Maritime Toar Assessments Marine Safety Services 2


What is a TOAR?

If you hold a USCG license, an endorsement is required to operate a Towing Vessels (NAVIC 3-16) states that a mariner may operate a towing vessel if, on or after 5/21/2006, and after any license transaction following any license upgrade or renewal, an officer operating towing vessels must hold any of the following licenses or endorsements:

  • Master of Towing Vessels.
  • Master of inspected self-propelled vessels greater than 200 GRT with a completed TOAR.
  • Mate (pilot) of towing vessel.
  • Mate of inspected self-propelled vessels greater than 200 GRT with a completed TOAR (limited to serving in the capacity of mate of towing).
  • Apprentice mate (steersman) under the direct supervision of a licensed officer (See visual flow chart).

Why should I hire Maritime Safety Management Services?

Maritime Safety Management Services will provide ​customized solutions ​ to all of your vessel’s operating requirements, including assisting you with compliance with all of Subchapter M regulations for ​YOUR towing vessel. Our highly professional staff has over 90 years of combined experience in the maritime industry, towing vessel industry, maritime training field, assessments, and U.S. Coast Guard and international inspection and surveys.

Is Maritime Safety Management Services a Third Party Organization?   

NO - ​We are a premier consulting firm that will work with your company throughout the  compliance process, and beyond. We work with small to midsize maritime companies and will  assist you with the ​“Coast Guard Option” ​ of compliance with​ Subchapter M.​ This will save  you time and resources in the long run as Third Party Organizations will require substantial fees  in order to visit your vessel periodically and audit your “approved” Towing Safety Management  Systems.

What is a Towing Safety Management System TSMS? 

A​ TSMS ​is a robust and very costly paper or electronic safety management system that  needs to be developed by your company AND approved by a Third Party Organization.  Vessels choosing the U.S. Coast Guard option ​ are NOT required to operate under a  costly TSMS and Third Party Organization in order to verify compliance. ​ Owners and  operators choosing the ​U.S. Coast Guard Option can simply use their TVR and/or other  electronic record keeping systems to document compliance directly with the U.S. Coast  Guard.

How will Maritime Safety Management Services assist me with the Coast Guard  Option?  

We will provide two vessel ‘audits’ per year along with a full audit report on any  deficiencies noted for your specific vessel to be in compliance with Subchapter M. Also, we  will work with your company in setting up a proper Towing Vessel Record (TVR) and  management system that will satisfy any Coast Guard requirements. We will schedule and  represent you during annual Coast Guard visits and inspections for your original Certificate of  Inspection (COI) and other required visits. We will work with your local OCMI (Coast Guard) to  assist you in maintaining your operation, allowing you to focus on your business and day to  day operations!

When do I need to meet Subchapter M? 

Subchapter “M” goes into effect on​ July 20, 2018​. This is when your vessel needs to be  in “compliance”. HOWEVER, the issuance of a Certificate of Inspection (COI) is based on how  many vessels, subject to Subchapter M, that the company operates. ​Maritime Safety  Management Services ​will assist you in that process of obtaining a COI and understanding  what you need to do in order to be in “compliance” before they Coast Guard comes to inspect  your vessel.

What is a COI? 

A Certificate of Inspection (COI) is a document issued by the local U.S. Coast Guard  (OCMI - Officer in Charge, Marine Inspection), which sets up the operational parameters for  your vessel. It will list the waters that the vessels is authorized to serve on, the number of  licensed or ‘unlicensed’ personnel are needed to operate the vessel, the required amount and  type of fire prevention and safety equipment that is to be operational when operating. The  COI is valid for a period of 5-years, but requires annual inspection(s) by the U.S. Coast Guard  to verify continued compliance.

​When do I need to have a COI on board to operate my towing vessel?

It all depends on how many vessels you own and operate under Subchapter M. There is  a 4-year phase in period from July of 2018 until July of 2022, by which ALL towing vessels that  fall under Subchapter M, must hold a valid COI. For example, IF you operate ONE towing  vessel (subject to Subchapter M), you will need to hold a COI by July 20, 2020. ​ Please contact  Maritime Safety Management Services and we can discuss your COI dates and options!!

I have small towing vessels that only push around construction barges or dredges  or pipelines, do I need to be in compliance with Subchapter M? 

​Subchapter M applies to towing vessels 26 feet in length or more. Unless the vessel  (less than 26 feet in length) is pushing a barge carrying petroleum products (dangerous liquid  cargoes -DL). Towing vessels LESS than 26 feet in length are NOT required to comply with  subchapter M or the requirements for licensed operators.

What if I have a towing vessel 26 feet or more and it only works on construction  sites or limited geographic areas?  

Subchapter M allows owners and operators to seek​ “work site exemptions” for certain  vessels that are used for limited purposes in a very limited geographic area. Each U.S. Coast  Guard Sector (OCMI) must approve this exemption on a case by case basis. ​Maritime Safety  Management Services ​will assist you in obtaining these exemptions, should that be an option  for you.

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Chart of eligibility for towing licenses