USCG Crackdown on TPO Inspections of Quality Management Systems

On March 31, 2020, the United States Coast Guard (USCG) updated CG-CVC Mission Management System Work Instructions CVC-WI-005(2) Request For Recognized Organization Internal Quality Management System Review – “Quality Case” to inform USCG Marine Inspectors to “evaluate situations where objective evidence indicates that a potential failure of a Recognized Organization (RO) or a Third Party Organization (TPO) under 46 CFR Subchapter M Quality Management System (QMS) resulted in the failure to adequately perform delegated functions under mandatory IMO instruments or national legislation and regulations on behalf of the Coast Guard.”

It further states that “delegated functions” is defined as synonymous with “statutory certification and services” as described in the RO Code and “approved functions” described in 46 CFR 139.115 for towing vessels subject to inspection under 46 CFR Subchapter M.

In cases where objective evidence of a potential failure or lack of effectiveness of an RO or TPO’s QMS has been found, a Quality Case may be utilized to request that the RO or TPO conduct an internal investigation or root cause analysis of their QMS.

Objective evidence may include:

  • Survey/audit reports
  • Condition of vessel and/or equipment subject to survey
  • Surveyor/auditor statements
  • Surveyor/auditor checklists/procedures
  • Other correspondence (email, notifications, letters, phone calls, etc.)
  • RO delegations (performing a delegated function that the RO did not have a delegation or authorization to perform)

TPOs assess whether towing vessels are in Subchapter M compliance with their Safety Management Systems. If the TPO does not comply with their QMS or the provisions of Subchapter M, their approvals may be suspended or revoked.

TPO delegated functions may include:

  • External surveys
  • External audits
  • Issuance of Safety Management System certificates
  • Oversight of internal audit program

Freer Consulting Co. can help your company be prepared to pass a USCG inspection regardless of the quality of their representative TPOs to take any worries of noncompliance out of the picture. Find out how by visiting our website here or calling us at 206-285-9044.