Has it been a success? If success is measured by Certificates of Inspection, then yes. Roughly four- fifths of the towing vessels that were afloat in July 2018 have their COIs. But the remaining 20% do not. In some cases, the boats weren’t physically able to pass the test and that is a huge measure of success. We don’t have to worry about the crew members on those boats and the danger to the environment that many of them posed.
On the other hand, some didn’t make it because the owners simply had enough of government regulation and sold the boats to those better positioned to comply. Or, they just scrapped the boats. By and large, these boats weren’t the pride of anyone’s fleet, but they worked. It has been sad to watch companies fold because of the one-size fits all approach to compliance of the USCG. We worked with the owner of a three-boat company in the northeast that one day just threw the towel in. The boats were good, had even gotten their COIs, the crews were exceptional, but the owner didn’t want (or need) the USCG in his face.
Measuring Success: A Moving Target
The second track, the USCG option, should not exist if the safety of mariners and the environment is what we are trying to achieve. For example, the vessels are required to have a Health & Safety Plan on board. This is a subset of policies and procedures that make up a TSMS. My company attends roughly 265 USCG Option inspections per year. Since 2018, I have only witnessed one marine inspector looking into the Health & Safety Plan. He asked the crew general questions about the plan and then moved on to recordkeeping. Otherwise, the inspectors are blissfully unaware of the Health & Safety Plan. It is a fair question to ask: If the inspectors don’t care, why should the crew?
Success is also hard to measure when you have two tracks to compliance. I believe that the companies that went the TSMS route initially – and really embraced it – are safer. But employee retention makes a fully developed safety culture a challenge for even the best companies.
The crews and shoreside personnel at a TSMS Option company are trained on the TSMS and audited annually. There are consequences for failing to understand the TSMS. It can mean the boat will be tied to the dock by the TPO that has oversight. Even the USCG gets in on the act and can remove a company’s TSMS Certificate if they find systemic issues. The loss of a TSMS certificate at a five-boat company can mean the loss of employment for about 60 people until the boats can be re-inspected as USCG Option boats.
That inspection is a deep dive into the boat’s systems and a quick look at recordkeeping. But that’s it. The USCG inspectors are not trained or qualified to audit a Health & Safety Plan, so it never gets done.
Decoding the Language of Inspections Acronym COI
TSMS TPO
USCG BM USCG MK
CFR 835
DD/ISE TVNCOE
OCMI NMC MMC
Source: Pat Folan 90 | ISSUE 111 | MAR 2025 | THE REPORT Full meaning: Certificate of Inspection
Towing Safety Management System Third Party Organization
U.S. Coast Guard Bosun’s Mate U.S. Coast Guard Machinery Technician
Code of Federal Regulations CG-835 -Form used by USCG Marine Inspectors to document deficiencies. Drydock / Internal Structural Exam U.S. Coast Guard Towing Vessel National Center of Expertise
Officer in Charge, Marine Inspection
U.S. Coast Guard National Maritime Center U.S. Coast Guard Merchant Mariner Credential
The USCG created two classes of vessel companies. One that only has to survive selective scrutiny by USCG inspectors and one that must undergo audits and surveys with third party auditors and the USCG inspectors. And if you doubt the selective scrutiny part, just watch an inspection where a USCG BM has to inspect the machinery space, or an MK has to inspect the wheelhouse and navigational equipment.
The USCG has no way to provide consistency within its inspections. It can’t do it well within a single unit and, arguably, it fails across most sectors.
After six years, everyone with a vessel knows where to go with the boat for an easy inspection. This is reminiscent of the ‘venue shopping’ done by mariners in the years prior to the consolidation of some responsibilities at Coast Guard regional exam centers into a central office in West Virginia. Driving up and down the east coast, mariners could hit four or five REC’s until they got the answer that they wanted on a license examination or renewal.
By easy; I mean fair and fast. There is nothing worse for the owner and crew than to have the government van pull up and four or five blue suiters pile out with the CFR books. At that point you know that the boat won’t be making any money that day. Most crews know that they must split up and follow the inspectors around the boat. And the good crews know to argue with some of the findings. Not all deficiencies are from the correct Subchapter.
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