These FAQs are for uninspected towing vessels. For inspected towing vessels FAQs click here: Inspected towing vessel FAQs.

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 Vessel Particulars


Q: Upon the sale of a UTV, is the removal of the Safety Decal required?

ANS: The current edition of the UTV examination form (UTV Form 001 (6/11)) states, "The Decal is to be removed from the vessel if the vessel is sold." After further review and in the best interest of the TVBP it has been decided that the safety decals will not be removed on the sole basis of being sold. Current guidance is for Sectors not to actively engage in the removal of safety decals when vessels are sold. Working with the new owner or operator to ensure the vessel remains in compliance with current regulations is recommended. The decal removal stipulation in future UTV examination form revision(s) will be deleted.


Q: Does an inspected towing vessel have to complete an Inspection for Certification and a UTV examination in order to be issued a UTV decal?

ANS: No. An inspected towing vessel does not need to undergo a UTV Exam on top of the Inspection for Certification to receive the UTV decal. The UTV decal should be issued to the vessel by virtue of the fact that it is in compliance with a higher standard (46 Subchapter I) than the uninspected regulations (46 CFR Subchapter C). Issuing a UTV decal to an inspected towing vessel, just like with small passenger vessels, allows operational units to quickly determine if the vessel is in regulatory compliance especially if the vessel's uninspected/inspected status is not readily apparent.

Guidance for issuing a UTV decal to inspected towing vessels:

1. The decal expiration date shall match the expiration of the COI.
2. Because the decal expires with the COI it is not required to be added to the MISLE certificates.
3. The COI is the authoritative document onboard, not the decal.
4. Posting of the decal shall be in accordance with current guidance. "Decal Placement: After issuing a decal, inform the operator that the decal must be displayed in clear view on the starboard superstructure of the pilothouse. (The decal may be displayed in a window in this location as long as the display does not obstruct the operator's view.)"


Q. What date should I use as the issue date for the Towing Vessel Examination Decal?

Ans. The issue date for the Towing Vessel Examination Decal is the date the decal is issued. The decal is valid for three (3) years from the issue date. Here are a few scenarios for clarification:

1. You complete a UTV examination with no disqualifying deficiencies noted and you issue a decal to the vessel. The decal issue date would be the same as the date of the examination.
2. You complete a UTV examination and disqualifying deficiencies were noted. The deficiencies were corrected before you completed the examination; you have documented the deficiencies as corrected and issued the decal. The decal issue date would be the same as the date of the examination.
3. You complete a UTV examination and disqualifying deficiencies were noted. Corrective action cannot be completed before the conclusion of the examination. You document the discrepancies and do not issue the decal. A few weeks later the company calls and indicates the discrepancies have been corrected. You complete a discrepancy follow-up visit (def check), clear the discrepancies and issue the decal. The decal issue date would be the same as the date of the discrepancy follow-up visit - the day the decal was issued.
4. Another port completes a UTV examination and disqualifying deficiencies were noted. Corrective action could not be completed before the conclusion of the examination. The examination was documented with outstanding discrepancies and a decal was not issued. At the end of the examination the owner/operator indicated they wanted to have the discrepancies cleared in your port and your OCMI agreed to this arrangement. A few weeks later the vessel is in your port and the company contacts you and indicates the discrepancies have been corrected. You complete a discrepancy follow-up visit (def check), clear the discrepancies and issue the decal. The decal issue date would be the same as the date of your discrepancy follow-up visit.


Q: Is a company required to maintain a valid uninspected towing vessel (UTV) examination decal on a UTV?

ANS: No. A decal is issued to a UTV as part of the Towing Vessel Bridging Program (TVBP) after the vessel is examined and found to be in compliance with all applicable safety laws and regulations. The decal is valid for three years. Once a vessel has been examined it has met the intent of the TVBP and no further examinations under the TVBP are required. If a company wants to maintain a valid decal they will need to contact their local Coast Guard office to schedule a re-examination.


Q. What considerations should be taken into account when conducting a re-exam of a towing vessel and issuing a new 3 year decal?

Ans. Sectors and towing companies wanting to maintain valid decals on their vessels should work together to understand the expectations for scheduling re-exams. Similar to what is required for inspected vessels, (46 CFR 2.01-3 requires owners to provide at least 30 days notification) companies should give the local Coast Guard ample notice so they can negotiate an agreed upon schedule to conduct the exam.

