Annual or Initial Surveys
Work with EDT to complete your Subchapter M surveys or audit your surveys.
Independent, Objective Surveys
The most useful aspect of Third Party Organizations (TPO) to a towing vessel operator is the opportunity to provide independent, unbiased survey of towing vessels in your fleet. While inspectors from your local Office(r) in Charge of Marine Inspections (OCMI) can provide this service directly for the USCG, as the number of towing vessels subject to Subchapter M increases, the workload on the USCG inspectors will also. TPO surveyors allow flexibility to the operator to choose the date of survey, rather than struggling to find an available date with the USCG.
TSMS Option Surveys
The ‘TSMS Option’ allows for two ways an operator can satisfy the inspection criteria of Subchapter M given in Part 137: external or internal surveys. These do not refer to the extent of survey (outside versus inside); rather, they describe who carries out the survey – a TPO or internally by qualified employees/contractors of the operator. Using internal resources may sound attractive to an operator – however, care must be exercised with this option.
The ‘TSMS Option’ with internal survey may use employees of the operator or hired external contractors. In either case, sections 137.130 and 137.210 have very specific requirements the operator must plan for:
- The TSMS must be specific in addressing the degree of survey, tests to be carried out, methods and procedures for non-conforming results and their corrective actions, identification of the persons in the organization with the power to prevent towing vessel operation (in cases of serious deficiencies), and identification of the experience required to conduct the survey.
- An internal survey program would need to be created and presented to the OCMI prior to acceptance of an internal survey
- Identification of the persons conducting the internal survey
- The qualifications of the persons conducting the internal survey
- TPO oversight of the internal survey
Internal Survey Advantages
The major advantage of the internal survey method of the ‘TSMS Option’ is the ability for the operator to make the survey a ‘continuous’ survey, where the elements of the internal survey program are evaluated over a year, as long as all elements are evaluated at least once in each yearly cycle. Using an internal survey method will still require the operator to contract with a TPO (or equivalent organization such as a Class Society) to audit the surveys, ensuring all elements of the survey as given in 46 CFR 137.220 have been evaluated. The TPO would then endorse the survey report to the USCG.
External Survey Advantages
Even the internal survey option will involve a TPO to audit the internal survey – some type of spot-check to ensure the survey was done properly and covered all aspects of the survey programs of Part 137 – an operator needs to have a TPO engaged. Should the TPO uncover discrepancies between the survey report and the audit condition, a full survey by the TPO may be warranted.
With the external survey option, the TPO is responsible for the survey of the towing vessel. This can be advantageous in many ways – one, it places the responsibility of finding qualified surveyors on the TPO, who can then be a resource for the operator, and two, it transfers the responsibility of conducting the reporting on the towing vessel condition to the TPO, who is then audited by the USCG. It should be noted that the USCG has accepted the qualifications of the TPO’s personnel as part of the TPO approval program in Part 139 of Subchapter M; there is no question that the USCG will accept the TPO’s personnel qualifications.
Other Survey Requirements
EDT can also perform Dry-Dock Surveys and UWILD Surveys for your fleet. Learn more about how we can help you comply with Subchapter M.