Commercial Vessel Compliance

2/5/2019: Update to Policy Letter 17-04, “Subchapter M Third Party Organization Guidance”

The Office of Commerical Vessel Compliance issued Change 1 to Policy Letter 17-04, “Subchapter M Third Party Organization (TPO) Guidance” Jan. 31, 2019.

CG-CVC Policy Letter 17-04 is here by cancelled and superseded by Change 1. Updates are limited to the Subchapter M Third Party Organization Guidebook enclosure and include:

a. Updated multiple parts of Section 5 that address the main responsibilities of a TPO;
b. Updated Section 7 to include more information pertaining to actions a TPO auditor or surveyor should take when they identify a problem;
c. Updated Section 8 to address the validity of TSMS certificates if a TPO’s approval is voluntarily surrendered;
d. Updated Section 9 to address the process for a third party developed course to gain Coast Guard acceptance;
e. Updated Appendix 1: Third Party Organization Application Job Aid to included previously missed regulations; and
f. Added two new appendices: Appendix 2: Audit Result Submissions and Appendix 3: Aid for Processing, Recording, and Reporting Deficiencies.

Policy Letter 17-04 (Change 1) provides guidance to the Towing Vessel National Center of Expertise, Officer(s) in Charge, Marine Inspection, and the marine industry on TPO requirements as discussed in reference the Inspection of Towing Vessels Final Rule published June 20 2016. It is intended for use by the NCOE, OCMIs, and entities within the maritime industry that are or want to become TPOs.

For full details, view or download Policy Letter 17-04 (Change 1), or contact the Office of Commercial Vessel Compliance, Domestic Compliance Division at

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.

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