46 CFR 138.210: Objectives of a towing safety management system

Last reviewed: October 14, 2026

This section sets out the objectives a TSMS must meet through its policies, procedures, and documentation. They cover management responsibility, document control, selection of third parties, recordkeeping, training, and resources.

What it says

  1. Management must demonstrate that it implemented the TSMS policies and procedures and that the entire organization adheres to its safety management program.

    46 CFR 138.210(a)“The management must demonstrate that they implemented the policies and procedures as contained in the TSMS and the entire organization is adhering to their safety management program.”

  2. A TSMS must describe and document the owner or managing operator's organizational structure, responsibilities, procedures, and resources which ensure quality monitoring.

    46 CFR 138.210(b)“A TSMS must describe and document the owner or managing operator's organizational structure, responsibilities, procedures, and resources which ensure quality monitoring.”

  3. The TSMS must clearly identify which types of documents and data are controlled and who is responsible for controlling activities, including approval, issue, distribution, modification, and removal of obsolete materials.

    46 CFR 138.210(c)“There must be clear identification of what types of documents and data are to be controlled, and who is responsible for controlling activities, including approval, issue, distribution, modification, removal of obsolete materials, and other related administrative functions.”

  4. Procedures for selecting TPOs must exist and must include how third parties are evaluated, including selection criteria.

    46 CFR 138.210(d)“Procedures for selection of TPOs must exist that include how third parties are evaluated, including selection criteria.”

  5. Records must be maintained to demonstrate effective implementation of the TSMS.

    46 CFR 138.210(e)“Records must be maintained to demonstrate effective implementation of the TSMS.”

  6. The owner or operator must establish and maintain documented procedures for identifying training needs and providing training.

    46 CFR 138.210(f)“The owner or operator must establish and maintain documented procedures for identifying training needs and providing training.”

  7. The TSMS must identify adequate resources and procedures necessary to comply with the TSMS.

    46 CFR 138.210(g)“Identify adequate resources and procedures necessary to comply with the TSMS.”

Common questions

What records must a TSMS include?

Records must demonstrate effective implementation of the TSMS. They must include audit records, non-conformity reports and corrective actions, auditor qualifications, auditor training, and other records as considered necessary.

“This must include audit records, non-conformity reports and corrective actions, auditor qualifications, auditor training, and other records as considered necessary.”

Who is responsible for TSMS training procedures?

The owner or operator must establish and maintain documented procedures for identifying training needs and providing training.

“The owner or operator must establish and maintain documented procedures for identifying training needs and providing training.”

Does a TSMS need procedures for choosing third parties?

Yes. Procedures for selection of TPOs must exist, and they must include how third parties are evaluated, including selection criteria.

“Procedures for selection of TPOs must exist that include how third parties are evaluated, including selection criteria.”

The text of 46 CFR 138.210

Electronic Code of Federal Regulations (eCFR), current as of April 16, 2026 · Read it on eCFR

Objectives of a TSMS

The TSMS, through policies, procedures, and documentation, must:

(a) Demonstrate management responsibility. The management must demonstrate that they implemented the policies and procedures as contained in the TSMS and the entire organization is adhering to their safety management program.

(b) Document management procedures. A TSMS must describe and document the owner or managing operator's organizational structure, responsibilities, procedures, and resources which ensure quality monitoring.

(c) Ensure document and data control. There must be clear identification of what types of documents and data are to be controlled, and who is responsible for controlling activities, including approval, issue, distribution, modification, removal of obsolete materials, and other related administrative functions.

(d) Provide a process and criteria for selection of third parties. Procedures for selection of TPOs must exist that include how third parties are evaluated, including selection criteria.

(e) Establish a system of recordkeeping. Records must be maintained to demonstrate effective implementation of the TSMS. This must include audit records, non-conformity reports and corrective actions, auditor qualifications, auditor training, and other records as considered necessary.

(f) Identify and meet training needs. The owner or operator must establish and maintain documented procedures for identifying training needs and providing training.

(g) Ensure adequate resources. Identify adequate resources and procedures necessary to comply with the TSMS.

The plain-English explanation on this page was written with AI from the regulation text above and checked automatically before publishing: every quote appears in the text, every number comes from it, and a second model confirmed each statement adds nothing the text doesn't say. Regulation text current as of April 16, 2026. The regulation text governs. RegKnot is not affiliated with the U.S. Coast Guard.