Because of the delays, the Coast Guard proceeded to the following recommendations so that the shipping industry won't be seriously affected:

  • Vessels Engaged on Domestic Voyages Only (Coastwise/Fisheries) can continue operate with an expired COD, domestically, in the condition that a renewal application has been submitted to the NVDC. Vessel owners should be ready to provide evidence, if needed, to the Officer in Charge, Marine Inspection (OCMI) or the Office of Commercial Vessel Compliance (CG-CVC), that a renewal application was submitted.
  • New Construction/Initial Certification (All Trade Endorsements): Based on the Maritime Safety Manual, Vol. II, seafarers can complete the COI before the COD is issued, only under the condition that the NVDC has received the application for documentation. The ones representing the vessel should be in the state of presenting evidence that they have submitted the application to the NVDC to the OCMI.



  • Engaged on International Voyage (Registry Endorsement): Those with an expired COD conducting international voyages and are subject to Port State Control may be provided with a letter from CG-CVC for continued operation. Those requesting a letter confirming the vessel registry by the US should contact and include objective evidence that a renewal application has been submitted to the NVDC.
  • Recreational Vessels (Recreational Endorsement): Vessel(s) with an expired COD that actively engage in recreational use shall not be subject to COD related enforcement action, provided the vessel owner can present evidence that the renewal application was submitted to the NVDC.