1. Subchapter M Third Party Organizations
Towing Vessel National Center of Expertise
11/16/2018

2. Precedents for Third Party Roles
Liferafts
Fire suppression systems
Fishing vessels
PE certifications
Plan review (ABS)
ACP
PSC/ISM code enforcement
TBSIP
OSVs…
Towing Vessel National Center of Expertise
11/16/2018

3. Approvals 139.115 (a)(1)-(5) Conduct TSMS audits
Issue TSMS Certificates
Conduct surveys
Issue survey reports
Approvals for 1 & 2, or 3 & 4, or 1-4.
Towing Vessel National Center of Expertise
11/16/2018

4. Application Contents
Organizational description (org chart, org history, etc.)
Description of clientele and general work history (3 years)
Quality management system (ISO 9001 or equivalent)
Procedures for audits and most recent internal audit
Conflicts of interest prevention procedures & code of ethics
Checklists, forms and job aids to be used
List of auditors/surveyors including qualifications
Procedures for employee oversight & development
Resource allocation procedures
Authorization for CG visit
Disclosure of potential conflicts and affidavit to avoid/report
Towing Vessel National Center of Expertise
11/16/2018

5. Objective evidence External source
Example: QMS should be supported by external audit report or certification letter/certificate
Equivalencies requested/accompanied by evidence
ISO international standard for certification bodies conducting assessments of management systems
Towing Vessel National Center of Expertise
11/16/2018

6. Auditors and Surveyors
Identification
Listed by TPO
Meet minimum standards
Many backgrounds acceptable
Field assessment… Should be suitable for tasking at hand
Observation
Q & A
Towing Vessel National Center of Expertise
11/16/2018

7. CG Oversight Actions Conducting verifications (vessel compliance)
Requiring amendments to TSMS
Vessel audits and surveys(occasionally- based on need)
Order presence of TPO
MISLE:
Third Party Oversight activities
Third Party Operational Control activities )
Towing Vessel National Center of Expertise
11/16/2018

8. Internal Survey Program
Must be coordinated by a responsible person
Must have experience necessary to coordinate
Can oversee specialized personnel conducting surveys
Subcontractors are acceptable under internal program
Individuals not required to meet
Scope same as External program
No more than 1 year between exam dates
Results are audited by TPO overseeing program
Towing Vessel National Center of Expertise
11/16/2018

9. Records Retention Maintained for 5 years Audit/survey reports
Includes auditor/surveyor, results, etc.
Ongoing client CA/PA oversight
CG audit results
Towing Vessel National Center of Expertise
11/16/2018

10. Towing Vessel National Center of Expertise
11/16/2018

11. Questions?
Towing Vessel National Center of Expertise
11/16/2018