X3 Towing,Field by Field.
Every towing vessel, certificate, survey and audit window on one clock.
- 46 CFR 136-144Subchapter M towing vessels
- 46 CFR 199.180Monthly drills
- 46 CFR 10.301Medical certificates
- 46 CFR 16.230Random testing — 50%
- 29 CFR 1915.12Confined & enclosed spaces
- 29 CFR 1917.50Crane certification
- 33 CFR 105.220Security drills every 3 months
- 33 CFR 155.1060Spill response exercises
- 46 CFR 4.05-10CG-2692 within 5 days
- 46 CFR 4.06-32-hour / 32-hour test clocks
Every record X3 Towing keeps, the rule behind it, how often it comes due, and exactly what to type in each field — with where to find it on your own paperwork.
Fleet & COI
46 CFR 136 / 137.200 / 137.205 · Once per vessel, update at each survey and COI renewal
Each towing vessel's Certificate of Inspection and compliance option. Without a current COI the boat cannot operate.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Compliance option | How the boat is inspected: through your TSMS and a TPO, or directly by the Coast Guard. | If you have a TSMS certificate from a TPO, it's the TSMS option. Your COI paperwork also shows it. | TSMS option |
| COI issued | The date the current COI was issued. | Date of issue on the Certificate of Inspection (COI). | 06/30/2025 |
| COI expires | The date the COI runs out. COIs are good for 5 years. | Expiration date on the COI. | 06/30/2030 |
| Last annual inspection / TPO survey | Date of the last annual survey (TPO) or Coast Guard annual inspection. | Survey report from your TPO, or the Coast Guard's inspection record or endorsement. | 06/15/2027 |
| Next survey (only if your TPO set a different date) | Only if your TPO set a different date for the next survey. | Your TPO's survey report or scheduling letter. | 05/31/2028 |
TSMS Audits
46 CFR 138.310 / 138.315 · Internal audit every year; external audits per certificate
Your company's Towing Safety Management System certificate and audits. Under the TSMS option, the TPO audits your system and the Coast Guard checks the certificate.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| TSMS certificate issued | The date the TSMS certificate was issued. | Issue date on the TSMS certificate from your TPO. | 03/01/2024 |
| TSMS certificate expires | The date the TSMS certificate runs out (up to 5 years). | Expiry ('valid until') date on the TSMS certificate. | 03/01/2029 |
| Last internal audit | Date of your last internal audit. It's due every year, within 3 months of the certificate anniversary. | Internal audit report, signed by an auditor independent of the work audited. | 02/15/2027 |
| Mid-period external audit done | Date of the mid-period external management audit done by your TPO. | TPO's external audit report. It falls around the middle of the certificate's 5 years. | 07/10/2026 |
| Third-Party Organization | The Third-Party Organization that issued your TSMS certificate. | Name on the TSMS certificate. | ABC Marine Services |
Vessel Audits
46 CFR 138.315(b) · Each audit (every boat at least once per certificate)
External audits of individual boats by your TPO. Each boat must be audited at least once during the 5-year TSMS certificate.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| External audit date | The date the TPO auditor audited this boat. | TPO vessel audit report. | 06/30/2027 |
| Auditor | The auditor's name and company. | Signature block of the audit report. | R. Landry, ABC Marine |
| Result | What the audit found and whether findings are closed. | Audit report. Put each finding in Findings with an owner and due date. | Findings issued |
Drydock & Hull
46 CFR 137.300 · Per the hull schedule (X3 works out the next due date)
Drydock and internal structural exams of the hull. Missing one can stop the boat from working and is checked at COI renewal.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Salt water | Whether the boat works in salt water more than 6 months a year. Salt water means more frequent exams. | Your operating area and trip history. | More than 6 months in any 12 |
| Last drydock exam | Date of the most recent drydock exam. | Drydock or survey report, or the shipyard invoice. | 04/15/2026 |
| Drydock exam before that | Date of the drydock exam before the last one. | Older drydock report. | 05/20/2023 |
| Last internal structural exam | Date of the last internal structural exam (inside the tanks, voids and hull). | Survey report for the internal structural exam. | 04/15/2026 |
| Next exam due (leave blank to work it out) | When the next exam is due. Leave blank and X3 works it out. | Only fill in if your TPO or the Coast Guard set a specific date. | 04/15/2029 |
Drills
46 CFR 140.420 / 142.245 · On your drill schedule (each topic for each crewmember)
Emergency drills and instruction held aboard. Every crewmember must take part in each type of drill, and drills must be recorded in the TVR.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Drill | The type of drill. | Pick the emergency practiced. Use Other for anything else. | Man overboard |
| Date held | The date the drill was held. | Logbook or TVR entry for the drill. | 06/30/2027 |
