In accordance with 46 CFR 136.202, owners and managing operators (OMO) are responsible for ensuring that 75% of their respective fleets receive a Certificate of Inspection (COI) before July 19, 2021. Failure to meet the regulatory phase-in schedule could result in vessel delays, civil penalties, or additional enforcement actions.  In order to operate after July 19, 2022, all Subchapter M towing vessels must have a valid COI.

Companies with vessels that have not been issued a COI within the phase-in period may be issued a deficiency on a Coast Guard Form CG-835V for non-compliance.Third Party Organizations (TPOs) are authorized to issue non-conformities to companies if they are aware that a vessel or company is not compliant with the Certificate of Inspection phase-in period set by 46 CFR 136.202.

Initial certification should be scheduled with the local Officer in Charge, Marine Inspection (OCMI) at least 3 months in advance of the desired inspection date.  Therefore, towing vessel OMOs should schedule vessel inspections as soon as possibleto ensure the COI is received before the end of the third year phase-in period.  When submitting the completed CG-Form 3752, “Application for Inspection of a U.S. Vessel,” to the OCMI, OMOs should indicate if the Coast Guard or Towing Safety Management System (TSMS) option will be used.

Please visit the Domestic & Offshore Compliance (CG-CVC-1) webpage for Towing Vessel Certificate of Inspection Phase-In Date Guidance.  Phone numbers for each OCMI can be found on the Marine Inspectors Contact List on the CVC-1 webpage.

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 publications, such as the Federal Register, Homeport and the Code of Federal Regulations. These publications remain the official source for regulatory information published by the Coast Guard.