TSMS) under 46 CFR 138.315.

· Conduct vessel surveys to verify compliance with applicable Subchapter M requirements.

· Provide objective reports and recommendations to the Coast Guard regarding compliance.

Working with a TPO allows operators to choose the TSMS option for compliance rather than relying solely on Coast Guard inspections (the Coast Guard option). TPOs provide flexibility, technical expertise, and a collaborative approach to maintaining safe and compliant vessel operations.

QUESTION: What are the minimum requirements to become a surveyor?

RESPONSE:  

46 CFR 139.130(c) Surveyors must meet the following qualifications:

• (1) High school diploma or equivalent.
• (2) At least one of the following:
  • (i) Four years of experience working on towing vessels as master, mate (pilot), or engineer; or
  • (ii) Other relevant marine experience such as Coast Guard marine inspector, military personnel with relevant maritime experience, marine surveyor, accredited marine surveyor, experience on vessels of similar operating and physical characteristics.

TVIB has two surveyor endorsements: (1) Annual Surveyor of Towing Vessels and (2) Drydock/Internal Structural Examinations. Additionally, we have a program to become an internal surveyor, for employees of our TPO Customers.

TVIBs requirements and the full process to become a TVIB-Certified Surveyor are documented in the Auditor/Surveyor Membership Application. If you have any questions, please call 832-323-3992 or click here to send an email.

QUESTION: What are the minimum requirements to become an external auditor?

RESPONSE:

46 CFR 139.130(b) Auditors must meet the following qualifications:

• High school diploma or equivalent.
• Four years of working on towing vessels or other relevant marine experience such as Coast Guard marine inspector, licensed mariner, military personnel with relevant maritime experience, or marine surveyor.
• Successful completion of an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) (incorporated by reference, see § 136.112 of this subchapter) lead auditor/assessor course or Coast Guard recognized equivalent.
• Successful completion of a training course for the auditing of a TSMS.
• Audit experience, as demonstrated by:
  • Documented experience in auditing the ISM Code or the American Waterways Operators Responsible Carrier Program, consisting of at least two management audits and six vessel audits within the past 5 years; or
  • Successful completion of an auditor apprenticeship, consisting of at least one management audit and three vessel audits under the direction of a lead auditor.

TVIBs requirements and the full process to become a TVIB-Certified Auditor are documented in the Auditor/Surveyor Membership Application. If you have any questions, please call 832-323-3992 or click here to send an email.

QUESTION: Are potable water tanks required to have protection such as a screen on the vents for safety or to prevent bugs from getting in?

RESPONSE: Yes. Vent screens are one of the measures that might be used to prevent contamination of potable water.

46 CFR 140.510(b) – As far as practicable, the owner or managing operator must implement other types of safety control measures before relying on Personal Protective Equipment. These controls may include administrative, engineering, source modification, substitution, process change or controls, isolation, ventilation, or other controls.

Further, the regulations also state:

21 CFR 1250.82(c) – Each potable water tank shall be provided with a means of drainage and, if it is equipped with a manhole, overflow, vent, or a device for measuring depth of water, provision shall be made to prevent entrance into the tank of any contaminating substance. No deck or sanitary drain or pipe carrying any nonpotable water or liquid shall be permitted to pass through the tank.

QUESTION: What do I do if my vessel is involved in a marine casualty?

RESPONSE:

Refer to 46 CFR 4.05-1 to determine if the incident is considered a Reportable Marine Casualty. If it is a Reportable Marine Casualty then you must comply with all reporting requirements as noted in the CFR and incorporated by reference in 46 CFR 140.900 which begins with notification to the local OCMI.

Once the Coast Guard has been notified according to 46 CFR 4.05-1 you may receive a CG-835V.  If the 835V is issued with an action code of “A” please follow these steps to properly report the incident TVIB:

• Call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:
  • URGENT: immediate assistance is needed, regardless of the time of day; or
  • NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.
• Email the 835V to TVIB. Click here to submit the 835V via email.

