5/24/2017: New policy letter on Subchapter M implementation released

Today, the Office of Commercial Vessel Compliance released Policy Letter 17-02: Use of Existing Safety Management Systems to Obtain an Initial Certificate of Inspection Under 46 CFR Subchapter M to provide guidance to the Officer(s) in Charge, Marine Inspection (OCMI), Coast Guard marine inspections as well as the towing industry on the use of existing safety management systems as permitted in 46 Code of Federal Regulations, 138.225(a) or 138.225 (b) to obtain an initial certificate of inspection under 46 CFR Subchapter M.

Highlights include use of previously conducted audits under existing safety management systems, such as the ISM Code and American Waterways Operators’ Responsible Carrier Program, as objective evidence of compliance for the issuance of a towing vessel’s initial  certificate of inspection.

As guidance and policies related to Subchapter M continue to be developed, towing vessel companies must make the important decision to employ 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 will likely 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.

Frequently asked questions about Subchapter M implementation are answered on the Towing Vessel National Center of Expertise’s website. If you have an additional question or comment not already covered, you are encouraged to submit it to TVNCOE or to the CVC-1 Domestic Compliance Division.

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.

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