In Advance Of Sub M, Coast Guard Suspends Random Audits Until 2022

As a key deadline for Subchapter M draws near this July, the latest item of concern for the towing industry is the possibility of random audits.

The Coast Guard had previously said that vessels covered by a Towing Safety Management System (TSMS) Certificate could be selected for random audits during the five-year period of the certificate’s validity.

In a February 1 letter to AWO members, regulator affairs director Caitlyn Stewart said, “Both AWO and our RCP [Responsible Carrier Program] auditing partners have expressed concern about this requirement, which is at odds with the RCP and ISM [International Ship Management] Code requirement for external vessel audits to be conducted on a fixed five-year schedule, and which does not add value to vessel safety and compliance.”

Evidently the Coast Guard listened. It released a policy letter dated January 25, CG-CVC Policy Letter 18-01, that clarified that “no random external vessel audits will be required during the COI phase-in period, which ends July 20, 2022.”

The policy letter said it is “more reasonable and practicable” to begin randomly selecting vessels for external audits after all vessels are certificated.

While the AWO welcomed this temporary fix, it reminded members that “AWO will continue to advocate for the elimination of the requirement for external vessel audits to be conducted randomly in the future, so that companies that choose the TSMS option can keep their vessels on their current external audit schedules.”