The OCMI retains the sole authority to close out a CG-835V.

Incidents that are not considered a Reportable Marine Casualty according to 46 CFR 4.05-1 may be reviewed by the auditor during the course of the next management audit.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document. If you have any questions about this process you may call 832-323-3992 or click here to send an email and a staff member will get back to you.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials o click here to send an email to request them.

QUESTION: During a recent annual survey the lifebuoy was in overall good condition, the reflective tape was good, and it was marked in block capital letters with the vessel’s name. However, the identification label was worn off and I was unable to confirm if the lifebuoy was USCG-approved. Does this lifebuoy need to be replaced?

RESPONSE:

Yes. 46 CFR 141.360(b)(1) states that each lifebuoy “Be approved under approval series 160.050 or 160.150.”  If the labeling on the lifebuoy is unreadable and/or missing, and you are unable to verify the series of the lifebuoy it should be replaced.

Fixed fire-extinguishing carriage requirements are discussed in 46 CFR 142.315, but one must step through a few other citations to identify the signage requirements for a CO₂ fixed fire-extinguishing system.

The term “Fixed fire-extinguishing system” is defined in §136.110 which includes a carbon dioxide system meeting requirements of 46 CFR subpart 76.15 and 46 CFR 78.47-9 and 78.47-11.  These citations are where you find the signage requirements.

Controls [§76.15-10(h)]

Complete, but simple operating instructions to be posted at or near all pull boxes, stop valves, and cylinder storage room.

System Schematic Diagram [§76.15-10(h)]

If cylinder storage is not within the space to be protected, the controls instructions must include a schematic diagram of the system and instructions detailing alternate methods of discharging the system should the manual release or stop valve controls fail to operate.

Control Valve to Branch Lines [§76.15-10(h)]

Each must be marked to indicate the related space served.

Carbon Dioxide Alarms [§78.47-9]

Each alarm must be conspicuously marked: “WHEN ALARM SOUNDS VACATE AT ONCE. CARBON DIOXIDE OR CLEAN AGENT BEING RELEASED.”.

Spaces Storing CO₂ Cylinders [§78.47-11(a)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. VENTILATE THE AREA BEFORE ENTERING. A HIGH CONCENTRATION CAN OCCUR IN THIS AREA AND CAN CAUSE SUFFOCATION.”.

Spaces Protected by CO₂ [§78.47-11(b)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. WHEN ALARM OPERATES OR WINTERGREEN SCENT IS DETECTED, DO NOT ENTER UNTIL VENTILATED. LOCK OUT SYSTEM WHEN SERVICING.”.  *

Spaces Into Which CO₂ Might Migrate [§78.47-11(c)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. DISCHARGE INTO NEARBY SPACE CAN COLLECT HERE. WHEN ALARM OPERATES OR WINTERGREEN SCENT IS DETECTED VACATE IMMEDIATELY.”.  *

* Wintergreen Scent Note [§76.15-60]

Each carbon dioxide extinguishing system installed or altered after July 2013, must have an approved odorizing unit to produce the scent of wintergreen, the detection of which will serve as an indication that carbon dioxide gas is present in a protected area and any other area into which the carbon dioxide may migrate.  “Altered” means modified or refurbished beyond the maintenance required by the manufacturer’s design, installation, operation and maintenance manual.  If the system does not include wintergreen odorizing unit, the reference to wintergreen scent may be omitted from signage.

Portable fuel containers are commonly found on towing vessels.  They are routinely used for fueling auxiliary equipment such as dewatering pumps, fire pumps, and auxiliary boats.

Subchapter M § 142.225 discusses the storage of flammable or combustible products, but there are other considerations in Part 147 of Subchapter N, which is probably the best place to start evaluating the question above.

