IMX Panel Details Vessel Construction TSMS Option
How do the requirements of Subchapter M and seeking a certificate of inspection (COI) using a third-party organization (TPO) under the Towing Safety Management System option affect the construction schedule? That was the focus of questions tackled by an expert panel at the recently concluded Inland Marine Expo.
Titled “From Concept to COI: Navigating the Realities of a New Construction TSMS Option Vessel,” the panel was hosted by Tava Foret, founder of the Towing Vessel Inspection Bureau. Panelists included Caleb King, a senior operations manager at TVIB; Mike Stone, manager of vessel engineering at Canal Barge Company; Patrick McKinney, marine surveyor and lead auditor at Rushing Marine Service, LLC; and Kenneth Humphreys, a licensed professional engineer and managing partner of MiNO Marine, LLC, a naval architecture and marine engineering firm based in New Orleans, La.
Stone pointed out that Subchapter M is “virtually silent on vessel construction.” This leaves room for flexibility, but also possibly for misunderstandings if communication is not good.
McKinney said that anyone building a vessel should set up meetings with their TPO as soon as possible—especially if they don’t build a vessel every year. Humphreys agreed, saying TPOs can guide vessel construction through some important steps. What about the case when the vessel is already under construction and the TPO is brought in midway through the process? That could be “an accident waiting to happen,” McKinney said.
King said vessel designers need to be part of the conversation from the beginning. The Coast Guard needs to be part of it as well, although the Coast Guard can sometimes be the slowest partner in responding due to being short-handed in some districts. Some issues may arise when a vessel is being built in one Coast Guard district, but the operator intends to apply for its COI in another district. Communication with the Coast Guard is crucial at all stages, since it has the power to require rebuilds or equipment additions. Humphrey said that Coast Guard inspectors are keenly interested in making sure that crews know how to operate all safety equipment. He said a Coast Guard inspection may take no longer than an hour or two if everything goes right. The most common deficiencies, he said, involve record-keeping and fire-fighting equipment, but these usually result in the issuance of an 835 (documentation of deficiency) that still allows the vessel to operate. The key is to build a good relationship with the local Officer in Charge Marine Inspection (OCMI) early on. Foret agreed, saying, “Do that first! Don’t wait for an incident.”
Featured photo caption: Panelists discuss best practices for navigating Subchapter M requirements during the session “From Concept to COI: Navigating the Realities of a New Construction TSMS Option Vessel” at the 2026 Inland Marine Expo. Pictured, from left, are Tava S. Foret, president and co-founder of Towing Vessel Inspection Bureau (TVIB); Patrick McKinney, marine surveyor and lead auditor at Rushing Marine Service LLC; Kenneth Humphreys, licensed professional engineer and managing partner of MiNO Marine LLC; Mike Stone, manager of vessel engineering at Canal Barge Company; and Caleb T. King, senior operations manager at Towing Vessel Inspection Bureau (TVIB). (Photo courtesy of ECN Photography)
