These instructions provide guidance to both US Coast Guard field offices and the maritime industry on the Coast Guard’s interpretations regarding the application and implementation of regulations applying to towing vessel inspections for certification under 46 CFR Subchapter M and the Towing Safety Management System (TSMS) option.


As of 20 July 20181, all towing vessels must have received, or be in the process of receiving, a COI from the USCG. There are two options for documenting compliance for certification: the Coast Guard option or the TSMS option.

'CVC-WI-013(2), Initial Towing Vessel COI Inspections Under TSMS Option' provides guidance on the US Flag Administration’s interpretations on the application and implementation of initial towing vessel Certificate of Inspection (COI) issuance under the Towing Vessel Safety Management System (TSMS) option.

Officers in Charge, Marine Inspection (OCMIs) should reference this guidance when issuing a COI under Subchapter M for inspected towing vessels choosing the TSMS option.

'CVC-WI-010(1), OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels' provides guidance to OCMIs on the application and implementation of a special consideration determination for towing vessels inspected under reference.

District Prevention Staff (dp), Officers in Charge, Marine Inspection (OCMIs) and the Towing Vessel National Center of Expertise (NCOE) should reference this guidance when a departure from the prescribe regulations is requested by a towing vessel owner, managing operator, or third party organization (TPO).

OCMIs have the authority to approve special consideration requests and should exercise this authority to manage the risk to towing vessels within their inspection zone.

In addition, CG-CVC Policy Letter 17-02 Ch-2 was updated to clarify questions on external audits for TSMS vessels.

The MMS is an ISO 9001 based quality management system, aiming to ensure fulfillment of domestic and international obligations for marine safety and security.

It provides a framework for CG-CVC to publish, maintain, and continually improve policy and guidance to IS Coast Guard units and share information with the maritime industry.