The USCG announced the release of Policy Letter 17-03 to provide guidance to the Officer(s) in Charge, Marine Inspection (OCMI) and the marine industry on the applicability of 46 CFR 136.202, Certificate of Inspection (COI) phase-in period, to existing towing vessels using the Towing Safety Management System (TSMS) option to obtain an initial COI under 46 CFR Subchapter M.
The policy letter is intended for use by both OCMIs and the maritime industry when an owner or managing operator, using the TSMS option, wishes to obtain initial COIs for greater than the percentage of the towing vessels outlined in 46 CFR 136.202. The letter provides details for the following:
- 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
For an owner or managing operator using the TSMS option, an OCMI may issue a COI or COIs in excess of the percentage specified in 46 CFR 136.202 taking into account the following:
- The OCMI has the resources available to accommodate the request for the issuance of additional COIs. To reduce the impact to towing vessel operations and Coast Guard resources, the OCMI should consider giving priority to those vessels that have a valid UTV decal
- The owner or managing operator must meet the requirements in 46 CFR 136.210 for obtaining a COI.
- For owners or managing operators with vessels operating in more than one OCMI zone, a request should be sent to the cognizant OCMI (consistent with 46 CFR 136.210) with a copy to each of the other OCMI(s).
- If an OCMI is unable to meet an owner or managing operator’s request for the additional COI inspections, the OCMI will coordinate with the other OCMI(s) to ensure the required percentage of the fleet is inspected.
USCG emphasizes that 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.
Find out more by reading USCG policy letter herebelow