Coast Guard releases bulletin on COIs for Subchapter M

The U.S. Coast Guard Sector Houston-Galveston issued a marine safety information bulletin last week on the issuance of initial certificate of inspections (COI) for Subchapter M inspected towing vessels that use the Towing Safety Management System (TSMS) option.

For vessels seeking an initial COI through the Coast Guard option, that will be addressed in a future MSIB.

Companies that choose the TSMS option will have a Coast Guard-approved third party organization (TPO) conduct independent verifications to assess whether their TSMS complies with the requirements of Subchapter M.

Owners and operators that select the TSMS option may submit requests for COIs to the local Coast Guard Officer in Charge, Marine Inspections (OCMI) by submitting the required information listed below as outlined in 46 CFR 136.210. NOTE: Priority will be given to vessels that have a valid UTV decal.

  1. Thirty days prior to the vessel undergoing the initial inspection for certification, owners and managing operators must submit Form CG-3752, “Application for Inspection of U.S. Vessel,” to the OCMI where the inspection will take place.
  2. Vessel particulars.
  3. A manning proposal.
  4. Vessel route.
  5. A description of any modifications to the vessel made since new construction.
  6. TSMS certificate issued by a TPO at least six months prior to the scheduled initial COI issuance date. Compliance with ISM may also be used IAW CG-CVC Policy Letter 17-02 dated May 24, 2017, Use Of Existing Safety Management Systems To Obtain An Initial Certificate Of Inspection Under 46 CFR Subchapter M.
  7. Objective evidence of compliance with the TSMS certificate.
  8. A report in accordance with 46 CFR 137.135 and 137.202(a) stating the vessel’s structure, stability, and essential systems comply with Subchapter M.
  9. Certificate of Documentation.
  10. If applicable, Fresh Water Intent Letter for hull exam intervals as per 46 CFR 137.300 (a).

NOTE: Objective evidence may include, but is not limited to, summaries of TPO independent verifications, audit findings, marine surveyor reports, and/or professional engineer certification.

At the OCMI’s discretion, towing vessels possessing a valid uninspected towing vessel (UTV) decal issued in the Coast Guard Sector Houston-Galveston zone will not require Coast Guard marine inspectors to physically attend prior to COI issuance.

For more information, please contact:

  • Sector Houston-Galveston: (281) 464-4733 or send email to
  • MSU Texas City: (409) 682-1903 or send email to

About the author

David Krapf

David Krapf has been editor of WorkBoat, the nation’s leading trade magazine for the inland and coastal waterways industry, since 1999. He is responsible for overseeing the editorial direction of the publication. Krapf has been in the publishing industry since 1987, beginning as a reporter and editor with daily and weekly newspapers in the Houston area. He also was the editor of a transportation industry daily in New Orleans before joining WorkBoat as a contributing editor in 1992. He has been covering the transportation industry since 1989, and has a degree in business administration from the State University of New York at Oswego, and also studied journalism at the University of Houston.

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