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Spotlight: Jo Ann Campbell, Owner of Salyers Solutions

Spotlight: Jo Ann Campbell, Owner of Salyers Solutions

Gaining an Auditor’s Perspective: How TVIB’s Subchapter M Auditor Course Strengthened a Consultant’s Approach

TVIB’s Subchapter M Auditor Course is designed to equip maritime professionals with the knowledge, skills, and tools to conduct both management and vessel audits in accordance with 46 CFR Subchapter M. The training combines classroom instruction with practical exercises, real-world case studies, and peer discussion to ensure participants leave confident in their understanding of audit principles, documentation, and field application.

Whether attendees are new to auditing or experienced in compliance and safety management, the course provides a comprehensive foundation for those pursuing TVIB Auditor Certification or seeking to strengthen their organization’s safety management system.

In this participant spotlight, TVIB is featuring Jo Ann Campbell, Owner and Consultant at Salyers Solutions, a maritime compliance and safety consulting firm.

Jo Ann recently attended TVIB’s Subchapter M Auditor Course at our training facility in Houston, Texas. With her deep experience supporting towing vessel operators, when asked why she joined the course she mentioned, “As an experienced auditor who attended one of TVIB’s first Subchapter M training sessions, I wanted to see how the course has evolved.”

She found that the updated course offered a clear, methodical path for both new and experienced auditors alike.  “The course structure paved the walkway starting from the foundation of being an auditor to the steps needed to perform and complete an audit. The overall learning environment was excellent, from the visual presentation to the hands-on group exercises. The instructor allowed time for discussions and ‘sea stories’ while maintaining the flow of the course.”

Although she initially intended to observe quietly, Jo Ann quickly found herself back in the role of a full participant, “No such luck,” she laughed. “I was placed in the class as a participant and was involved in all aspects of the training. It ended up being a great refresher.”

She walked away with two major reminders that shape every audit she conducts:

  • Every audit requires the full process. “Even though I work with many of the same companies, each audit must follow all steps—especially developing a fresh audit plan for each job.”
  • Words matter. “When writing findings, the reader—whether TPO, USCG, or client—needs to visualize what you’re describing as if they were onboard or reviewing the TSMS.”

Working independently as a consultant, Jo Ann particularly valued the group interaction and collaboration the course encouraged.  “Because I work for myself, I don’t have much interaction with other auditors. The group exercises and discussions gave me new perspectives and put me back on track to the basics of the auditing process.”

For those considering the course, Jo Ann offers clear advice:

“Whether this is the career path you’re pursuing, or your company simply wants a deeper understanding of the external auditor’s role, this course provides an excellent foundation and the confidence to perform and participate in audits effectively.”

Jo Ann also credits the TVIB training team and support staff for creating an environment of professionalism and guidance.  “Having instructors like Tava, Caleb, and Ken—who all have maritime backgrounds—is invaluable. They bring real-world insight to every discussion. And the support staff keeps the entire process running smoothly.”

For Jo Ann, the TVIB Subchapter M Auditor Course served as both a technical refresher and a professional reset. It reaffirmed that even the most experienced auditors benefit from revisiting the fundamentals—ensuring every audit is approached with clarity, precision, and a fresh perspective.

Jo Ann’s experience reflects how TVIB’s training programs help professionals across the towing industry gain the skills and confidence needed to promote safe, compliant operations.

Our Subchapter M Auditor Course continues to equip participants with practical auditing tools, deeper understanding of regulatory expectations, and the ability to contribute meaningfully to their organizations’ safety management systems.

 

About Jo Ann Campbell

Jo Ann Campbell is the Owner and Consultant at Salyers Solutions, where she provides safety, compliance, and operational consulting services to towing vessel operators and maritime organizations. Drawing on decades of industry experience, Jo Ann partners with companies to strengthen their management systems, prepare for audits, and foster a proactive culture of compliance and safety. She is also a TPO Sub M Auditor and external surveyor.

TVIB FAQ – What is a TPO?

This FAQ is designed to provide concise answers to common questions about Third Party Organizations (TPOs) and their role under 46 CFR Subchapter M. It serves as a guide for operators, auditors, and other stakeholders seeking to better understand compliance requirements and the benefits of working with a TPO.

For comprehensive answers and guidance, visit the FAQ section on our website: TVIB FAQ. Use the search function with the term “TPO” or navigate to 46 CFR Part 139 for relevant details.

