46 CFR Part 139 Third-Party Organizations


Towing vessel owners or managing operators who select the Towing Safety Management System (TSMS) option to demonstrate compliance with 46 CFR subchapter M must complete management and vessel audits to assess compliance with their TSMS, obtain a TSMS Certificate and complete surveys to demonstrate vessel compliance with 46 CFR subchapter M. Functions related to completing audits, issuing a TSMS certificate and completing surveys are carried out by a TPO or an organization that can perform the work of a TPO.

Organizations that may perform work as a TPO

In accordance with 46 CFR 139.110, classification societies that are recognized and/or authorized meet the requirements of a TPO. These classification societies are approved by regulation to perform certain work as a TPO without further Coast Guard approval.

Summary Table of Classification Society Subchapter M Functions

Commercial Vessel Inspection Alternatives and Delegated Functions

Coast Guard (TVNCOE) Approved TPOs

Organizations other than recognized and/or authorized classification societies that conduct TPO functions for towing vessels must be Coast Guard approved.

    Summary Table of Coast Guard Approved TPOs Subchapter M Functions

How to be approved as a TPO

An organization seeking approval as a TPO under 46 CFR Subchapter M must at a minimum, submit an application package containing all the information listed in 46 CFR 139.120. The application package must be submitted to the Towing Vessel National Center of Expertise, which will review the information and determine if the organization meets the minimum standards for approval as a TPO. TPO approvals are granted for a period of five (5) years.

Application packages can be submitted to:

Towing Vessel National Center of Expertise
504 Broadway St. Suite 101
Paducah, KY 42001

TPO Guidance

Third-Party Organization (TPO) Guide
Towing Safety Management System (TSMS) Guide
Tips for Submitting TPO Applications for Approval
TPO Application Check Sheet