46 CFR 139.130: Qualifications of auditors and surveyors

Last reviewed: October 14, 2026

This section sets the qualifications for prospective auditors and surveyors. Both must have the skills and experience to assess compliance with all requirements of this subchapter. It then lists specific education, experience and training requirements for auditors and for surveyors.

Applies toThis section applies to prospective auditors and surveyors.

What it says

  1. A prospective auditor or surveyor must have the skills and experience necessary to assess compliance with all requirements of this subchapter.

    46 CFR 139.130(a)“A prospective auditor or surveyor must have the skills and experience necessary to assess compliance with all requirements of this subchapter.”

  2. Auditors must have four years of working on towing vessels or other relevant marine experience, such as Coast Guard marine inspector, licensed mariner, military personnel with relevant maritime experience, or marine surveyor.

    46 CFR 139.130(b)(2)“Four years of working on towing vessels or other relevant marine experience such as Coast Guard marine inspector, licensed mariner, military personnel with relevant maritime experience, or marine surveyor.”

  3. Auditors must successfully complete a lead auditor/assessor course under ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E), or a Coast Guard recognized equivalent. The text incorporates these standards by reference and refers the reader to § 136.112 of this subchapter.

    46 CFR 139.130(b)(3)“Successful completion of an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) (incorporated by reference, see § 136.112 of this subchapter) lead auditor/assessor course or Coast Guard recognized equivalent.”

  4. Auditors must successfully complete a training course for the auditing of a TSMS.

    46 CFR 139.130(b)(4)“Successful completion of a training course for the auditing of a TSMS.”

  5. Auditors may show audit experience through documented ISM Code or American Waterways Operators Responsible Carrier Program auditing, consisting of at least two management audits and six vessel audits within the past 5 years.

    46 CFR 139.130(b)(5)(i)“Documented experience in auditing the ISM Code or the American Waterways Operators Responsible Carrier Program, consisting of at least two management audits and six vessel audits within the past 5 years; or”

  6. Auditors may instead show audit experience by completing an apprenticeship of at least one management audit and three vessel audits under the direction of a lead auditor.

    46 CFR 139.130(b)(5)(ii)“Successful completion of an auditor apprenticeship, consisting of at least one management audit and three vessel audits under the direction of a lead auditor.”

  7. Surveyors must have a high school diploma or equivalent.

    46 CFR 139.130(c)“Surveyors must meet the following qualifications:”

  8. Surveyors must have four years of experience working on towing vessels as master, mate (pilot), or engineer, or other relevant marine experience as the text describes.

    46 CFR 139.130(c)(2)(i)“Four years of experience working on towing vessels as master, mate (pilot), or engineer; or”

Common questions

What experience does a towing vessel auditor need?

An auditor must have four years of working on towing vessels or other relevant marine experience. An auditor must also show audit experience through documented audits or an apprenticeship.

“Four years of working on towing vessels or other relevant marine experience such as Coast Guard marine inspector, licensed mariner, military personnel with relevant maritime experience, or marine surveyor.”

How can an auditor show audit experience?

An auditor may show documented ISM Code or Responsible Carrier Program auditing of at least two management audits and six vessel audits within the past 5 years. An auditor may instead complete an apprenticeship of at least one management audit and three vessel audits under a lead auditor.

“Successful completion of an auditor apprenticeship, consisting of at least one management audit and three vessel audits under the direction of a lead auditor.”

What experience does a surveyor need under Subchapter M?

A surveyor must have at least one of two kinds of experience: four years working on towing vessels as master, mate (pilot), or engineer, or other relevant marine experience.

“Four years of experience working on towing vessels as master, mate (pilot), or engineer; or”

Does an auditor need training in auditing a TSMS?

Yes. An auditor must successfully complete a training course for the auditing of a TSMS.

“Successful completion of a training course for the auditing of a TSMS.”

The text of 46 CFR 139.130

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

Qualifications of auditors and surveyors

(a) A prospective auditor or surveyor must have the skills and experience necessary to assess compliance with all requirements of this subchapter.

(b) Auditors must meet the following qualifications:

(1) High school diploma or equivalent.

(2) Four years of working on towing vessels or other relevant marine experience such as Coast Guard marine inspector, licensed mariner, military personnel with relevant maritime experience, or marine surveyor.

(3) Successful completion of an ANSI/ISO/ASQ Q9001-2000 or ISO 9001:2008(E) (incorporated by reference, see § 136.112 of this subchapter) lead auditor/assessor course or Coast Guard recognized equivalent.

(4) Successful completion of a training course for the auditing of a TSMS.

(5) Audit experience, as demonstrated by:

(i) Documented experience in auditing the ISM Code or the American Waterways Operators Responsible Carrier Program, consisting of at least two management audits and six vessel audits within the past 5 years; or

(ii) Successful completion of an auditor apprenticeship, consisting of at least one management audit and three vessel audits under the direction of a lead auditor.

(c) Surveyors must meet the following qualifications:

(1) High school diploma or equivalent.

(2) At least one of the following:

(i) Four years of experience working on towing vessels as master, mate (pilot), or engineer; or

(ii) Other relevant marine experience such as Coast Guard marine inspector, military personnel with relevant maritime experience, marine surveyor, accredited marine surveyor, experience on vessels of similar operating and physical characteristics.

Sections it refers to

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.