Companies requesting a re-exam within 90 days of the expiration of their current valid decal should be issued a new decal valid for 3 years from the expiration date of the current decal. This provides for companies to receive a full 3 years on each decal issued. (i.e. current decal expires 1 Oct 2012, re-exam complete 22 Aug 2012, new decal valid to 1 Oct 2015)

If the re-exam is conducted after the expiration of the initial decal issuance, the new decal would be valid from the date of the completion of the re-exam and clearance of deficiencies if issued. (i.e. current decal expired 22 Aug 2012, re-exam complete 1 Oct 2012, new decal valid to 1 Oct 2015)

If during the re-exam deficiencies are issued that would result in a Captain of the Port Order (COTP) to be issued not allowing the vessel to sail, removal of the current decal could be warranted. Decals should not be removed when deficiencies are issued with specific timeframes to meet compliance and companies are working towards completing those items, however a new decal will not be issued until those items are cleared. If the removal of a decal takes place, Units are reminded that detailed and accurate documentation in MISLE is critical for the integrity of the TVBP.

 Credentials, Documents & Records


Q. What should be the course of action if a non-documented UTV is suspected of being at least five net tons?

Ans. In accordance with 46 CFR 67.7 and 67.19, and unless exempted under 46 CFR 67.9, a towing vessel of at least five net tons is required to have a properly endorsed Certificate of Documentation (COD). A Coastwise endorsement entitles the vessel to employment in unrestricted coastwise trade, dredging, towing, and any other employment for which a registry or fishery endorsement is not required. If a non-documented UTV is suspected of being at least five net tons and meets the criteria listed in the above regulation, the owner/ operator should be directed to submit a completed Application for Simplified Measurement (form CG-5397) to the National Vessel Documentation Center for tonnage and documentation requirement clarification. It is encouraged that the UTV examiners assist the owner/operator with application process. There is an online, interactive version of this form which will do the calculations for owner/operator.

Further information, as well as other relevant FAQs concerning documentation and tonnage, can be found on the National Vessel Documentation Center's website.


Q. Are the operational conditions identified in a UTV's Stability Letter always applicable?

Ans. The operational conditions identified in a UTV's Stability Letter are only applicable when the vessel's Load Line Certificate applies. In accordance with 46 USC 5102(b)(6) Load Lines are not applicable to "a vessel of the United States on a domestic voyage that does not cross the Boundary Line, except a voyage on the Great Lakes." Therefore, if a US vessel is operating on a domestic voyage (except for the Great Lakes), inside the Boundary Line as described in 46 CFR part 7, the Stability Letter does not apply.


Q. If MTSA regulations are applicable to an uninspected towing vessel (UTV)…how often must the UTV undergo a MTSA verification?

Ans. A minimum of once in five years.

Guidance for conducting MTSA verifications can be found in Navigation and Vessel Inspection Circular (NVIC) No. 04-03. Some confusion regarding the verification cycle may exist due to conflicting information contained in NVIC 04-03, the USCG Uninspected Towing Vessel Examination form (UTV Form 001(6/09)) and the USCG Requirements for Uninspected Towing Vessels guidebook. Section 3.B in enclosure 2 to NVIC 04-03 states, "Uninspected vessels must undergo verification, initially, at least once every five years, and based on risk at other times..."  Paragraph 8.7.3 in enclosure 8 to NVIC 04-03 states, "After initial verification, uninspected vessels must be verified at least twice every five years." The UTV examination form and the UTV guidebook also indicate MTSA verifications should be completed twice in five years.

Due to the ambiguous nature of NVIC 04-03 (different timeframes in separate enclosures), CG-544 and CG-543 decided to require the minimum frequency stated in NVIC 04-03 "...once in five years." Once in five years is a minimum verification cycle. The COTP may increase the number of MTSA verifications if warranted by operational risks. 

 Navigation Safety Equipment



What towing vessels are required to have the bridge-to-bridge radiotelephone station inspected and obtain a Bridge to Bridge Certificate?

ANS: The Bridge to Bridge Act (BBA) is found in 33 USC Chapter 24 and the purpose is " provide a positive means whereby the operators of approaching vessels can communicate their intentions to one another through voice navigational information, on navigable waters of the United States."  The Coast Guard equipment carriage requirements for the BBA are found in 33 CFR Part 26.  FCC radiotelephone station operating and technical conditions requirements for the BBA are found in 47 CFR Part 80 Subpart U.  Per 33 USC 1203(a)(3), 33 CFR 26.03(a)(3) and 47 CFR 80.1001(c), applicability of the BBA includes every towing vessel of 26 feet or over in length while navigating.

47 CFR 80.1005 requires certain bridge-to-bridge radiotelephone stations to be inspected for compliance with the BBA, and outlines when those inspections are to be conducted.  All vessels subject to the BBA that are required to conduct regular radiotelephone station inspections under Part II or III of Title III of Communications Act of 1934 (CA), the Safety Convention (SOLAS), or the Great Lakes Agreement (GLA) are required to have the radiotelephone station inspected for compliance with the BBA at the time of those inspections, and to carry a BBA certificate with a valid endorsement while subject to the BBA.  Failure to complete the prescribed inspections would invalidate the Bridge to Bridge certificate.

