🔍 Key Concepts

• 46 CFR Subchapter M requirements for towing vessels • What a Towing Safety Management System (TSMS) actually covers (the organization vs. the physical vessel) • Who is responsible for implementing and maintaining the safety management system

💭 Think About

• Ask yourself: Is a management system more closely tied to a person, a company, or a specific hull? • Think about who has overall responsibility for safety policies, procedures, and audits across a fleet of towing vessels. • Consider whether the Coast Guard wants this certificate to follow an individual mariner, a single boat, or the company that manages multiple boats.

✅ Before You Answer

• Verify in 46 CFR Subchapter M, Part 138 who is required to have a TSMS and who must comply with it. • Check whether the certificate is vessel-specific or tied to the operator/management organization. • Confirm which party (vessel, master, or company) is described as being responsible for implementing and maintaining the TSMS.