TVNCOE Compare Differences Between TSMS-Option Vessels and Coast Guard-Option

Deficiency Trends: A Crucial Comparison Between TSMS and Coast Guard-Option Vessels

Subchapter M compliance remains a cornerstone of safe and efficient towing operations. One of the most telling indicators of compliance health is the rate of serious deficiencies—those that can halt operations or signal unsafe conditions. Understanding how different oversight models impact vessel performance is critical as the industry continues to evolve. Insights from the September 2025 TPO meeting, hosted by the Coast Guard’s Towing Vessel National Center of Expertise (TVNCOE) highlight clear performance differences between TSMS-option vessels and those using the Coast Guard-option.

Fleet Composition: The Foundation for Comparisons

Understanding the makeup of the U.S. towing vessel fleet is essential for interpreting deficiency trends. CWO Jimmy Collins of the TVNCOE states that the fleet currently includes 4,869 towing vessels. Of these, 3,512 operate under a TSMS certificate or Document of Compliance (DOC) issued by a TPO or Responsible Organization (RO), with 2,875 specifically under the TSMS-option. This means approximately 72% of the fleet is managed through third-party oversight, while the remaining 28% falls under the Coast Guard inspection option. This disparity in oversight models provides a meaningful context for comparing serious deficiency rates.

 

 

Trends in Serious Deficiencies

At the September 2025 meeting, Mr. Dave Phillips, Gulf Technical Advisor at the TVNCOE, presented metrics covering serious deficiencies from September 1, 2024, to September 1, 2025. These metrics focused on CG-835V action codes: Code 17 (Rectify deficiencies prior to departure), Code 30 (Restriction/No-Sail Condition), and Code 60 (Detention due to Unsafe Condition). The data was normalized to reflect ‘per vessel inspected’ rates for both TSMS-option and Coast Guard-option vessels.

Key findings from Mr. Phillips’ presentation include:

  • Coast Guard-option vessels incurred more serious deficiencies per vessel inspected than TSMS-option vessels.
  • The divergence is particularly notable for CG-835V codes 17, 30, and 60.
  • TSMS-option vessels demonstrated a relatively steady or slightly declining deficiency rate over successive quarters, while CG-option vessels showed greater volatility and higher peaks.

 

TVIB’s Perspective on this Disparity

From the industry’s viewpoint, several factors contribute to the consistent outperformance of TSMS-option TPO/RO-overseen vessels in managing serious deficiencies:

  • Proactive vs. reactive oversight: TSMS-option helps catch problems early, before they grow into bigger issues. This early action builds safety and confidence. Coast Guard-option vessels, however, may not discover issues until an inspection takes place.
  • Slow fixes: When vessels aren’t regularly audited, problems can linger and get worse by the time inspectors find them.
  • Inspection exposure: Annual Coast Guard inspections can uncover problems that have built up over time, while TSMS-option vessels benefit from continuous oversight that prevents issues from piling up. Ongoing monitoring gives operators confidence that potential problems are caught early.
  • Structural differences among operators: Factors such as company size, maturity of management systems, and staffing levels influence how effectively deficiencies are identified and resolved.
  • Policy and reporting: TSMS-option operators undergo a greater number of compliance activities overall, increasing the likelihood that deficiencies are identified and corrected before being noted by the Coast Guard.

 

Takeaways and Industry Implications

The data presented at the recent TPO meeting reinforces the value of the TSMS-option and provides actionable insights for operators:

  • Shows why choosing the TSMS-option makes sense: The difference in serious deficiencies highlights the benefits of operating under TSMS-option with TPO/RO oversight.
  • Applying data to support decisions: TVIB is gathering and sharing data on deficiency ratios so members can compare performance and keep improving.
  • Focus on root cause and trend analysis: Beyond counting deficiencies, TVIB encourages members to “follow the audit trail”, investigating root causes, identifying common failure modes, and sharing lessons learned.
  • Avoid complacency in TSMS-option fleets: Maintaining high performance requires ongoing vigilance, auditing, training, and management support.

The consistent trend of higher serious deficiency ratios among Coast Guard-option vessels underscores the effectiveness of the TSMS-option model. Every deficiency avoided translates to reduced downtime, fewer corrective actions, improved safety performance, and more substantial justification for choosing the TSMS-option path. TVIB’s unwavering commitment to supporting its members with tools, training, and resources instills optimism about the future of Sub M, driving continuous improvement across the industry.

For TVIB members, this is more than just a statistic—it’s a license to press forward. Every deficiency avoided means less downtime, fewer corrective actions, better safety performance, and more substantial justification for the TSMS-option path.