References: 33 USC Chapter 24; 47 CFR 80.901, 80.903, 80.951, 80.953, and 80.1005; Part II and Part III of Title III of Communications Act of 1934 Sections 351, 352, 362, 381 and 382; SOLAS Chapter 1 Reg 9 and Chapter IV Reg 1.

47 CFR 80.1005 also requires bridge-to-bridge radiotelephone stations to “ inspected from time to time" for compliance with the BBA on towing vessels not subject to regular inspections under Part II or III of Title III of the CA, SOLAS, or the GLA.  The FCC and the Coast Guard consider this to be an inspection required for reasonable cause.  Evidence showing a radiotelephone station meets the BBA includes labeling on the radios or other documentation (i.e. manufactures specification sheet) indicating the equipment is 47 CFR Part 80 compliant.  If the vessel has the proper equipment and the radio passes a radio check, there should be no further inspection requirements needed.  If the radiotelephone appears to be malfunctioning, then prompt repairs should be considered per requirements of 33 CFR 164.72(a)(3) and 164.82. If there is reasonable cause to require an inspection of the radiotelephone to certify compliance with the BBA, and the vessel does not pose an immediate hazard to navigation, the FCC should be notified so they can take action as they deem appropriate.  As an alternative to conducting a reasonable cause BBA inspection, replacement of the defective equipment with serviceable BBA compliant equipment is acceptable.

References: 33 USC 24; 47 CFR 80.1005; Part II of title III of Communications Act of 1934 Sections 351 and 352.

Bridge to Bridger Act (BBA) Summary Table
Towing Vessel
BBA applicable?
BBA inspection required?
BBA inspection interval?
BBA certificate required?7

Seagoing1 => 300 GRT and =>26 ft. in length;
Seagoing carrying more than 12 passengers; or SOLAS requirement to survey radio installation

12 months

Authorized to transport more than six passengers for hire in the open sea1 or any tidewater adjacent or contiguous to the open sea

5 years

Operates on the Great Lakes and => 26 ft. in length

13 months

Seagoing1 <300 GRT and =>26 ft. in length; or
Inland => 26 ft. in length

As needed5
Time to time

< 26ft. in length

  1. Seagoing and open sea include operations beyond the boundary line as defined in 46 CFR Part 7.
  2. Vessel is subject to regular inspections under Part II of Title III of the CA.  The BBA inspection is conducted at the time of the CA inspection or SOLAS survey.
  3. Vessel is subject to regular inspections under Part III of Title III of the CA.  The BBA inspection is conducted at the time of the CA inspection.
  4. Vessel is subject regular inspections under the GLA.  The BBA inspection is conducted at the time of the GLA inspection.
  5. Vessel is not subject to regular inspections under Part II or III of Title III of the CA, SOLAS, or the GLA.  The bridge to bridge radiotelephones is only inspected under the BBA for reasonable cause.  If the vessel has had a reasonable cause BBA inspection, there should be an inspecting technician's entry in the station log or a Bridge-to-Bridge certificate.
  6. References: 33 USC 24; 33 CFR 26.03; 47 CFR 80.1001.
  7. A properly endorsed Bridge to Bride certificate demonstrates successful completion of a BBA inspection.  In lieu of endorsing an inspection on the Bridge to Bridge certificate, compliance can be certified in the station log required by section 47 CFR 80.409(f).























Q. Are towing vessels required to maintain a radio log?

Ans. Yes, if the vessel is subject to the Vessel Bridge to Bridge Radiotelephone Act or the Great Lakes Agreement.

33 CFR Part 26 contains the regulations that implement the Vessel Bridge to Bridge Radiotelephone Act. In accordance with (IAW) 33 CFR 26.03, "Every towing vessel of 26 feet or over in length while navigating must have a radiotelephone on board capable of operation from its navigational bridge." Towing vessels which require a radiotelephone IAW 33 CFR 26.03 meet the definition of a compulsory ship IAW 47 CFR 80.5 which is, "Any ship which is required to be equipped with radio telecommunication equipment in order to comply with the radio or radio-navigation provisions of a treaty or statute to which the vessel is subject." 47 CFR 80.409(e) requires ship radiotelephone logs/log entries for vessels that are compulsorily equipped for radiotelephony."

You can find details regarding applicable radiotelephone log entries in 47 CFR 409(f). Taking into account the vessel's route and service, not all of the log requirements will be applicable to all vessels (i.e. inland towing vessels will not have GMDSS, SARTS, etc.). 47 CFR 409(f)(3) states "Radiotelephony stations subject to the Bridge-to-Bridge Act must record entries indicated by paragraphs (e) (1), (5), (6), (7), (11) and (12) of this section." Those record entries are:

(1) A summary of all distress and urgency communications affecting the station's own ship, all distress alerts relayed by the station's own ship, and all distress call acknowledgements and other communications received from search and rescue authorities.
(5) A weekly entry that:
    (i) The proper functioning of digital selective calling (DSC) equipment has been verified by actual
    communications or a test call;
    (ii) The portable survival craft radio gear and radar transponders have been tested; and
    (iii) The EPIRBs have been inspected.
(6) An entry at least once every thirty days that the batteries or other reserve power sources have been checked and are functioning properly.
(7) The time of any inadvertent transmissions of distress, urgency and safety signals including the time and method of cancellation.
(11) Results of inspections and tests of compulsorily fitted lifeboat radio equipment;
(12) A daily statement about the condition of the required radiotelephone equipment, as determined by either normal communication or test communication;

47 CFR 80.409(f)(2) states, " Radiotelephony stations subject to the Great Lakes Agreement and the Bridge-to-Bridge Act must record entries indicated by paragraphs (e) (1), (5), (6), (7), (8), (9), (11) and (12) of this section." IAW 47 CFR 80.409(f)(2), vessels subject to the Great Lakes Agreement must make two additional record entries:

8) At the beginning of each watch, the Officer of the Navigational Watch, or GMDSS Operator on watch, if one is provided, shall ensure that the navigation receiver is functioning properly and is interconnected to all GMDSS alerting devices which do not have integral navigation receivers, including: VHF DSC, MF DSC, satellite EPIRB and HF DSC or INMARSAT SES. On a ship without integral or directly connected navigation receiver input to GMDSS equipment, the Officer of the Navigational Watch, or GMDSS Operator on watch, shall update the embedded position in each equipment. An appropriate log entry of these actions shall be made.
(9) A GMDSS radio log entry shall be made whenever GMDSS equipment is exchanged or replaced (ensuring that ship MMSI identifiers are properly updated in the replacement equipment), when major repairs to GMDSS equipment are accomplished, and when annual GMDSS inspections are conducted.

If the radio station is required to be inspected additional log entries are required per 47 CFR 80.409(f)(1) or 80.490(f)(2) as applicable.

IAW 47 CFR 409(a)(1), the log "...must be kept in an orderly manner." and "...may be kept electronically or in writing."

 Pollution Prevention


Q. Are hoses used for the internal transfers of fuel oil, engine oil, bilge slops and other fluids on towing vessels required to meet the oil transfer hose requirements of 33 CFR 154.500?

ANS. No. These hoses when used in the internal transfer of these fluids aboard towing vessels are not required to meet the design, testing or marking requirements specified by 33 CFR 154.500.

33 CFR 154.105 defines a transfer as any movement of oil or hazardous material to, from, or within a vessel by means of pumping, gravitation, or displacement. A transfer is considered to begin when the person in charge on the transferring vessel or facility and the person in charge on the receiving facility or vessel first meet to begin completing the declaration of inspection as required by 33 CFR 156.150. Therefore, transfer is not considered to have begun until the following are met;

(1) There is a person in charge (PIC) assigned at the each end of the transfer (facility and vessel); and
(2) A declaration of inspection (DOI) is completed jointly.

Moving liquids such as bilge slops, engine oils, or other fluids used for or resulting from the maintenance of machinery, internally (within in the engine room), will not meet the definition of a transfer until those liquids are transferred from the towing vessel to a facility or another vessel, necessitating the assignment of a person in charge, at each end of the transfer and the completion of a declaration of inspection. Consequently, the hoses used in the internal portion of the transfer are not subject to the requirements of 33 CFR 154.500 for oil transfer hoses.


Q. Will the Coast Guard verify compliance with Vessel General Permit (VGP) requirements during Industry Initiated Exams on Uninspected Towing Vessels (UTV)?

Ans. Not at this time. Although, a Memorandum of Understanding (MOU) between the Environmental Protection Agency (EPA) and the USCG allows the USCG to evaluate vessel compliance with EPA's VGP requirements and also to share observations with the EPA, the thrust of this policy is verification of VGP matters for inspected vessels. Therefore, while UTV's must comply with applicable VGP items, the USCG will not evaluate compliance with VGP requirements during routine exams (e.g., Industry Initiated Exams). It is important that the vessel owners/operators understand the applicable requirements and also that the USCG will likely engage in verification activities with UTV's at some future date. Further information can be found on the EPAs webpage and from the USCG's policy letter CG-543 11-01.


Q. What are the requirements for the above described vessels, and what if the owner/operator feel requirements cannot be satisfied?

Ans. 33 CFR 155.420 requires that oceangoing ships between 100 gross tons and 400 gross tons (fitted with main or auxiliary machinery spaces) have at least one pump installed to discharge oily mixtures through a fixed piping system to a reception facility. The same requirement applies to non-oceangoing ships of 100 gross tons or more (a pump with fixed piping). In this case, oceangoing means operated at any time seaward of the outermost boundary of the territorial sea of the U.S. (see 33 CFR 151.05 & 33 CFR 2.22)

An oceangoing ship (between 100 gross tons and 400 gross tons) that has approved oily-water separating equipment does not need the pump or piping; this also applies to the non-oceangoing ship (of 100 gross tons or more) that has oily-water separating equipment onboard.