Subchapter N:  46 CFR §147.1(b) – Applicability for Part 147 (Hazardous Ships’ Stores) indicates “This part applies to all vessels listed in 46 U.S.C. 3301…”.  The U.S.C. 3301 includes “(15) towing vessels”.  So, we know it is appropriate and acceptable to apply the requirements of § 147.45 (Flammable and combustible liquids) to a Subchapter M towing vessel.

46 CFR §147.45(f) specifies that fuel may be stored in a portable safety container meeting UL 30, UL 1313, or UL 1314.  Standard plastic consumer-use fuel containers are not allowed.

You may store portable safety container(s) in any of the three locations:

• A storage cabinet meeting UL 1275 or FM 6050; and
• A storage room (i.e., paint locker) that is free of ignition sources; and
• An open location designated by the master (see § 147.45(g))

ADDITIONAL CONSIDERATIONS:

• A location designated by the master should be identifiable through signage, TSMS reference(s), and crew knowledge.  It is also advisable to ensure the designated storage location adequately secures the portable safety containers from movement due to vessel maneuvers and environmental conditions.
• Refilling portable safety containers onboard the vessel requires a drip pan of adequate size and that a 10-B:C (former B-I) fire extinguisher be within 9.75 feet of the refilling location (see § 147.45(i)).

PREFERRED:  Company to identify testing frequency within TSMS. During the annual survey the surveyor visually inspects system components and has a crew member perform a function test with the vessel safely secured at a dock, fleet, or mooring.

ALTERNATIVE:  During annual survey the surveyor visually inspects system components.  If vessel is underway and not able to secure at a dock, fleet, or mooring, a function test WILL NOT be performed.  If documentation can be provided showing fuel shutoff valves have been tested as indicated in the TSMS, the surveyor can accept this as objective evidence of successful function testing.  If there is no documentation of testing IAW the companies TSMS the surveyor will issue a finding that successful function testing was not able to be performed due to operating conditions and that there was no current documentation of testing as required by the TSMS. The anticipated corrective action plan from the vessel operator would be to have system function tested within 30 days and documentation of same provided to TVIB as objective evidence.

In either case, if the visual inspection of the Fuel Shutoff valves reveals a deficient condition, a finding will be issued and may affect the vessel’s ability to operate until a successful function test is completed to the satisfaction of the attending surveyor.

IN ALL CASES:  A non-operational Fuel shutoff valve is a major non-conformity, which requires notification to TVIB within 24 hours (real-time is preferred).

NOTE: A valve is a device not a system. The operation of the valve does not act to suppress the fire. §142.240(a) specifically references “machinery shutdowns”, which requires testing every 12 months. TSMS testing frequency should identify testing frequency IAW either of the below associated references:

ASSOCIATED REFERENCES:

• §142.240 (a): All portable fire extinguishers, semi-portable fire-extinguishing systems, fire-detection systems, and fixed fire-extinguishing systems, including ventilation, machinery shutdowns, and fixed fire-extinguishing system pressure-operated dampers on board the vessel, must be inspected or tested at least once every 12 months, or more frequently if otherwise required by the TSMS applicable to the vessel.
• Table 46 CFR 143.245 (b): identifies “All other essential systems” as having a testing frequency of at least once every 3 months.
• §136.110 includes systems for suppression of fire as an essential system.

46 CFR § 143.460(d) states:

“Each winch that is capable of an uncontrolled release of the towline while under tension must have a warning sign at or near the winch controls. All safety devices must be engaged during winch operation.”

In plain terms, this requirement applies only to towing winches capable of unintentionally releasing line under load. The regulation requires that a clearly visible warning be posted at or near the winch controls and that all safety devices remain engaged during operation. While the regulation does not define “uncontrolled release,” it is commonly understood to mean a situation in which the line pays out unintentionally under tension, creating hazards such as serious injury, equipment damage, or loss of tow control. Vessel owners or managing operators are responsible for ensuring appropriate signage is installed, maintained, and understood by the crew.

