Written by Cmdr. Jacqueline Twomey, Supervisor, Towing Vessel NCOE
On January 3, 2017, the Coast Guard approved several Third Party Organizations (TPOs) in accordance with 46 CFR 139.115 to carry out functions described in 46 CFR Subchapter M. The list of approved Third Party Organizations and other useful information regarding Subchapter M is posted on the Towing Vessel National Center of Expertise’s (TVNCOE) website. The Coast Guard continues to review other applications and expects to add to the pool of approved TPOs in the near future.
Third Party Organizations will perform audits and surveys to ensure towing vessels comply with requirements in Subchapter M for vessels that choose the Towing Safety Management System (TSMS) option. In addition, Recognized and Authorized Classification Societies, as defined in 46 CFR 8.100, are not subject to further approval and for the purposes of Subchapter M may perform the functions of a Third Party Organization.
To assist in the implementation of Subchapter M, the TVNCOE and the Coast Guard Headquarters Office of Commercial Vessel Compliance held several meetings in December. The Coast Guard met with the public to provide updates on policy decisions, including an overview of the Frequently Asked Questions posted on the TVNCOE website. The Coast Guard provided a summary of TSMS requirements to assist towing companies in the development of TSMS. The Coast Guard also described a job aid currently in the final stages of development, Tug Safe, which will be available to both Coast Guard and industry users and will be accessible on mobile platforms as well as on the internet.
In addition, the Coast Guard held meetings with both prospective TPOs and Classification Societies to answer questions and receive feedback regarding any implementation challenges. The Coast Guard fully supports the TSMS option because it allows the Coast Guard to focus resources on vessels of the greatest risk. Therefore, TVNCOE will assist any prospective TPOs throughout the application for approval process. Prospective TPOs may contact the TVNCOE at TVNCOE@uscg.mil with questions or to receive assistance.
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.