The above regulation requires that the defined vessel(s) be equipped with fixed piping and one pump installed to discharge oily mixtures to a reception facility. Utilization of the system is not required. Therefore, the company is permitted to use an alternative means to remove oily mixtures from the vessel(s).

EXEMPTION: As provided for by 33 CFR 155.130, companies can submit in writing an exemption request to Commandant, via a local Captain of the Port or Officer in Charge, Marine Inspection, regarding the pump/piping requirement. In accordance with 33 CFR 130 (a)(2)(i-iii) The exemption must meet one of the following conditions: Compliance with a specific requirement is economically or physically impractical; no alternative procedures, methods, or equipment standards exist that would provide an equivalent level of protection from pollution; and the likelihood of discharge occurring as a result of the exemption is minimal.

EXTENSION: As provided for by Policy Letter 10-02, companies can request an extension to obtain additional time to comply with the pump/piping requirement. 

 Fire Fighting, Protection & Suppression Equipment


Q: When is fire detection system certification per 46 CFR 27.203(g) required on an uninspected towing vessel (UTV) that holds a valid SOLAS certificate(s)?

Ans: SOLAS fire safety requirements, standards and oversight are equal to or higher than that required in 46 CFR Subchapter C. A UTV that maintains a valid SOLAS certificate certifying the vessel complies with SOLAS fire safety requirements is deemed to be in compliance the fire detection system requirements contained in 46 CFR 27.203.

Per the preamble to the interim rule which required fire detection systems on board UTVs: "The goal of the proposed rule was to ensure that a dedicated, reliable system would be installed aboard towing vessels, to provide early warning of fires." - see 64 FR 56257. At a minimum, all UTVs are required to have their fire detection system certified at least once to ensure they meet the above goal. A key point to keep in mind is, while 46 CFR 27.203(g) does require fire detection systems to be certified it is silent on the form of the certification - i.e. a letter, notation on a system plan, etc.

A UTV that only operates on domestic routes or, operates on an international route but does not maintain SOLAS certificate(s) covering SOLAS fire safety systems, would be required to have the fire detection system certified in accordance with 46 CFR 27.203(g). Fire detection system certification completed in accordance with 46 CFR 27.203(g) remains valid (no expiration) as long as the system is maintained as originally configured for certification. A fire detection system would need to be recertified if the system is modified, repaired with other than "replacement in kind" parts or the system is replaced entirely.

A UTV that operates on an international route may have to comply with SOLAS fire safety requirements, Fire Safety System Code requirements and maintain SOLAS certificates. The fire detection system on any towing vessel that maintains a SOLAS certificate must be Coast Guard approved under 46 CFR 162.002. Unlike the domestic vessels, UL listed systems are not accepted as alternatives to Coast Guard type approved systems under SOLAS. The Coast Guard or an authorized classification society (i.e. ABS) certifies a vessel meets SOLAS fire safety systems requirements by issuing a SOLAS certificate - i.e. Cargo Ship Safety Equipment Certificate. A SOLAS certificate is issued to a vessel after the Coast Guard or an authorized classification society has done an inspection of the associated system(s) and found them to be in working order and in compliance with international requirements. The vessel is also subject to annual compliance surveys between the initial issuance and renewals of the SOLAS certificate to ensure those systems covered by the SOLAS certificates are properly maintained.


Q: What type of remote operator is acceptable for the fuel shut-off valves installed on uninspected towing vessels?

Ans: The preamble to the Final Rule (see 65 FR 52043) dated 28 August, 2000 requiring fuel shut-off valve(s) on uninspected towing vessels stated the intent of the regulation was " require a means to stop the main supply of fuel to the engine room during a fire."

Per 46 CFR 27.207 remote fuel shut-off valve(s) are required on all fuel lines that supply an engine or generator. The valve(s) must be fitted with a remote operator to allow the crew to close the valve from a safe location in the event of an engine room fire. The regulations specify that the fuel shut-off valve(s) must be located near the source of supply such as at the day tank or fuel distribution manifold. The remote valve operator must be located outside the space were the valve is installed. The remote operator for the valve must be capable of functioning if there is a fire in the engine room. Fuel shut-off valves that can be remotely operated by reach rods, pull cables, electric, hydraulic, pneumatic or other means are acceptable as long as they can reasonably be expected to work during a fire in the space. In some cases system components such as wiring or flexible connections may require shielding or other means to ensure the valves remote operator will remain operational during a fire in the space. If a powered (electric, pneumatic, hydraulic, etc.) operator is employed there must be a means to remotely close the valve even in a deadship condition.


Q: What fire hoses meet the definition of "lined commercial fire hose" and are appropriate for use on uninspected towing vessels?

