to implement an SMS. The ISM guidelines establish basic principles for verifying that a ship operator’s SMS complies with the ISM Code and for issuing and verifying a document of compliance (DOC). USCG implements and enforces the ISM Code for U.S.-flag vessels and for foreign-flag vessels entering U.S. ports and is authorized to board a vessel and to determine the existence of a valid DOC or safety management certificate.29 The U.S. regulations that implement the ISM Code are found in 33 CFR Part 96, and detailed guidelines for ISM Code enforcement with regard to foreign-flag vessels are contained in Navigation and Vessel Inspection Circular (NVIC) 04-05.30

Subchapter M, Inspection of Towing Vessels

A rule that applies to U.S.-flag vessels and that contains regulations for a comprehensive SMS has been proposed as 46 CFR Chapter I, Subchapter M, Inspection of Towing Vessels, Parts 136 to 144. The towing safety management system (TSMS) will include company and vessel compliance policies, vessel standards, and inspection procedures for new and existing towing vessels. The TSMS would allow companies flexibility in customizing their approach to meeting the rule’s requirements. The TSMS will provide an organized and reviewable document of a company’s health and safety policies and procedures and will describe how its vessels and employees would comply with all applicable requirements prescribed in this new subchapter, including lines of communication, emergency response procedures, contractor management, and management review procedures. A company’s existing SMS that is fully compliant with the ISM Code requirements, as found in 33 CFR Part 96, Rules for the Safe Operation of Vessels and Safety Management Systems, will be considered compliant with the proposed TSMS requirements.

To achieve compliance, a company must select one of two options. The first involves developing and implementing a TSMS and using a third-party auditor approved by USCG. The company has 2 years to create the TSMS and have the third party approve and issue a TSMS


29 See TRB 2012, pp. 35–36, for additional details about USCG enforcement of the ISM Code.

30 NVIC 04-05 cancels NVIC 04-98. See for more information.

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