What’s a TSMS? 

A TSMS is a Towing Safety Management System.  The TSMS is a document that is customized to your company and details the safe and correct way to perform the duties both on the vessel and ashore. 


     The goal is safety and environmental protection.  Keep the crew safe, the equipment safe and functioning as designed and protect the waterways, land and air around the vessel.


     It boils down to risk assessment – something that each of us do daily and something that our mariner’s do as such a regular part of their jobs that it is second nature.  Risk assessments are conducted to estimate how much damage or injury can be expected from exposures to a given risk agent and to assist in judging whether these consequences are great enough to require increased management and/or regulation.


     So the TSMS starts out as a compilation of the assessed risks and how we deal with them.  It encompasses the what-if’s – what if we went aground, what would we do to minimize injury or death, damage to the equipment and damage to the environment.  It covers the procedures for safe use of equipment – deck machinery, tools, ladders, etc. 


     And it is built on a foundation of commitment.  The company commits to operating in a safe and environmentally aware way.  Roles and responsibilities are defined.  Authority of the Master is acknowledged.  A maintenance program is committed to so that equipment is not just run to failure, but rather maintained in a responsible, safe manner.


     And then, the whole system is checked both internally and externally and the results of the audits are used to improve the company.


     This is where Tug & Barge Solutions comes in.  We have developed TSMS’s for both coastal and inland companies.  We have not only assessed the companies that we work for, but also our own performance and we keep improving.  It’s never ending and we live for it.


     Tug & Barge Solutions’ TSMS is second to none.  We have had it vetted by two class societies and two TPOs and it meets Sub M, AWO RCP and the ISM Code.  We have used it for AWO RCP and it has come through with flying colors.  It has been through 5 AWO RCP audits in 2017 and 11 AWO RCP audits in 2016. And for the last two years we have been refining the Sub M policies, procedures and forms in the field.  Our customers make it usable and continually improve on its functionality.


Here’s part of what Sub M says a TSMS is:

138.200      Safety Management    


All towing vessels must be operated in compliance with an Owner/Managing Operator (O/MO) implemented TSMS or be subject to an annual USCG inspection regime.

138.205      Purpose of TSMS        

(a)TSMS establishes policies and procedures and required

     documentation to ensure the O/MO meets its established goals

     while ensuring continuous compliance with all regulatory


    The TSMS must contain a method to ensure all levels of the

    organization are working within the framework.

                   (b) A TSMS establishes and maintains:

                   (1) Management policies and procedures that serve as an

                          operational protocol for all levels within management

                   (2) Procedures to produce objective evidence that demonstrates

                          compliance with the requirements of this subchapter

                   (3) Procedures for an O/MO to self-evaluate that ensure it is

                          following its own policies and procedures and complies with

                          the requirements of this subchapter

                   (4) Arrangements for a periodic evaluation by an independent

                          third party to determine how well an O/MO and their towing

                          vessels are complying with their stated policies and

                          procedures and to verify that those policies and procedures

                          comply with the requirements of this subchapter, AND

                   (5) Procedures for correcting problems identified by

                          management personnel and third parties and facilitating

                          continuous improvement


138.210      Objectives of TSMS     

     The TSMS through policies, procedures and documentation MUST:


 (a) Demonstrate Management Responsibility.  The management must demonstrate that they implemented the policies and procedures as contained in the TSMS and the entire organization is adhering to their safety management program.

(b) Document Management Procedures.  A TSMS must describe and document the O/MO’s:

•        organizational structure

•        responsibilities

•        procedures

•        resources

which ensure quality monitoring

                   (c) Ensure Document & Data Control.  There must be a clear identification of what types of documents and data are to be controlled, and who is responsible for controlling activities, including:

•        Approval

•        Issue

•        Distribution

•        Modification

•        Removal of obsolete materials

•        Other related administrative functions

                   (d) Provide a process and criteria for the selection of third

                       parties.  Procedures for the selection of third parties must

                       exist that include:

•        How third parties are evaluated

•        Selection criteria

                   (e) Establish a System of Record-keeping.  Records must be

                       maintained to demonstrate effective operation of the

                       TSMS.  This should include:

•        Audit records

•        Non-conformity reports

•        Corrective Actions

•        Auditor qualifications

•        Auditor training

•        Other records as considered necessary

                   (f) Identify and Meet Training Needs.  Documented

                       procedures for identifying training needs and providing

                       training must be established and maintained.