| Scenario and instruction given | What was practiced and what instruction was given. | Drill sheet or logbook. Be specific: what happened, what crew did. | Deckhand overboard off the tow |
| Crew who took part | Names of the crew who took part. | Drill sign-in sheet. | J. Ruiz, T. Bell, M. Ortiz |
| Repeat every (days) | Days between drills of this type. | Your TSMS or drill schedule. 30 = monthly. | 30 |
Findings
46 CFR 138.220(a)(2)(ii) / 137.135 · Each time a finding is issued
Problems found by audits, surveys or the Coast Guard, with the fix and proof it worked. Auditors want to see each finding closed with evidence.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| From | Who found the problem. | Audit or survey report heading, or the CG-835V for Coast Guard items. | External audit |
| Finding | The problem, in the auditor's words. | Copy it from the audit report, survey report or CG-835V. | Fire drill not logged for May |
| Corrective action | What you will do to fix it and stop it happening again. | Your corrective action plan. | Add drill to monthly checklist |
| Due | When the fix must be done. | Date set by the auditor, TPO or Coast Guard, or your TSMS deadline. | 07/31/2027 |
| How the fix was verified | How you proved the fix worked. | E.g. reviewed next month's logbook, photo of repair, re-audit. | Checked June TVR — drill logged |
| Status | Where the finding stands. Close it only after it's checked. | Fixed - awaiting check means someone still has to verify it. | Open |
Watch Log
46 CFR 15.705(d) / 140.400(c) · Every watch change
Who stood watch and when. Watch changes must be recorded in the Towing Vessel Record.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Role | The watch position the person stood. | Watch schedule or logbook. | Mate (Pilot) |
| Assumed watch | When the person took over the watch. | Logbook or TVR watch entry. | 06/30/2027 06:00 |
| Relieved | When the person was relieved. | Logbook or TVR watch entry. | 06/30/2027 12:00 |
Towing Vessel Record
46 CFR 140.910 / 140.915 · Each time a required event happens
The Towing Vessel Record: the official log of required events. Missing or incomplete TVR entries are one of the most common towing deficiencies.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Date & time | Date and time of the event. | When it actually happened, not when it was written down. | 06/30/2027 08:15 |
| Entry | The type of event being recorded. | Pick the matching type. Every required TVR item is listed. | Towing gear inspection |
| Details | What happened, plainly and completely. Never overwrite an earlier entry; add a correction. | From the crew's notes, checklist or logbook. | Inspected main towline, no damage |
Fire & Lifesaving Gear
46 CFR 142.240 / Part 141 · Monthly checks; yearly servicing by a servicing company
Inspections and servicing of fire-fighting and lifesaving gear. Expired or uninspected gear is a common inspection deficiency.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Equipment | The type of equipment. | Pick the matching type. | Portable extinguishers |
| Unit no. / ID | Serial number or your own tag number for this item. | Stamped on the item, its data plate or service tag. | EXT-04 |
| Last inspected / tested | The date of the last inspection or test. | Inspection tag on the item, or the servicing company's report. | 06/30/2027 |
| By (crew, servicing company) | Who did it: a crewmember for monthly checks, or the servicing company for yearly service. | Initials on the tag or the company named on the service report. | Gulf Fire & Safety |
| Result | OK, or Defect found. Put any defect on Defects & Work Orders too. | The inspection result. | OK |
| Repeat every (days — 30 for the monthly NFPA 10 check) | Days between inspections. 30 for the monthly extinguisher check. | Maker's instructions or your TSMS. | 30 |
Crew Orientation
46 CFR 140.410 · Each new crewmember on each boat
The safety orientation each new crewmember gets before working aboard. It must be recorded in the TVR.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Safety orientation given | The date the safety orientation was given. | Orientation checklist signed by the crewmember, or the TVR entry. | 06/30/2027 |
| Given by | Who gave the orientation. | Name on the signed orientation checklist. Usually the master or mate. | Capt. R. Landry |
Health & Safety Plan Training
46 CFR 140.515 · Within 5 days of employment, then yearly
Health & safety training for each crewmember: within 5 days of starting, then a yearly refresher.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Hired or joined the company | The day they started. | Personnel file. | 09/01/2026 |
| Health & safety plan training completed | The day they finished health & safety training. | Sign-in sheet or certificate. | 09/03/2026 |
Hazard Register
46 CFR 140.505 / 140.510 · Review every year and after any injury
Your list of health and safety hazards on each boat and how you control them — engineering controls before PPE.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Last reviewed | When this hazard was last reviewed. | Your safety meeting minutes. | 07/10/2026 |
Towing Gear
46 CFR 140.820 / 33 CFR 164.76 · On your TSMS schedule
