Subchapter M Compliance

We have deep understanding of towing vessel construction and safe operation, and our engineers can adapt to your schedule and provide a timely, unbiased review.

Towing Vessel Safety Services

What is Subchapter M? 

Subchapter M is a part of the Code of Federal Regulations (CFR), Title 46 (Shipping), Chapter I, Parts 136 to 144. The intent of Subchapter M is to provide a unified basis to inspect towing vessels – tugboats – which had previously not been required to be regularly inspected by the United States Coast Guard (USCG). Subchapter M applies to most towing vessels and became effective July 20, 2018.  

EDT TPO Services 

As a Subchapter M third party organization (TPO), EDT is authorized to offer a range of services to help towing vessels comply with Subchapter M. 

  • Towing Safety Management System (TSMS) certificates
  • TSMS audits
  • Towing vessel initial surveys and annual surveys
  • Towing vessel dry-dock surveys and UWILD surveys
  • Reporting of towing vessel surveys
  • Plan review

EDT Reviews & Audits

Each surveyor from EDT is a registered professional engineer or a seasoned ship surveyor. Our surveyors have the ability to interpret your towing vessel’s unique compliance with the requirements of Subchapter M and can make reasonable judgments of equivalence. 

Each auditor with EDT is a Lead Auditor for management systems and has been trained under either the International Safety Management (ISM) Code or the Towing Vessel Safety Management System (TSMS).

TSMS Certification 

EDT consultants, when reviewing your TSMS and auditing against the requirements of Subchapter M, will validate your Safety Management System against Parts 138, 140, and 144 as applicable to your fleet.  Our consultants have years of experience auditing companies and vessels to the ISM Code or the AWO Responsible Carrier Program (RCP) and will apply their experience to ensure your TSMS is fully compliance with Subchapter M.  For companies with existing ISM Code DOC/SMC or RCP, EDT will use that framework and provide a ‘gap analysis’ prior to the audit to ensure the provisions of Subchapter M are included in your SMS.

Work with Us

Have questions about Subchapter M and the TSMS option? Our lead marine engineers are located in our EDT Oakland and EDT Seattle offices, and we also have licensed engineers across the U.S. that you can rely on. Connect with EDT today.

Certificates, Auditing, and Surveying

Our experienced marine engineers help inland, coastal, and ocean fleets comply with Subchapter M and the TSMS Option. Connect with us to work with a reliable Subchapter M TPO.

Reach us 24 hours a day with your questions.