PREFERRED:  Company to identify testing frequency within TSMS. During the annual survey the surveyor visually inspects system components and has a crew member perform a function test with the vessel safely secured at a dock, fleet, or mooring.

ALTERNATIVE:  During annual survey the surveyor visually inspects system components.  If vessel is underway and not able to secure at a dock, fleet, or mooring, a function test WILL NOT be performed.  If documentation can be provided showing fuel shutoff valves have been tested as indicated in the TSMS, the surveyor can accept this as objective evidence of successful function testing.  If there is no documentation of testing IAW the companies TSMS the surveyor will issue a finding that successful function testing was not able to be performed due to operating conditions and that there was no current documentation of testing as required by the TSMS. The anticipated corrective action plan from the vessel operator would be to have system function tested within 30 days and documentation of same provided to TVIB as objective evidence.

In either case, if the visual inspection of the Fuel Shutoff valves reveals a deficient condition, a finding will be issued and may affect the vessel’s ability to operate until a successful function test is completed to the satisfaction of the attending surveyor.

IN ALL CASES:  A non-operational Fuel shutoff valve is a major non-conformity, which requires notification to TVIB within 24 hours (real-time is preferred).

NOTE: A valve is a device not a system. The operation of the valve does not act to suppress the fire. §142.240(a) specifically references “machinery shutdowns”, which requires testing every 12 months. TSMS testing frequency should identify testing frequency IAW either of the below associated references:

ASSOCIATED REFERENCES:

• §142.240 (a): All portable fire extinguishers, semi-portable fire-extinguishing systems, fire-detection systems, and fixed fire-extinguishing systems, including ventilation, machinery shutdowns, and fixed fire-extinguishing system pressure-operated dampers on board the vessel, must be inspected or tested at least once every 12 months, or more frequently if otherwise required by the TSMS applicable to the vessel.
• Table 46 CFR 143.245 (b): identifies “All other essential systems” as having a testing frequency of at least once every 3 months.
• §136.110 includes systems for suppression of fire as an essential system.

Electrical Safety FAQ:

Multiple Power Source Warning Requirements

What does 46 CFR 143.250(b) require?

Federal regulations require that any electrical panel or enclosure containing more than one power source be clearly labeled with a warning sign. This sign must:

• Alert personnel that multiple power sources exist, and
• Identify where each power source can be secured or disconnected.
  

  ---

Why is this requirement important?

Electrical panels with multiple power feeds—such as shore power, generators, or battery systems—can remain energized even when one source is shut off. Proper signage prevents electrical shock, arc flash, and equipment damage by ensuring workers know all potential sources of energy before performing maintenance or service.

What should the warning label say?

While the regulation allows flexibility, the wording must be clear, visible, and specific.

Example label:

Warning: More than one power source. Disconnect shore power and generator supply before servicing.

Labels should be made of durable material, resistant to heat, moisture, and corrosion.

Where should the warning be placed?

Place the warning directly on or adjacent to the panel or enclosure in a conspicuous location, easily seen by anyone accessing the equipment.

Who is responsible for compliance?

Vessel owners, managing operators, and masters are responsible for ensuring all applicable panels and enclosures meet this labeling requirement.

How is compliance verified?

Compliance with 46 CFR 143.250(b) is verified during:

• U.S. Coast Guard inspections
• Authorized Class Society (ACS) surveys
• Annual Surveys (for Subchapter M vessels)

Best practices for maintaining compliance

• Inspect labels regularly and replace if damaged or faded.
• Update signage whenever power configurations change.
• Use engraved placards or marine-grade adhesive labels.
• Train all crew and maintenance personnel on the meaning of the signs.

QUESTION: What inspections are required for an electric water heater on a towing vessel?

RESPONSE:  To answer this question, first you must identify some characteristics of the electric water heater.

46 CFR 136.110 defines a pressure vessel as “… a closed tank or cylinder containing gas, vapor, or liquid, or a combination thereof, under pressure greater than atmospheric pressure.”

