The Office of Commercial Vessel Compliance announced the release of Policy Letter 17-04: Subchapter M Third Party Organization Guidance to assist the Towing Vessel National Center of Expertise (NCOE), Officer(s) in Charge, Marine Inspection (OCMI), and the maritime industry on TPO requirements. Entities within the maritime industry that are or want to become a TPO, or who use or are considering using a TPO, should be familiar with Policy Letter 17-04.
The information in the TPO guidebook is meant to aid in the understanding of the TPO requirements of Subchapter M and is intended to be a living document that may be updated by the Coast Guard based on lessons learned throughout the implementation process. Additionally, it is a companion document and, therefore, does not restate all regulatory requirements. Section IV of the preamble to the Inspection of Towing Vessels final rule and its Subchapter M regulations should be read before using the TPO guidebook.
With less than one year to go before a significant portion of towing vessels start to obtain a COI, owners and managing operators are encouraged to develop a plan to ensure their vessel(s) are in compliance, allowing adequate time for the Coast Guard or a Third Party Organization to complete the required inspections, audits, and surveys necessary prior to the issuance of a COI.
Other recent policies on Subchapter M include:
(1) CG-CVC Policy Letter 17-01: Use Of The Uninspected Towing Vessel (UTV) Decal To Meet Certain Requirements Regarding Issuance Of The Initial COI Under Subchapter M;
(2) CG-CVC Policy Letter 17-02: Use Of Existing Safety Management Systems To Obtain An Initial Certificate Of Inspection Under 46 CFR Subchapter M; and
(3) CG-CVC Policy Letter 17-03: Certification Of Inspection (COI) Phase-In Period For Existing Towing Vessels Using The TSMS Option Under Title 46, Code Of Federal Regulations (CFR) Subchapter M
These and other policy letters are available on CG-CVC’s website.
CG-CVC is currently drafting additional policy letters to assist the maritime industry in implementing Subchapter M to include a Towing Safety Management System Guidebook and a Compliance Guidebook.
As guidance and policies related to Subchapter M continue to be developed, companies must make the important decision to employ either the Coast Guard option or the Towing Safety Management System (TSMS) option. Using a third party to conduct surveys and audits is a paradigm shift from traditional Coast Guard inspections. However, the TSMS option may provide greater flexibility to companies in scheduling and performing surveys and audits, while also establishing a comprehensive quality control system that will increase the safety and efficiency of all towing vessel operations.
If stakeholders have additional questions or concerns that are not clearly explained in the preamble or regulatory text of Subchapter M, we encourage you to submit questions via the TVNCOE website or attend the Towing Safety Advisory Committee meetings. Towing companies, whether American Waterways Operators (AWO) members or not, are urged to consult AWO’s Subchapter M website.