Inspections of towlines, face wires and other towing gear. Worn or uninspected gear can part under load and is checked by TPOs and the Coast Guard.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Towline, face wire or spring line | The towline or wire inspected, with its ID if it has one. | Towline record, tag on the line, or the maker's certificate. | Main towline #2, 2-in. HMPE |
| Examined | The date the gear was examined. | TVR towing gear entry or checklist. | 06/30/2027 |
| Examined by | Who examined it. | Name in the TVR entry. | T. Bell, Mate |
| Repeat every (days, per your TSMS) | Days between examinations. | Your TSMS or towline maker's guidance. 30 = monthly. | 30 |
Towline Register
33 CFR 164.74 / 46 CFR 140.820 · Inspect at least monthly
Every towline, its breaking strength and its monthly condition checks. If the condition record lapses 3 months, the line must be retested or removed.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Minimum breaking strength (lbs) | The line's minimum breaking strength when new, in pounds. | Manufacturer's certificate or test report. | 250000 |
| Last inspected (condition) | Last visual condition inspection. | Your towline log or vessel record. | 10/20/2026 |
| Last retest | Last tensile retest, if any. | Class society or test lab certificate. | 02/14/2025 |
Pre-Underway Tests
46 CFR 140.615 / 33 CFR 164.80 · Before trips over 24 hours, and at each change of master
Tests of steering, signals, propulsion and navigation gear before getting underway. These are required before trips over 24 hours and when a new master takes over.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Tested | When the tests were done. | TVR or logbook entry. | 06/30/2027 05:30 |
| Steering | Result of the steering test (full rudder both ways, alarms, indicators). | Pre-underway checklist. | Pass |
| Whistle / signals | Result of the whistle and sound signal test. | Pre-underway checklist. | Pass |
| Propulsion control | Result of the propulsion control test (ahead and astern from each station). | Pre-underway checklist. | Pass |
| Towing gear | Result of the towing gear check. | Pre-underway checklist. | Pass |
| Navigation lights | Result of the navigation lights check. | Pre-underway checklist. | Pass |
| Navigation equipment | Result of the navigation equipment check (radar, GPS, compass, AIS, swing meter). | Pre-underway checklist. | Pass |
| Communications | Result of the radio and internal communications check. | Pre-underway checklist. | Pass |
Fuel & Oil Residue Log
46 CFR 140.915(a)(8) / 33 CFR 151.25 · Each fueling or waste offload
Fuel and lube oil taken on, and oily waste or bilge water landed ashore. Oily bilges are a leading cause of towing vessel detentions.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Date & time | When the fueling or offload happened. | Fuel delivery ticket or waste receipt. | 06/30/2027 10:00 |
| Entry | What was received or landed ashore. | Fuel ticket for fuel; reception facility receipt for oily waste. | Oily residue landed ashore |
| Gallons | Amount in US gallons. | Delivery ticket or waste receipt. | 450 |
| Facility / supplier | The fuel supplier or waste reception facility. | Name on the ticket or receipt. | Riverbend Fuel Dock (sample) |
| Receipt no. | The receipt or ticket number. Keep the paper. | Top of the delivery ticket or waste receipt. | BDN-55102 |
Defects & Work Orders
46 CFR 140.620 / 137.135 / 138.220 · Each time a defect is found
A list of everything broken or wrong on the boat, who is fixing it and by when. Inspectors and TPOs look for defects that were found, tracked and actually closed.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| System | The part of the boat the problem is in. | Pick the closest match. Use Navigation equipment for radar, AIS, GPS, compass or radios. | Steering |
| Defect | A short, plain description of what is wrong. | Copy it from the crew report, survey report, audit finding or CG-835V wording. | Port steering ram leaking hydraulic oil |
| Found | The date the problem was first noticed. | Logbook or TVR entry, the crew report, or the survey or audit report date. | 06/30/2027 |
| Severity | How serious it is. Major = stop using the boat (or that system) until fixed. | Use your SMS/TSMS definitions. Anything that could hurt someone or the boat right now is Major. | Non-conformity |
| Affects navigation safety | Yes if the problem affects safe navigation (steering, lights, radar, compass, radios). | If Yes, the master must decide whether it is safe to continue and log that decision. | Yes |
| Fix by | The date the repair must be done by. | Your SMS/TSMS deadline, or the due date written on the CG-835V or audit finding. | 07/15/2027 |
| Parts / vendor | Parts on order and the shop or vendor doing the work. | Purchase order, vendor quote or work order. | PO 4471 — Gulf Hydraulics |
| Repair made | What was actually done to fix it. | Mechanic's work order or invoice, or the engineer's logbook entry. | Replaced ram seals, tested OK |
| Status | Where the repair stands. Only close it after someone has checked the fix works. | Repaired — awaiting check means a second person still needs to verify it. | Repaired — awaiting check |