An electric water heater is a closed tank that contains liquid and is under pressure greater than atmospheric pressure.

The following italicized text contains excerpts from the regulatory citations and not the language in its entirety.

§ 143.300 further defines requirements for pressure vessels as those that are greater than or equal to 37.4 gallons and over 15 pounds per square inch.  Under this set of requirements, there are some that are applicable to an electric water heater:

 (a) be equipped with a spring loaded relief valve that prevents pressure from exceeding the MAWP by more than 10 percent.

 (b) be externally examined annually and relief valve tested in accordance with § 143.245 (i.e., twice every 5 years with no more than 3 years between testing)

 (c) be marked with MAWP

 (d) if installed after July 20, 2018, must meet ABS rules (see § 143.540)

Since the water heater will operate at the pressure of the potable water system, the gauge requirement of § 143.300(a) is more commonly applied by having a pressure gauge on the output side of the potable water pump or thereafter in the piping system.

While not applicable to Subchapter M vessels, one can look at Subchapter T (46 CFR 182.320) and Subchapter K (§ 119.320) for similar regulatory guidance. Those regulations put specifications that apply to a water heater that is UL listed, under 120 gallons, and heat input is less than 200,000 BTU per hour.

Additionally, the water heater manufacturer likely provides documentation to guide the owner on maintenance. A quick web search of some major water heater manufacturers identified that at least annually the temperature pressure relief valve should be tested, and one was found to call for the relief valve to be reinspected once every three years and replaced if necessary. The vessel owner/operator should consult the manufacturer’s documentation for the make/model installed on the vessel.

QUESTION: I have a regulatory interpretation question regarding generators.

A generator fails on a vessel equipped with 3 generators while the other two generators are fully operable. Only one generator is needed to carry the load for the vessel.  Are we required to report this to the Coast Guard and TVIB?

RESPONSE:  Short answer is yes, based on the following:

Guidance concerning reportable marine casualties was taken from NVIC 01-15 title 46, code of federal regulations (CFR), part 4 marine casualty reporting procedures guide with associated standard interpretations 46 CFR 4.05-1.

The loss of an online generator IS considered a reportable marine casualty no matter the duration. However, if you have the required 2 operational power supplies, you continue to meet the requirements under Subchapter M.

The benefit of this setup is that the vessel still has the required power supplies so you can schedule repairs to the affected generator later and continue operations without lost time.

Once reported, this may be handled differently from one Coast Guard unit to another since it does not affect operations. These would be the 2 most likely and agreed-upon options but they do not preclude an alternate path not discussed in this FAQ under the direction of the OCMI.

• CG-835V not issued, Notify TPO IAW companies TSMS for repairs. Continue operations
• CG-835V issued, Action Code A, Self-reported Worklist item, not fwd. facing. Notify TPO IAW Companies TSMS. Continue operations.

QUESTION: If I am experiencing an issue with a checklist or have a question who do I contact?

RESPONSE:

If you are experiencing an issue with an item on the checklist such as you believe the login isn’t working properly or have an item on the checklist that is consistently resulting in a finding when it should not, first check to see that you have answered all questions in red. These questions drive the logic and if they are skipped or answered incorrectly it may result in an issue with the checklist.

If you are still experiencing an issue or have any questions please contact an Operations Coordinator by calling 832-323-3992 or click here to send an email.

QUESTION: Who do I contact if my login credentials aren’t working?

RESPONSE:

Please call the office at 832-323-3992 or click here to send an email.

QUESTION: When do I need to alert TVIB that my vessel is going into drydock for repairs?

RESPONSE:

You need to alert TVIB when your vessel is going into drydock for the following:

• Any Credit Drydock
• Non-credit drydock that involves the following:
• Any repair to a fuel tank;
• A repair that crosses two or more frames; or
• Steel replacement of greater than 324 square inches.

If you have any questions please call 832-323-3992 during normal business hours or click here to send an email and the appropriate staff member will get back to you.

