- Domestic Vessels

6/15/2017: New policy letter on Subchapter M implementation

The Office of Commercial Vessel Compliance has released Policy Letter 17-03: Certificate of Inspection (COI) Phase-In Period for Existing Towing Vessels Using the TSMS Option Under Title 46, Code of Federal Regulations (CFR) Subchapter M.

Highlights include:

  • An agreement between the OCMI and the respective towing company regarding the specifics of the program
  • The OCMI having the necessary resources available to conduct the program
  • The owner or managing operator meeting the requirements in 46 CFR 136.210 for obtaining a COI


Additionally, towing vessels that possess a valid Uninspected Towing Vessel (UTV) decal may be able to use this policy letter along with Policy Letter 17-01 to obtain a COI earlier without a Coast Guard initial COI inspection.

As guidance and policies related to Subchapter M continue to be developed, towing vessel companies must make the important decision to employ the Coast Guard option or the Towing Safety Management System (TSMS) option. Using a third party to conduct surveys and audits is a paradigm shift from traditional Coast Guard inspections. However, the TSMS option and this policy letter will likely provide greater flexibility to companies in scheduling and performing surveys and audits, while also establishing a comprehensive quality control system that will increase the safety and efficiency of all towing vessel operations.

Frequently asked questions about Subchapter M implementation are answered on the Towing Vessel National Center of Expertise’s website. If you have an additional question or comment not already covered, you are encouraged to submit it to TVNCOE or to the Domestic Compliance Division.


This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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