The owner or managing operator of a towing vessel choosing to use the TSMS option must implement an external or internal survey program for vessel compliance. The program for vessel compliance can be either:

1. (a) An external survey program, in which the owner or managing operator would have a third-party organization (TPO) conduct either the surveys required by § 137.205, the examinations required by § 137.310, or both; or
2. (b) An internal survey program, in which the owner or managing operator would conduct either the surveys required by § 137.210, the examinations required by § 137.315, or both, using internal resources or contracted surveyors. The internal survey program would be conducted with the oversight of a TPO.

3. (c) Each program of either type must include:

   1. (1) Owner or managing operator policy regarding the surveying and examination of towing vessels;
   2. (2) Procedures for conducting towing vessel surveys and examinations, as described in this part;
   3. (3) Procedures for reporting and correcting non-conformities and deficiencies;
   4. (4) Identification of the individual or individuals responsible for the management of the program, and their qualifications; and
   5. (5) Documentation of compliance activities.