Thus, officers in charge, Marine Inspections should follow this guidance when issuing a COI under 46 CFR Subchapter M for inspected towing vessels choosing the TSMS option. A flow chart is included in the Work Instruction to illustrate the TSMS compliance process.

This instruction provides guidance on the US Flag Administration’s interpretations concerning the application and implementation of towing vessel certificate of inspection, issued under the  Towing Safety Management System option.



According to the updated guidance, from July 20, 2018all towing vessels must be in compliance and have received, or are making plans to receive, a COI from the Coast Guard. Those interested, can document their compliance either according to Coast Guard's certification or TSMS's certification.

  • Surveys: [Internal] The owner or managing operator completes a vessel survey under the internal survey program with Third Party Organization (TPO) oversight of the same. The owner or managing operator is not required to survey items as described in 46 CFR §137.220 as one event, but may survey items on a schedule over time, provided that the interval between successive surveys of any item does not to exceed one year. ii.
  • Surveys: [External] External surveys shall be managed in accordance with 46 CFR §137.205 and conducted annually, within 3 months of the anniversary date of the COI.
  • Audits: [Internal]: Under 46 CFR §138.310(d), are conducted by the owner or managing operator. The auditor must be independent of the procedures being audited, unless this is impracticable due to the size and nature of the organization. The auditor may not be the designated person, or any other person, within the organization that is responsible for development or implementation of the TSMS.
  • Audits: [External]: The TPO completes an external management audit prior to the issuance of the initial TSMS certificate and will conduct an external vessel audit either prior to or after initial issuance of the COI depending on how long the vessel has been owned or operated and subject to the TSMS (46 CFR §138.315). For vessels that have been owned or operated for fewer than 6 months, 46 CFR §138.315(b)(2) requires that an external audit must be conducted no later than 6 months after the issuance of the initial COI.

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