Ans. In 46 CFR 27.301(d) and (e)(2), applicable towing vessels must be equipped with "...lined commercial fire-hose." Hoses that are considered to meet this requirement are those that meet Underwriters Laboratories (UL) Standard 19, or are constructed in accordance with National Fire Protection Association (NFPA) Standard 1961. Hoses meeting either standard still must meet the minimum diameter (1.5 inches) and length (50 feet) requirements. Other fire hoses will be considered on a case-by-case basis.

Acceptable lined hoses include single or double jacket woven cotton/polyester hose or rubber covered fire hose. Woven jacket fire hose has a single or double layer of outer woven fabric with an internal rubber lining. Rubber covered fire hose is constructed with the rubber covering integral with the weave. This hose appears homogeneous and does not have separate layers.

In addition, hoses must be equipped with nozzles made of corrosion resistant material. Brass is acceptable for any service, while anodized aluminum may be used in fresh water applications. Fittings are to meet the same material requirements.


Q: Is the B-III semi-portable fire extinguishing system listed in 46 CFR 25.30-20(2)(ii) required on an uninspected towing vessel?

Ans: The B-III is not required per 47 CFR 27.303(a) and 46 CFR 27.305(a).

46 CFR Part 27 contains the regulations for provisions of fire protection and fire suppression equipment on towing vessels.

46 CFR 27.303 states that towing vessels in inland service and towing vessels in ocean or coastal service whose construction was contracted for before August 27, 2003 must carry both the minimum number of hand portable fire extinguishers required by subpart 25.30 of this part and, by April 29, 2005, either an approved B-V semi-portable fire extinguishing system to protect the engine room or a fixed fire extinguishing system installed to protect the engine room of the vessel.

46 CFR 27.305 states that towing vessels in ocean or coastal service whose construction was contracted for on or after August 27, 2003 must carry the minimum number of hand portable fire extinguishers required by subpart 25.30 of this part, an approved B-V semi-portable fire extinguishing system to protect the engine room, and a fixed fire-extinguishing system to protect the engine room. This section does not apply to any towing vessel pushing a barge ahead, or hauling a barge alongside, when the barge's coastwise or Great Lakes route is restricted (as indicated on the certificate of inspection), so that the barge may operate in fair weather only, within 12 miles of shore, or with words of that effect.

As stated above 46 CFR 27.303(a) and 46 CFR 27.305(a)(1) refer to subpart 25.30 for the minimum number of hand portable fire extinguishers required, but do not refer to subpart 25.30 for a B-III semi-portable fire extinguishing system. 46 CFR 25.30-10(c) states that sizes I and II are hand-portable fire extinguishers. 46 CFR 25.30-10(c) states sizes III, IV, and V are semi-portable fire extinguishers.

On June 18, 2004 the final rule was published adding 46 CFR 27.303 and 46 CFR 27.305 to 46 CFR Part 27 Towing Vessel regulations. Prior to this the B-III fire extinguishing system was required.


Q: What do I do if during an UTV examination I find out the fire suppression company used liquid level indicators rather than weighing the CO2 cylinders while conducting the annual servicing of the vessel's fixed CO2 system?

Ans: National Fire Protection Association (NFPA) standard 12 / states all high pressure cylinders shall be weighed. The Coast Guard and NFPA require CO2 cylinders to be weighed to verify the cylinder contains the proper amount of CO2. Using liquid level indicators is not an acceptable alternative to weighing CO2 cylinders. If you come across this situation, explain to the towing vessel representative that the Coast Guard does not recognize the use of liquid level indicators and request they have the fire suppression company weigh the CO2 cylinders at the next annual servicing.

In NFPA 12 Annex G General Information on Carbon Dioxide it states the following:

"As the temperature of the CO2 liquid increases, the pressure also increases. As the pressure increases, the density of the vapor over the liquid increases. On the other hand, the liquid expands as the temperature goes up and its density decreases. At 87.8°F (31°C), the liquid and the vapor have the same density, and of course the liquid phase disappears. This is called the critical temperature for carbon dioxide. Below the critical temperature [87.8°F (31°C)], carbon dioxide in a closed container is part liquid and part gas. Above the critical temperature, it is entirely gas."

Note: There was a Navigation and Vessel Inspection Circular (NVIC) No. 8-73 (Alternate means of determining the weight of CO2 in fire extinguishing systems) that did allow the use of liquid level indicators in lieu of weighing the CO2 cylinders however, the NVIC has been cancelled.


Q: Can Halon 1301 be used as a firefighting suppression agent on an uninspected towing vessel?

Ans: 46 CFR 27.100 defines fixed fire-extinguishing systems as:

1. A carbon-dioxide system that satisfies 46 CFR subpart 76.15 and is approved by the Commandant;
2. A manually-operated clean-agent system that satisfies the National Fire Protection Association (NFPA) Standard 2001 (incorporated by reference in Sec. 27.102) and is approved by the Commandant; or
3. A manually-operated water-mist system that satisfies NFPA Standard 750 (incorporated by reference in Sec. 27.102) and is approved by the Commandant.

