Meridian’s Newest Service: Towing Vessel Safety Management System

Towing Vessel Safety Management System

January 3, 2018 – On June 20, 2016, the Coast Guard published Title 46 Code of Federal Regulations (CFR) Subchapter M – Towing Vessels. In complying with the new regulations, owners and managing operators have two options: (1) Towing Safety Management System (TSMS) Option, and (2) Coast Guard Option.

Regardless of which option an owner or operator chooses, Meridian is ready to assist with readiness assessment and compliance preparation. We can support the following activities:

  1. TSMS Development and Implementation
  2. Internal Audits
  3. Vessel Survey
  4. Incident Investigation
  5. Management Review Support
  6. Designated Person

To order, please contact (808) 282-4981 or

Other Meridian Services and Products

Meridian.US Announces New Designated Person Services

Regulations, including International Safety Management Code and Towing Safety Management System, require a vessel operator to appoint Designated Person(s) that have the following responsibilities:
  • Ensuring the safety management system is implemented and continuously functions throughout management and the fleet.
  • Ensuring the safe operation of each vessel.
  • Providing a link between the Company and those on board.
  • Monitoring the safety and pollution-prevention aspects of the operation of each vessel and ensuring that adequate resources and shore-based support are applied, as required.
For companies looking for highly experienced contractors to supplement their staff, has senior-level personnel who can serve effectively as Designated Person(s).
For more information on Meridian’s Designated Person services, please contact Captain Hung Nguyen at (808) 282-4981 or

Subchapter M: Addressing the New Towboat Standards

The final rule requiring Towing vessels to meet specific regulatory requirements under Title 46, Code of Federal Regulations, Subchapter M, was published in June of 2016, and at we are dedicated to helping you both understand and execute the new rules.  

The new regulation applies to all companies with towing vessels greater than 26 feet, as well as those under 26 feet moving barges carrying oil or hazardous materials.  According to the U.S. Coast Guard, a fully implemented Towing Safety Management System (TSMS) establishes a comprehensive quality control system throughout the company, which increases the safety and efficiency of all towing vessel operations. Across the maritime industry, vessel operators have told the Coast Guard that a proper TSMS increases safety while cutting overall operating costs. A proper TSMS will reduce accidents and equipment failures, and decrease or possibly completely undo delays.


Two options for towboat companies

The Coast Guard essentially gives towboat companies two options: either implement a safety management system or be inspected annually by the Coast Guard.

The benefits to implementing a TSMS are:

  • Greater flexibility in scheduling required surveys and audits,
  • Less vessel downtime,
  • No requirement for USCG presence for drydock and internal exams,
  • Greater flexibility in correcting discrepancies, and
  • Significantly less USCG intrusion on operations.


For those companies choosing the USCG inspection route, Coast Guard inspectors will visit the vessel at least annually and in some cases more frequently, possibly stopping operations until a Coast Guard inspector can visit the vessel.

The new rule will not apply to all towing vessels in your fleet all at once—there are specific phase-in requirements for the TSMS program. But regardless of the route your company decides to take, each towing vessel will eventually be required to have on board a Certificate of Inspection (COI).

For companies with more than one tow vessel:

  • By July 22, 2019, at least 25 percent of the towing vessels must have valid COIs on board;
  • By July 20, 2020, at least 50 percent of the towing vessels must have valid COIs on board;
  • By July 19, 2021, at least 75 percent of the towing vessels must have valid COIs on board; and
  • By July 19, 2022, 100 percent of the towing vessels must have valid COIs on board.
  • All owners or managing operators of only one existing towing vessel required to have a COI by this subchapter must ensure the vessel has an onboard, valid COI by July 20, 2020.


How opting for a TSMS can help your towing company

There are two aspects to a TSMS: Surveys and Audits. Surveys are the actual inspection of a ship’s systems, e.g., show me your emergency fire pump is properly installed. Surveys by companies using a TSMS (as opposed to the opting for the annual Coast Guard inspections) may be conducted by either someone in the towboat company or a Third-Party Organization (TPO). Audits focus on whether companies are following the processes and procedures of their TSMS.

Key take away – do not use the term “inspection” instead of “survey” when speaking with people in the industry—“survey” is a term of art in the towing vessel world.

Any TSMS must be compliant with the ISO 9001:2000 or ISO 9001:2008 standard. Reportedly, the Coast Guard will also consider approving standard like ISO 9001.


Where we come in is offering the Audit and Survey programs as a service to our clients. Meridian will provide the highest levels of service at reasonable rates to ensure our clients receive the most for their money.  Meridian is a fully compliant third-party organization approved by the U.S. Coast Guard. Meridian is compliant with ISO 9001:2015 and ISO 28001:2015 standards as well as OSHA safe work practices.

Navigating federal rules and regulations can be one of the most difficult aspects of your job, let help you through the compliance process. Please contact at (251) 345-6776 or