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COLUMN SPECIAL REPORT

OCMI 90 days in advance to begin the COI process. This T TPO/TSMS OHE PTION process includes document review and other preparatory Changing course to one of the more insightful and ac- requirements. Upon completion and meeting of the ? rst commodating areas of Subchapter M is the TPO/TSMS requirements, owner/operators may schedule their vessel (Towing Safety Management System) alternative. The inspections within 30 days. If you are planning on using TPO alternative is unique to the tugboat and towing ves- the USCG and have not reached out to your local OCMI sel industry and allows owner/operators the ? exibility of yet, then stop reading and contact them now. choosing a TPO to complete their COI. As we covered

The feedback from industry and regulators during the earlier, this option will be critical to meet the high demand bridging period allowed USCG to acknowledge their lim- of inspections to meet Sub M compliance. Additionally, ited resources and identify other ways to offset the daunt- it provides owners/operators with the opportunity to se- ing task of increasing their inspected vessel ? eet. One of lect a TPO from traditional classi? cation societies such as those areas builds upon the Coast Guard’s strong working ABS, DNV-GL or choose a newer TPO, such as the Tow- relationship with owner/operators that have been volun- ing Vessel Inspection Bureau (TVIB). Owners/operators tarily participating in UTV program over the years. The can make the best business decision that meets their goals, success of that program has provided industry with anoth- timelines, and more importantly, their budget. er path to expedite the COI process. Additionally, Owners/Operators can use an existing

USCG implemented policy that recognizes those ves- safety management system to obtain an initial Certi? cate sels that have a valid UTV decal within three years from of Inspection. Owner/Operator holding valid ISM will be the date the towing vessel is required to undergo its initial considered compliant to TSMS requirements. Other ac-

COI issuance, the decal will be applied as full credit that cepted safety management systems, such as AWO-RCP an initial inspection for certi? cation has occurred, provid- may also be considered as meeting the TSMS requirements ed a few conditions are met. Those conditions include that along with objective evidence that the vessel complies with if the TPO option is selected, the TPO must have issued Subchapter M. (Note: As of March 7, 2018, USCG Policy

TSMS certi? cation to owner/operator of the vessel at least was amended to include 3-year objective evidence in lieu of six months before the date the vessel is scheduled for its holding TSMS Certi? cate for six-month prior to issuance of initial COI issuance. There must be no outstanding major vessel’s initial COI. [Refer to USCG CVC Policy letter 17-02 non-conformities and a copy of the report must be sub- (Ch.01) for further guidance.]) mitted to the OCMI with the Application of Inspection The real strength to the TPO/TSMS option is that it (CG-3752) at least 30 days in advance of the scheduled is speci? c to tugboat and towing vessel industry. This initial COI issuance date. (2) The vessel has successfully means that there is less sharing of resources and time, completed both a vessel audit and a survey with no major speci? cally with the domestic passenger vessel market non-conformities. (Refer to USCG CVC Policy letter 17-01 and competing for limited resources currently available for further guidance.) within United States Coast Guard. For Owner/operators

May 2018

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