TVIB News FAQ Category: 46 CFR Part 138 – TSMS - Towing Safety Management Systems

Management Audit – Multiple Locations

 

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.

Random Vessel Audits

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.

Add or Remove Vessel from TVA

QUESTION: How do I add or remove a vessel from my fleet?

RESPONSE:

On 10/20/22, TVIB retired the PDF version of the TSMS Vessel Addendum Add/Remove form and replaced it with a web-based form.

  • The TSMS Vessel Addendum Add/Remove form must be submitted electronically through the TVIB Member Portal, click here to access the form.
    • 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.
  • Once the form is submitted, the TVIB Operations team will receive a notification and an Operations Coordinator will process the request.
  • The revised TSMS Vessel Addendum (TVA)will be forwarded to the individual listed as the Primary Contact for the organization as well as the Coast Guard’s Towing Vessel National Center of Expertise (TVNCOE).

If you have any questions or need assistance with completing the process call 832-323-3992 or click here to send an email to the Operations Team. Below is a video to walk you through the process of logging into the TVIB Member Portal and submitting the form.