46 CFR 138.310: Internal audits for a TSMS certificate

Last reviewed: October 14, 2026

This section requires owners or managing operators to run internal management audits of their TSMS every year. The audits must reach all levels of the organization and all towing vessels to which a TSMS applies. The section also sets records rules and qualifications for internal auditors.

Applies toOwners or managing operators who hold a TSMS certificate and their towing vessels to which a TSMS applies.

What it says

  1. Internal management audits must be conducted annually, within 3 months of the anniversary date of the TSMS certificate, to ensure the owner or managing operator is effectively implementing all elements of their TSMS.

    46 CFR 138.310(a)“Internal management audits must be conducted annually, within 3 months of the anniversary date of the TSMS certificate”
  2. The internal management audit must ensure that management has implemented the TSMS throughout all levels of the organization.

    46 CFR 138.310(b)“must ensure that management has implemented the TSMS throughout all levels of the organization”
  3. The audit must include all of the owner or managing operator's towing vessels to which a TSMS applies, to ensure implementation at the operational level.

    46 CFR 138.310(b)“including audits of all the owner or managing operator's towing vessels to which a TSMS applies to ensure implementation at the operational level”
  4. The results of internal audits must be documented, kept for 5 years, and made available to the Coast Guard upon request.

    46 CFR 138.310(c)“The results of internal audits must be documented and maintained for a period of 5 years and made available to the Coast Guard upon request.”
  5. Internal auditors must have knowledge of the management, its SMS, and the standards contained in this subchapter.

    46 CFR 138.310(d)(1)“Must have knowledge of the management, its SMS, and the standards contained in this subchapter;”
  6. Internal auditors must have completed an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) internal auditor/assessor course or a Coast Guard-recognized equivalent. The text refers to § 136.112 of this subchapter for incorporation by reference.

    46 CFR 138.310(d)(2)“Must have completed an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) (incorporated by reference, see § 136.112 of this subchapter) internal auditor/assessor course or Coast Guard-recognized equivalent;”
  7. Internal auditors may not be the designated person, or any other person in the organization, who is responsible for development or implementation of the TSMS.

    46 CFR 138.310(d)(3)“May not be the designated person, or any other person, within the organization that is responsible for development or implementation of the TSMS; and”
  8. Internal auditors must be independent of the procedures being audited, unless this is impracticable due to the size and the nature of the organization.

    46 CFR 138.310(d)(4)“Must be independent of the procedures being audited, unless this is impracticable due to the size and the nature of the organization.”

Common questions

How often must a TSMS internal audit be done?

Internal management audits must be conducted annually. They must take place within 3 months of the anniversary date of the TSMS certificate.

“Internal management audits must be conducted annually, within 3 months of the anniversary date of the TSMS certificate”

How long must TSMS internal audit records be kept?

The results must be documented and kept for 5 years. They must be made available to the Coast Guard upon request.

“The results of internal audits must be documented and maintained for a period of 5 years and made available to the Coast Guard upon request.”

Can the person who developed the TSMS be the internal auditor?

No. An internal auditor may not be the designated person, or any other person in the organization, who is responsible for development or implementation of the TSMS.

“May not be the designated person, or any other person, within the organization that is responsible for development or implementation of the TSMS; and”

Does an internal auditor have to be independent of what is audited?

Yes, an internal auditor must be independent of the procedures being audited. The exception is when this is impracticable due to the size and the nature of the organization.

“Must be independent of the procedures being audited, unless this is impracticable due to the size and the nature of the organization.”

The text of 46 CFR 138.310

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

Internal audits for a TSMS certificate

(a) Internal management audits must be conducted annually, within 3 months of the anniversary date of the TSMS certificate, to ensure the owner or managing operator is effectively implementing all elements of their TSMS.

(b) The internal management audit must ensure that management has implemented the TSMS throughout all levels of the organization, including audits of all the owner or managing operator's towing vessels to which a TSMS applies to ensure implementation at the operational level.

(c) The results of internal audits must be documented and maintained for a period of 5 years and made available to the Coast Guard upon request.

(d) Internal auditors:

(1) Must have knowledge of the management, its SMS, and the standards contained in this subchapter;

(2) Must have completed an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) (incorporated by reference, see § 136.112 of this subchapter) internal auditor/assessor course or Coast Guard-recognized equivalent;

(3) May not be the designated person, or any other person, within the organization that is responsible for development or implementation of the TSMS; and

(4) Must be independent of the procedures being audited, unless this is impracticable due to the size and the nature of the organization.

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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.