Commercial Vessel Compliance

11/28/2017: Fifth policy letter regarding Subchapter M implementation now available

The Coast Guard Office of Commercial Vessel Compliance has issued Policy Letter 17-10, “Deficiency Recording and Reporting for Vessels Using a Towing Safety Management System (TSMS) Option,” to provide guidance to Coast Guard entities including Officer(s) in Charge, Marine Inspection (OCMI), Third Party Organizations (TPO), and the marine industry on the recording and reporting of deficiencies and non-conformities on vessels whose owners have chosen to use the TSMS option.

The overall responsibility for vessel compliance rests with the vessel owner and/or managing operator. TPOs conduct independent verifications of a company’s TSMS and towing vessels to verify compliance with the requirements of 46 CFR Subchapter M.

A successful quality system proactively identifies areas for improvement, establishes corrective actions, and documents the findings and action. As stated in Title 46, CFR, Section 137.130, the TSMS must include procedures for reporting and correcting non-conformities and deficiencies, regardless of how they are identified.

The Coast Guard’s expectation is that owners and/or managing operators will actively identify non-conformities and document the items in accordance with their approved TSMS. The TPOs will then verify the non-conformities are properly addressed as well as independently verify the vessel and company are in compliance with the regulations. When a non-conformity is found, the TPOs should ensure that corrective measures have been taken, the issue is resolved in a timely manner, and the appropriate documentation is maintained.

The accurate documentation of serious deficiencies or major non-conformities within the Marine Information for Safety and Law Enforcement (MISLE) database is necessary to assess vessel, company, and TPO performance and provide data for future risk based inspection programs. OCMIs are encouraged to periodically review the data within MISLE to better define the scope of inspections on all towing vessels as well as inform the industry of trends in vessel compliance.

For full details, read or download Policy Letter 17-10.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.