Using one of the TSMS compliance options to verify that their vessels are in continuous compliance, minimizes the need and presence of Coast Guard personnel on board the vessel as compared to the Coast Guard Option. Using a TSMS option may give companies more flexibility in their operational schedules.

46 CFR Subchapter M  requires within the TSMS establishment of safeguards to ensure mitigation of risks in safety and pollution in towing vessel operations. The CFR places responsibility for this squarely on the companies charged with the vessel’s management as also with the Masters of these vessels. Towing Safety Management Systems need not be complex and need to work for all concerned while also meeting the requirements of the CFR.

Owners or managing operators selecting the TSMS option must obtain a TSMS certificate issued under 46CFR § 138.305 at least 6 months before obtaining a Certificate of Inspection (COI) for any of their vessels covered by the TSMS certificate. Let the QMII team of experts work with your team to identify opportunities for improvement as also to meet your compliance needs.

46 CFR Subchapter M is applicable to all U.S.-flag towing vessels as defined in §136.110 engaged in pushing, pulling, or hauling alongside, except—

  • A vessel less than 26 feet (7.92 meters) in length measured from end to end over the deck (excluding the sheer), unless that vessel is pushing, pulling, or hauling a barge that is carrying oil or hazardous material in bulk
  • A vessel engaged in one or more of the following:
    •     Assistance towing as defined in §136.110;
    •     Towing recreational vessels for salvage; or
    •     Transporting or assisting the navigation of recreational vessels within and between marinas and marina facilities, within a limited geographic area, as determined by the local Captain of the Port   (COTP);
  • A workboat operating exclusively within a worksite and performing intermittent towing within the worksite
  • A seagoing towing vessel of 300 gross tons or more subject to the provisions of subchapter I of this chapter
  • A vessel inspected under other subchapters of this chapter that may perform occasional towing
  • A public vessel as defined in 46 U.S.C. 2101
  • A vessel that has surrendered its COI and is laid up, dismantled, or otherwise out of service
  • A propulsion unit used for the purpose of propelling or controlling the direction of a barge where the unit is controlled from the barge, is not normally manned, and is not utilized as an independent vessel

Our methodology addresses these questions:

  • Are there any major gaps in the management system?
  • Is there any chronic system weakness?
  • What are the systemic causes of process waste?
  • Does the TSMS meet the predetermined criteria?
  • How quickly can the system deficiencies be solved?
  • How can the system appreciate the risks before incurring loss and before damaging reputation?
  • Document how the organization works to achieve compliance and conformity with 46 CFR Subchapter M in a  TSMS or modify the existing SMS to reflect the “as-is” of how the functional objectives and other requirement of Subchapter M are achieved.
  • Begin implementing the TSMS both ashore and onboard and start maintaining documentation/records as required.  Generally you want the system running for at least two months before conducting internal audits.
  • At this point QMII as your TPO will conduct a review the TSMS documentation to verify all elements of Part 138 – including requirements spelled out in detail in Parts 140 through 144 – of Subchapter M are being met. This will be followed by an audit of the office.
  • As a last step in the certification process, QMII will conduct a shipboard audit of one towing vessels in the fleet.
  • Audits resulting in no major non-conformities will result in QMII issuing a TSMS Certificate with a validity of five years.
  • Continued certification includes an audit the office(s) twice in five years. All vessels within the fleet also need to be audited on a rotating basis  so each towing vessel with a COI  has a shipboard audit at least once in every 5 year period.

Click on the links below to access resources related to Subchapter M and TSMS