USCG reminded that owners and managing operators of towing vessels are responsible for ensuring that 75% of their respective fleets receive a Certificate of Inspection (COI) before 19 July 2021, in accordance with 46 CFR 136.202.
ailure to meet the regulatory phase-in schedule could result in vessel delays, civil penalties, or additional enforcement actions. By 19 July 2022, 100% of Subchapter M towing vessels must have valid COIs onboard.
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 owners and managing operators should schedule vessel inspections as soon as possible to 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 US Vessel,” to the OCMI, OMOs should indicate if the Coast Guard or Towing Safety Management System (TSMS) option will be used.