The US Coast Guard announced an update to “Guidance on the Audit Scheme for Vessels Using a Towing Safety Management System (TSMS) Option.”
Key changes include:
- The random external vessel audit program shall begin upon the first TSMS renewal (i.e. renewal or initial) after July 19, 2022;
- Provides an equivalent to meeting the requirements of the random external vessel audit program.
According to the update, no random external vessel audits are required during the phase-in period. In fact, all vessels using a TSMS option will undergo an audit as part of their initial COI.
It is more reasonable and practicable to begin the random process only after all vessels are issued a COI. This allows the TPO/company to draw an equivalent “random” selection from the entire pool of vessels
said USCG.
In addition, upon the first TSMS Certificate issuance (i.e. renewal or initial) after July 19, 2022, the random external vessel program will begin. This involves a single random audit conducted for each vessel during the 5-year period of validity of the TSMS Certificate. Vessels will be selected randomly and the schedule of external vessel audits covered by a TSMS Certificate should be distributed as evenly as possible.
Furthermore, as an equivalent to meeting the requirements of the random external vessel program an owner or managing operator may request OCMI approval to allow the TPO to perform two planned (i.e. non-random) audits in a 5-year cycle in a similar manner to the ISM Code, one planned external vessel audit conducted between the second and third anniversary date of the COI with a second audit before the COI renewal.
This alternative arrangement will be considered an equivalent level of safety, and must be documented in the TSMS applicable to the vessel.
Moreover, if employing the TSMS equivalency option, the owner or managing operator shall base their vessel auditing program schedule on the first COI issuance date (i.e. renewal or initial) for each vessel after July 19, 2022. Additionally, one of the two scheduled audits may use objective evidence, such as recent surveys, pictures, video, vessel logs, machinery logs etc. to credit the audit with attendance at the vessel as deemed necessary by the TPO.
Finally, environmental considerations were examined in the development of this policy letter and have been determined not to be applicable.