Planned Maintenance
46 CFR 138.220(c) / 199.190(b) · Each time a task is done
Routine maintenance that is due by calendar days or engine hours. A working maintenance plan is a required part of a TSMS or SMS, and auditors check that jobs were done on time.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Equipment | The machine or system the task is for. | Name it the way it appears on the equipment list or maker's manual. | Main engine — port |
| Task | The maintenance job to do. | Maker's manual service schedule or your TSMS/SMS maintenance list. | Change lube oil and filters |
| Every (days) | How many days between jobs. Leave blank if the job runs on engine hours only. | Maker's manual or your maintenance plan. 30 = monthly, 90 = quarterly, 365 = yearly. | 90 |
| Or every (running hours) | How many running hours between jobs, if the task is hour-based. | Maker's service interval in the engine or generator manual. | 500 |
| Last done | The date the task was last completed. | Engineer's log, work order or the service record. | 06/30/2027 |
| Running hours when done | The hour-meter reading when the job was last done. | Hour meter on the engine or control panel, written on the work order. | 12,450 |
| Running hours now | Today's hour-meter reading. Update it regularly so X3 can tell when the next job is due. | Read it off the engine hour meter or the engine room log. | 12,880 |
Safety Checks
46 CFR 185.728 / 199.190 / 176.810 / 142.240 / 180.68 · Weekly to monthly, depending on the check
Routine safety-gear checks such as EPIRB self-tests, extinguisher inspections and alarm tests. These are common items on a Coast Guard or TPO deficiency list.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Check | Which safety check was done. | Pick the matching check. Use Other for anything not listed and describe it in notes. | EPIRB monthly test |
| Done | The date the check was done. | Logbook entry, inspection tag initials, or the checklist sheet. | 06/30/2027 |
| Result | OK, or Defect found if anything failed. A defect should also go on Defects & Work Orders. | The person doing the check marks this on the spot. | OK |
| Expires (flares, batteries) | Expiry date for items that run out, such as flares or batteries. | Printed on each flare, and on the label of EPIRB batteries and hydrostatic releases. | 11/30/2028 |
| Repeat every (days — blank uses the usual interval) | Days between checks. Leave blank to use the usual interval for this check. | Only fill in if your SMS/TSMS sets a different interval. 7 = weekly, 30 = monthly. | 30 |
Surveys & Reports
46 CFR 137.200 / 137.205 / 2.01 · Each time a survey or inspection is done
A record of each survey, inspection or exam done on the boat, and what it found. This is your proof for the COI renewal and for the TPO.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Survey | The type of survey or inspection. | Shown at the top of the survey report or on the Coast Guard inspection paperwork. | Annual TPO survey |
| Date | The date the survey or inspection was done. | First page of the survey report, or the date on the Coast Guard inspection record. | 06/30/2027 |
| Surveyor / inspector | The name of the surveyor or Coast Guard inspector. | Signature block of the survey report, or the inspector named on the CG-835V. | J. Thibodeaux |
| TPO | The Third-Party Organization the surveyor works for, if any. | Letterhead of the survey report or your TSMS certificate. | ABC Marine Services |
| Report no. | The report or job number, so you can find the paper later. | Top of the survey report. Coast Guard records may show an activity number. | SR-2027-0412 |
| Non-conformities found | How many problems the survey found. Enter 0 if none. | Count the findings listed in the survey report. | 2 |
| Items to fix before service | Anything the surveyor said must be fixed before the boat goes back to work. | Look for 'prior to', 'before return to service' or out-of-service items in the report. | Replace fire pump impeller |
Internal Survey Program
46 CFR 137.202 / 137.210 / 137.215 · Every item at least every 12 months
Each item of your internal survey program and when it was last surveyed. TPOs are told to write a non-conformity when the program isn't tracked.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Last surveyed | The date this item was last surveyed. | Your internal survey report. | 04/12/2026 |
| Surveyor (competent person) | Who surveyed it — a competent person. | The survey report signature. | Port Engineer R. Lee |
| Part of the fifth-year survey | Yes if this survey is part of the fifth-year survey before COI renewal. | Your survey plan. | Yes |
Safety Walkdowns
46 CFR 137 / company program · Monthly, and before every survey
A walk-through of the boat using the checklist of items inspectors write up most. Fails become defects automatically.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Walked | Date of the walkdown. | Your checklist. | 10/25/2026 |
Compliance information, not legal advice. Rules cited are current as we publish; confirm against the official eCFR.