                   (g) Ensure Adequate Resources.  Identify adequate resources

                        and procedures necessary to comply with the TSMS


138.215      Functional Requirements of TSMS

    The functional requirements of a TSMS include:

                   (a) Policies and procedures to provide direction for the safe

                       operation of the towing vessels and protection of the

                       environment in compliance with applicable US law,

                       including the CFR’s, and international laws where


                   (b) Defined levels of authority and lines of communication

                       between shoreside and vessel personnel.

                   (c) Procedures for reporting accidents and non-conformities

                   (d) Procedures to prepare for and respond to emergency

                        situations by shoreside and vessel personnel

                   (e) Procedures for verification of vessel compliance with this


                   (f) Procedures to manage contracted (vendor) safety services

                   (g) Procedures for internal auditing of the TSMS, including

                        shoreside and vessel

                   (h) Procedures for external audits

                   (i) Procedures for management review

                   (j) Process to evaluate recommendations made by

                       management personnel


138.220      TSMS Elements 


     The TSMS must include the following (non-applicable elements must be accompanied by documented justification that is subject to acceptance by the third party):

                   (a) Safety Management System Administration and

                       Management Organization.  A policy must be in place that

                       outlines the TSMS culture and how management intends

                       to ensure compliance with this subpart.  Supporting this

                       policy, the following procedures and documentation must

                       be included:

                   (1) Management Organization

                   (i) Responsibilities.  The management

                       organization, authority and responsibilities of


                   (ii) Designated Person. 

 (iii) Master Authority. Each O/MO must define the scope of the master’s authority. 

                   (2) Audit Procedures.

                   (i) Procedures for conducting internal and external

                       audits in accordance with 138.310 and 138.315

                       of this part

                   (ii) Procedures for identifying and correcting non-


                   (b) Personnel.  Policies must be in place that cover the O/MO’s

                        approach to managing its personnel, including, but not limited to:

•        Employment

•        Training

•        Health

•        Safety

Supporting these polices, the following procedures and documentation must be included:

                   (1) Employment Procedures. 

                   (2) Training of Personnel.  The TSMS must contain a policy related to

                           the training of personnel, including:

                   (i) New Hire Orientation

                   (ii) Duties associated with the execution of the TSMS

                   (iii) Execution of operational duties

                   (iv) Execution of emergency procedures

                   (v) Occupational health

                   (vi) Crew Safety AND

 (vii) Training required by this subchapter

                   (c) Verification of Vessel Compliance. Policies must be in place that

                           cover the O/MO’s approach for ensuring vessel compliance,

                           including but not limited to:

•        Maintenance and Survey

•        Safety

•        The environment

•        Security

•        Emergency preparedness

     Supporting these policies, the following procedures and

     documentation must be included:

                   (1) Maintenance and Survey.  Procedures outlining the O/MO’s

                          survey regime must specify all maintenance, examination and

                          survey requirements. ***Applicable documentation must be

                          maintained for all activities for a period of 5 years.

                   (2) Safety, Environment and Security.  Procedures must be in place to

                          ensure the safety of property, the environment and personnel.  This

                          must include procedures to ensure

•        the selection of the appropriate vessel,

•        including adequate maneuverability and


•        appropriate rigging and towing gear,

•        proper management of the navigational watch,

•        compliance with applicable security measures

                   (3) All procedures required by this subchapter must be

                           contained in the TSMS

                   (d) Compliance with Subchapter M.  Procedures and documentation

                          must be in place to ensure that each towing vessel complies with

                          the operational, equipment and personnel requirements of this


                   (e) Contracted (Vendor safety) Services.  Procedures must be in place

                          to ensure the safety, effective management and compliance with

                          applicable regulations for contracted vessel towing services,


                   (1) Procedures to evaluate personnel qualifications

                   (2) Procedures to evaluate adequacy of vessel capability,

                          condition and compliance with applicable regulations

                   (3) Compatibility of Safety Management Systems, AND

(4) Procedures to maintain objective evidence as required by both organization’s SMS’s.


138.225      Existing Safety Management Systems     


(a) A Safety Management System which is fully compliant with the ISM Code requirements of 33 CFR Part 96 will be deemed in compliance with these requirements

          (b) Other safety management systems may be considered for acceptance as

                meeting the TSMS requirements of this part. 



  • Inadequate Management Support

  • Inappropriate Scope

  • Inadequate Resources

  • Giving Up Early On

To see the Sub M Final Rule click here
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