The towing operations can be very tricky, given the number of people taking part in it; From the Coast Guard, Third Party Organizations (TPO), auditors, surveyors, owners, operators, and myriad documentation requirements, as the Certificate of Inspection, TSMS, surveys, audit reports, work lists, maintenance schedules, logs.

#Case study:

USCG presents an incident where an inspected towing vessel was chartered (bareboat) to another operator with a different TSMS. During the handoff to the new operator, the vessel was added to the chartering company’s TSMS, but the handoff didn't specify how to bring a chartered vessel under the new TSMS.

Therefore, the receiving TPO did not adequately survey the vessel, and the receiving operator did not understand the existing deficiencies or pending repairs/maintenance.

During operations by the charterer, the vessel experienced a loss of propulsion due to insufficient fuel in the day tank; When inspected, it was found that the fuel transfer pump and the tank’s low- level alarm were both found inoperative. Only one of these issues was already known before the incident.

The investigation also revealed that the crew had no knowledge of the charterer’s TSMS procedures, did not feel empowered to conduct any repairs on the vessel and were generally unfamiliar with the vessel’s configuration and arrangement.

Therefore, in light of the above, the USCG recommends that before offering or accepting a charter arrangement:

  1. Ensure a vessel is in full compliance with all applicable regulatory requirements;
  2. Establish clear procedures to transfer a vessel to a different TSMS;
  3. Confirm that all parties understand their responsibilities for safety, repairs, and maintenance;
  4. Outline the steps to transfer known Corrective Action Reports, deficiencies, and maintenance needs;
  5. Ensure planned and unplanned maintenance continues under the charter arrangement;
  6. Establish processes to provide indoctrination/on-boarding for new crew members;
  7. Notify the Coast Guard to ensure proper updates are made to the vessel’s Certificate of Inspection.