While some "clean agents" are listed in the National Fire Protection Association (NFPA) Standard 2001 (incorporated by reference in Sec. 27.102) Halon 1301 is not.

The Lifesaving and Fire Safety Division's (CG-5214) website indicates that the production of Halon 1301 fire fighting agent was terminated effective January 1, 1994, and the installation of new Halon systems on SOLAS ships is prohibited. However, existing systems may be retained if in good and serviceable condition. The best reference to use for a Halon 1301 systems is NVIC 06-72 Change 1.

National Fire Protection Association (NFPA) 12A (Standard on Halon 1301 Fire Extinguishing Systems) should be used as guidance to assist with conducting inspections and maintenance on existing fixed Halon fire extinguishing systems.


Q. What do I do if I find a Hillersafe fire detection system during a UTV examination?

Ans. See Marine Inspection Notice 06-11 HillerSafe Fire Detection Systems on Uninspected Towing Vessels



Q. What fire detection systems can be considered excess equipment under Policy Letter 10-06?

Ans. The engine room fire detection system is required by 46 CFR 27.203 and therefore is not considered excess equipment under Policy Letter 10-06. However, if a vessel has additional fire detection systems in other spaces of the vessel, they may be considered excess equipment if they meet the requirements contained in paragraph 5-c of the Policy Letter.

In accordance with CG-543 Policy Letter 10-06, existing fire detection systems and equipment that are carried and designated by the operator as excess are exempt from 46 CFR 27.203 (c) through (g) provided it (the equipment) is listed by an independent testing laboratory and is designed, installed, tested, and maintained in accordance with the equipment manufacturer's recommendations and relevant NFPA standard(s).

As an example, a vessel that is fitted with the required engine room fire detection system might also have a galley fire detection system. In this case, the galley system may be considered excess if it does not meet the requirements of 46 CFR 27.203 but does fall within the guidelines set forth in CG-543 Policy Letter 10-06.


Q. Can a NICET Level IV, SET certify a fire detection system on board an uninspected towing vessel (UTV)?

Ans: Only on a case by case basis by submitting a request for equivalency. 46 CFR 27.203(g) states that the required engine-room fire detecting system needs to be certified by a Registered Professional Engineer, or by a recognized classification society.

A person having the NICET Level IV, SET Technician Certification trained in sub-fields of Fire Alarm and/or Special Hazards Suppression Systems can be considered equivalent to a Registered Professional Engineer or classification society as required in 46 CFR 27.203(g). The UTV owner/operator must request an equivalency for the specific NICET Level IV SET Technician that the owner/operator wants to use. The owner/operator of the UTV must forward the equivalency request  to the local Coast Guard office to be processed. A guide detailing how to submit an equivalency request can be found under Policy and Guidance in the Towing Vessel National Center of Expertise's website.

Once the NICET Level IV, SET Technician has been granted equivalency approval from Coast Guard COMDT (CG-5431) the Marine Inspectors and Towing Vessel Examiners should require letters attesting to the installation of fire detection systems to bear the technician's NICET certified mark. Similar to a PE, NICET certified individuals receive a certification number. Any display of the NICET Certified Mark must include the following information about the corresponding NICET-certified person:
Certification Number
Level and/or Grade

When the NICET Level IV, SET Technician certifies a fire detecting system, the CG issued equivalency letter and the NICET certification letter should be kept together on board the vessel or be able to be produced on demand if required by the CG.

NICET is a not-for-profit organization created by the National Society of Professional Engineers to serve the certification needs of the engineering technology community. NICET certification is a tool to measure technical knowledge and skills. This certification program was designed for engineering technicians working in the fire alarm industry who engage in a combination of the following fire alarm systems activities: system layout (plan preparation), system equipment selection, system installation, system acceptance testing, system trouble-shooting, system servicing, and system sales. Technical areas covered include applicable codes and standards, types of signaling systems, supervision requirements, types of fire and smoke detectors, building occupancy considerations, basic electricity and electronics, and physical science fundamentals.

Information on NICET Level IV qualification requirements can be found at their website.


Q: What is the difference between USCG Approved and Listed by Independent Testing Laboratory with regard to fire detection systems for installation aboard UTVs?

ANS: The difference is that the fire detection systems are qualified under different processes. The Listed by Independent Testing Laboratory process is the standard shore-side process in the US. This process focuses on the individual components and devices. Each model of a device (e.g., smoke detector, horn/strobe, pull-station, and control panel) is certified by the laboratory (i.e., UL, FM, and Intertek) as meeting the current appropriate national standard as produced. The listing of the control panel along with the manufacturer's instructions will identify compatible devices to be used with that control panel. The system designer/installer must ensure that all devices being used in a system are compatible.

