USCG Issues Advice for Collecting Information for SubM COI's
As of June 25, 2018, the Coast Guard has issued 22 certificates of inspection (COI) to towing vessels in both the Atlantic and Pacific areas of operation.
Additional inspections are scheduled between now and July 20, 2018, when Subchapter M is fully implemented. Following are several important points to keep in mind when seeking a COI:
- The requirements for obtaining a certificate of inspection, as detailed in 46 CFR 136.210, begin when the owner/operator submits the Office of Management and Budget (OMB) approved Form CG-3752 “Application for Inspection.” New construction vessels use Form CG-3752A. Owners/operators are only required to complete OMB-approved forms and submit the information listed in the regulations.
- In order to collect other necessary information, marine inspectors may use job aids or checklists to help document and organize all the required information. Form CVC-FM-004(1) – “Towing Vessel Particulars,” is one example marine inspectors may use. These forms are for the marine inspectors, not owners/operators, to fill out. The marine inspector will complete the job aid/checklist using input from the owner/operator before, during, or after the initial inspection. This input could include information gained from verbal interviews, visual inspection, or review of system manuals and other pre-existing vessel documentation the owner/operators provides to the marine inspector.
- To decrease the disruption to the vessel’s operation, the Coast Guard recommends that vessel owners/operators make any pre-existing vessel documents readily available to the marine inspector during the initial inspection. Doing so may reduce the marine inspector’s time on board the vessel and alleviate the need for follow up visits.
- There is less than four weeks to go before towing vessels are required to comply with the provision ins 46 CFR Subchapter M. Owners and managing operators are encouraged to work with their local OCMI and develop a plan to ensure their vessel(s) are in compliance, allowing adequate time for the Coast Guard or a Third Party Organization to complete the required inspections, audits, and surveys necessary prior to the issuance of a COI.
For Coast Guard Subchapter M policy letters, visit the Office of Commercial Vessel Compliance’s website or the Towing Vessel National Center of Expertise’s website.
By USCG LT Amy Midgett and Cdr. Jennifer Hnatow, Domestic Compliance Division, Office of Commercial Vessel Compliance