03 Jun 2020
Peter Rowand
Marketing and Business Development


USCG vessel image

Deciding whether to use the US Coast Guard (USCG) or hiring a third-party organization (TPO) for your certificate of inspection (COI) can be difficult. You must ensure that you’re staying compliant with Sub Chapter M regulations, but which option is the best way to do that for your company? The good news is that you don’t have to make this decision alone. We’re here for you with some great resources to help you decide which option is the right fit for you. Let’s get to it!

Our partners, Tug and Barge Solutions, have put this video together to help make your decision easier. In the video, they outline the similarities and differences between the USCG and the TPO option, and discuss the pros and cons of each.


Here’s a summary of what the video covers.


USCG Option:

The USCG will come out on an annual basis and use their towing vessel inspection checklist on your vessel. With the USCG option, companies are not required to have a formal SMS; they only need to have their own Health and Safety Plan. However, companies who choose the USCG option must still maintain proper documentation showing that they have the proper policies and procedures in place to be compliant, so some companies who use this option still choose to make their own SMS.


  1. Benefits good operators. If you’re a good operator with good equipment, you shouldn’t be worried about having the USCG onboard
  2. Final say. The USCG has the final say, so if they like what they see you’re good to go.
  3. Less work is required. The minimum requirement is to build a Health and Safety plan, which is much easier and requires less time commitment than a full TSMS.


  1. Inspectors change and transfer. Inspectors change every three years, so you’ll have to get used to new people.
  2. No consistency. There is no consistency between inspectors, and they all drill into something different.
  3. Not granted permits to proceed. A USCG option boat is stuck with what they tell you to do.
  4. Most non-conformities are considered no sail items. If non-conformities are identified, you’re often not allowed to operate.


TPO Option

Companies who choose the TPO option must write and implement a towing safety management system (TSMS) and hire a TPO to conduct its vessel inspections. TPOs are certified by the coast guard to inspect the vessel and ensure that it follows Sub M regulations.


  1. Operate more safely and efficiently. Having a set of policies and procedures defining how you work and holding you to certain standards will help your company improve.
  2. Add structure to your operations. A TSMS will add structure to your operations and increases consistency.
  3. Greater flexibility. With the TSMS option you’re granted greater flexibility to complete required surveys and audits.
  4. No USCG attendance. TSMS vessels are not subjected to mandatory USCG attendance for dry dock or internal structural exams.
  5. Permit to proceed. Having a TSMS allows you to proceed to another port for repairs if certain conditions are met.
  6. Identify and fix non-conformities. A TSMS allows you to identify non-conformities and create corrective actions while continuing to operate.


  1. Higher Cost. TPOs are businesses and their services are not free.
  2. Time Commitment. It will take time to learn the TSMS and how to be audited.
  3. Complexity of a TSMS. A TSMS is much more complex compared to a Health and Safety Plan.
  4. Size of a TSMS. A Health and Safety Plan is only a small part of a TSMS, so it will take much more work to put together a TSMS.


Still need help deciding? We have two blog posts that go into detail about each option. Read more about the USCG option here and the TPO option here.

Thanks again to our partners Tug and Barge Solutions for this video. We hope it helps!