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 Third Party Organizations

Third Party Organizations (TPO) approved by the Coast Guard Towing Vessel NCOE (TVNCOE) are authorized to perform the functions listed in 139.115.  Towing vessels intending on complying with the requirements found in Subchapter M by utilizing the Towing Safety Management System (TSMS) compliance option must obtain and maintain a TSMS Certificate from a TPO.  Recognized and Authorized Class Societies are authorized under 139.110 to perform the work as a TPO without having to submit an application for approval.

The CG is responsible for the oversight of CG approved TPOs under Subchapter M as well as Recognized and Authorized Class Societies performing work related to Subchapter M.

Items to check:

  • TPO approval letter from CG TVNCOE
  • TPO conformance with internal Quality Management System (QMS)
  • TPO retained list of current and former auditors and surveyors
  • Results of audits submitted to the TVNCOE
  • Results of vessel/management audits and reports of surveys conducted
  • Records of complaints regarding TPO
  • MISLE history of vessels operating under a valid TSMS
  • Results of TPO assessments conducted by the CG

Regulatory Cites:

46 CFR Part 8  Vessel Inspection Alternatives
46 CFR 139.115 General
46 CFR 139.120 Application for approval as TPO
46 CFR 139.130 Qualifications of auditors and surveyors
46 CFR 139.135 Addition and removal of auditors and surveyors
46 CFR 139.165 Documentation

Additional Guidance:

CVC Policy Letter 17-04 CH 2 Subchapter M Third Party Organization (TPO) Guidance
CVC Work Instruction WI-005 – Request for Recognized Organization (RO) Internal QMS Review – “Quality Case”
CVC Work Instruction WI-008 - Vertical Contract Audits
Part 139 FAQs

 Towing Safety Management Systems

The purpose of a Towing Safety Management System (TSMS) is to establish policies, procedures, and required documentation to ensure the owner or managing operator meets its established goals while ensuring continuous compliance with all regulatory requirements. Towing vessels utilizing the TSMS compliance option must be associated with a TSMS Certificate, issued by an approved Third Party Organization (TPO), and complete scheduled surveys and audits to verify compliance.

Items to check:

  • Valid TSMS Certificate (or copy on board vessel)
  • Verify applicable policies and procedures are available to the crew
  • Crew knowledge of TSMS, ability to respond to emergencies
  • Master’s annual review of TSMS
  • Completion of required audits
  • Results of audits and corrective action process completion

Regulatory Cites:

46 CFR 138.210 Objectives of a TSMS
46 CFR 138.215 Functional requirements of a TSMS
46 CFR 138.220 TSMS elements
46 CFR 138.310 Internal audits for a TSMS certificate
46 CFR 138.315 External audits for a TSMS certificate
46 CFR 138.405 Conduct of internal audits
46 CFR 138.410 Conduct of external audits
46 CFR 138.505 Submittal of external audit results

Additional Information:

CG-CVC Policy Letter 17-02 Use of Existing Safety Management Systems to Obtain an Initial Certificate of Inspection
Part 138 FAQs
CVC Work Instruction WI-003 – USCG Oversight of SMSs on U.S. Flag Vessels