Subchapter M

TVIB Offers Drydock Hull Examination Course

The Towing Vessel Inspection Bureau (TVIB) has launched a drydock and internal structural examination certification course.

The three-day course is being held virtually for now with plans to transition back into a classroom setting once the COVID-19 pandemic has passed.

More than two years after the Coast Guard issued its first Certificates of Inspection (COIs), towing vessel operators are beginning to address compliance with another key component of Subchapter M: periodic drydock and internal structural examinations for credit. Coast Guard Regulation 46 CFR 137.300 requires all towing vessels to undergo a drydock and internal structural examination at least once every five years for vessels not exposed to salt water more than six months in any 12-month period. Those exposed to salt water more than that must undergo the examinations at least twice in five years with no more than 36 months between inspections. That means vessels operating in salt water that obtained their COIs early in the implementation process are coming due for their first credit drydock and internal structural examination.

TVIB said it developed the course after recognizing the need to train surveyors on Subchapter M’s expectations for compliance. The company added that there is not currently another course available to the market that focuses on these examinations.

Additionally, TVIB said it knew vessel owners and managing operators would need guidance on how their vessel’s Towing Safety Management System (TSMS) would tie into this set of surveys for those who chose the TSMS option for obtaining a COI.

Over the course of a year, TVIB staff worked alongside a committee made up of TVIB-certified surveyors, NAMS and SAMS surveyors, recently retired Coast Guard marine inspectors, port engineers and others with extensive backgrounds in vessel maintenance and repairs to create consistent and comprehensive course content. Mike Rushing of Rushing Marine Service in Jackson, Mo., is the primary course instructor. TVIB said Rushing and other staff members spent hours in shipyards during the course’s development, creating a library of photos and videos to help drive student and instructor conversations about vessel conditions and suitability.
Content includes establishing the roles of the surveyor, TPO and Coast Guard during survey activities, how to assess vessel hull structure damage inside and out, assessing hull thickness, how to apply ABS Rules and NVIC 07-68, among other currently available published resources, and how to write acceptable drydock and internal examination reports while adhering to Subchapter M requirements. It also includes practical exercises for using the TSMS during the examination.

While the course was designed to train towing vessel surveyors, towing vessel owners and managing operators, shipyard personnel and other stakeholders may gain insights by taking the course as well, according to TVIB.