The Coast Guard's Office of Commercial Vessel Compliance reminded towing vessel owners and operators last week that the deadline for 100% Subchapter M phase in is July 19, 2022.

On that date, all towing vessels meeting the applicability criteria found in 46 CFR § 136.105 must have on board a valid Certificate of Inspection (COI) issued by the Coast Guard.

Towing vessel owners and operators are responsible for ensuring that all towing vessels in their fleets receive a Certificate of Inspection (COI) before July 19. Failure to meet vessel certification requirements may result in CG-835V deficiencies, vessel delays, civil penalties, or additional enforcement actions.

Initial certification should be scheduled with the local Coast Guard Officer in Charge, Marine Inspection (OCMI) at least three months in advance of the desired inspection date. Thus, towing vessel owners and operators should schedule vessel initial inspections as soon as possible, but no later than April 20. Please note that Coast Guard attendance is required for initial certification for both the Coast Guard inspection option and the Towing Safety Management System (TSMS) option, as described in 46 CFR § 136.130.

Application for inspection should be made using the CG-Form 3752, “Application for Inspection of a U.S. Vessel.” OCMI contact information can be found on the Marine Inspectors Contact List on the CVC-1 webpage. 

For further information, please see the Coast Guard’s Towing Vessel National Center of Expertise (TVNCOE) website.