If you require assistance after hours please call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:

• URGENT: immediate assistance is needed, regardless of the time of day; or
• NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document.

QUESTION: Does TVIBs External Vessel Audit Program satisfy the requirement for all vessels to be randomly audited during the 5-year period of validity of the TSMS certificate?

RESPONSE:

Yes.  TVIB published the External Vessel Audits policy to meet the elements laid out in CG-CVC Policy Letter 18-01 CH.2 which clarifies the requirement for random vessel audits as noted in 46 CFR 138.315(b)(3). TVIB staff worked with the Audit Committed to develop the External Vessel Audits policy that takes into consideration the logistical issues related to scheduling random external vessel audits across a company’s entire fleet during the 5-year period of validity of the TSMS certificate.

Click here to access the TVIB Member Portal where you can log in and download the External Vessel Audits policy. Once you log in click on the drop-down menu in the upper right-hand corner and select Policies and Member Communications to locate the policy.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials please click here to send an email to request them.

QUESTION: What do I do if I miss my annual survey window?

RESPONSE:

As soon as you realize you have missed the window for the annual survey you should do the following:

• Notify TVIB by contacting an Operations Coordinator by phone at 832-323-3992 or click here to send an email; and
• Notify the local OCMI as the COI was issued under the TSMS option and the vessel must comply with all elements for the COI to remain valid.
  • It is important to advise the local OCMI that the TPO was notified of the deficiency and there is a plan in place to have the survey conducted.

The annual survey must note this failure to comply as a deficiency that must be addressed in the Corrective Action Plan (CAP).

The CAP for this item should detail HOW the company will ensure this does not happen in the future. It is NOT sufficient to state “the annual survey was completed” as this does not address the initial failure to comply and provide a plan to prevent a recurrence on this vessel or any others in the fleet.

See the FAQ related to calculating the window for conducting an annual survey for additional information.

QUESTION: What do I do if my vessel is involved in a marine casualty?

RESPONSE:

Refer to 46 CFR 4.05-1 to determine if the incident is considered a Reportable Marine Casualty. If it is a Reportable Marine Casualty then you must comply with all reporting requirements as noted in the CFR and incorporated by reference in 46 CFR 140.900 which begins with notification to the local OCMI.

Once the Coast Guard has been notified according to 46 CFR 4.05-1 you may receive a CG-835V.  If the 835V is issued with an action code of “A” please follow these steps to properly report the incident TVIB:

• Call the TVIB 24-hour Response Line 888-983-TVIB (8842) and be prepared to indicate whether the issue is:
  • URGENT: immediate assistance is needed, regardless of the time of day; or
  • NON-URGENT: a response from the on-call staff person within 24 hours is acceptable.
• Email the 835V to TVIB. Click here to submit the 835V via email.

The OCMI retains the sole authority to close out a CG-835V.

Incidents that are not considered a Reportable Marine Casualty according to 46 CFR 4.05-1 may be reviewed by the auditor during the course of the next management audit.

For a more detailed description of the notification requirements for this and other issues please log in to the TVIB Member Portal and download the TVIB Subchapter M Notifications document. If you have any questions about this process you may call 832-323-3992 or click here to send an email and a staff member will get back to you.

You will need login credentials to gain access to the TVIB Member Portal. If you do not have login credentials o click here to send an email to request them.

QUESTION:
For an item that was corrected during the audit/survey and marked as such on the report, is a response required by the operator on the CAP?

RESPONSE:
The answer is no, provided that the following elements are satisfactory:

• The finding statement clearly articulates how the item was corrected; and
• The finding is NOT one of the following:
  • Major Non-conformity*
  • Unsafe Condition*
  • Repeat Finding**

* A major non-conformity or unsafe condition has mandatory reporting requirements, please reference the TVIB Notifications document for specifics.

** Repeat findings may indicate a failure of the TSMS.

If you have any questions please call 832-323-3992 or click here to send an email.