The USCG Approval process follows the standard maritime tradition of approving a complete system which imposes a limitation that all components or devices must be from an approved component list. These systems have met the requirements of 46 CFR 161.002 which includes additional environmental tests for suitability for ship-board installation.

UTV's are required to have either a USCG approved or Listed fire detection system and thus UTV owner/operators and Professional Engineers (PE) who certify installations of fire detection systems aboard UTVs should be aware of these nuances:

• If the fire detection system is USCG Approved then the PE should ensure that all the components are from the system's list of approved components. Any deviations from the approved list will void the approval status.

• If the device (i.e. control panel) is Listed by Independent Testing Laboratory, then the PE should ensure that each component (i.e., detector) is compatible. In addition, regulations require that each compatible detector, control panel and fire alarm must also be Listed by Independent Testing Laboratory [46 CFR 27.203(a)]

Owner/operators should also be aware that some detection systems may be USCG Approved only for a certain class of vessels, such as small passenger vessels; which would not satisfy the fire detection requirements for Uninspected Towing Vessels. However, if components of that same system were Listed by UL or others, then it would satisfy the requirements of 46 CFR 27.203(a).

For more information on CG type approval, check out CGs Life Saving & Fire Safety Division (CG-521) website.


Q: What are the requirements for the location of the remote fuel shut-off valves?

Ans: The fuel shut off valves should be located near the source of the fuel supply. This means near the storage tank, day tank or fuel distributions manifold.

46 CFR 27.207 states that to stop the flow of fuel in the event of a break in the fuel line, you must have a positive, remote fuel-shut-off valve fitted on any fuel line that supplies fuel directly to an engine or generator. The valve must be near the source of supply (for instance, at the day tank, storage tank, or fuel-distribution manifold). Furthermore, it must be operable from a safe place outside the space where the valve is installed. Each remote valve control should be marked in clearly legible letters, at least 25 millimeters (1 inch) high, indicating the purpose of the valve and the way to operate it.

This requirement, derived from the final rule, states that any fuel line subject to internal head pressure from the fuel tank must be provided with a remotely operable fuel shut-off valve. The intent is to require a means to stop the main supply of fuel to the engine room during a fire. Coast Guard data shows that failure of fuel lines and flexible hoses are among the leading causes of fires in engine rooms on towing vessels. Fuel leaking and spraying from gravity tanks significantly increases the magnitude of these fires and makes these fires almost impossible to extinguish without outside assistance.

Only a fuel line directly supplying an engine (or generator) needs a remotely operable positive shut-off valve.

The shut-off valves should be installed as follows:
  1. If you have a day tank supplying fuel, install the shut-off valve at the day tank;
  2. If you have a fuel-distribution manifold only (no day tank), install the shut-off valve in the single fuel supply line after (downstream of) the manifold; or
  3. If you have a fuel tank directly supplying an engine or a generator, without the use of a day tank, a storage tank, or a fuel-distribution manifold, install the shut-off valve at the fuel tank.

Fuel shut-off valves have been found located at the end of the fuel piping before the fuel hose which is connected to the engine. Sometimes these fuel shut off valves are over 30 feet away from the fuel tank. The vessel owner/operators are calling these valves engine shutdowns. The location of these engine shutdown valves does not meet the intent of 46 CFR 27.207. The vessel owner/operator may continue to use the engine shutdown valves but they must also install fuel shut-off valves at the proper locations.

During the towing vessel examination the Coast Guard examiner should verify the proper location of the fuel shut-off valves and witness the vessel's representative conducting an operational test from the remote location to verify the fuel shut-off valves close properly. A number of towing vessels have the fuel shut-off valves located in the vessel's fuel tanks. During construction of towing vessels some shipyards installed these fuel shut-off valves in the fuel tanks and installed a reach rod to open and close the valve from the main deck. The examiner should have the vessel's representative close and open the fuel shut-off valve using the reach rod to verify that the valve is functioning properly.

The regulations do not specify an allowable distance between the shutoff valve and the storage tank, day tank or fuel distribution manifold. On some towing vessels, this distance should be minimized to reduce the chances of fire damage to attached piping. If it is necessary to locate the valve away from the storage tank, day tank or fuel distribution manifold, then the owner/operator will have to demonstrate that an equivalent level of protection can be provided. 46 CFR 24.15-1 gives the Commandant the authority to accept in substitution an alternative arrangement and grant an equivalency.

An example of an equivalent protection would be to install extra-heavy schedule 80 piping with all welded connections between the shutoff valve and the fuel tank. If the towing vessel owner/operator wants to request an equivalency they should submit their request through their local Coast Guard office. Some towing vessel owners/operators have requested equivalency for their fuel valve locations and have been granted approvals. Equivalency approvals can be granted for specific vessels or a company's fleet of vessels. An approved equivalency cannot be utilized by other companies. Each towing vessel company must obtain their own equivalency approvals as outlined in 46 CFR 24.15.


Q. What is the policy for CO2 or Dry Chemical portable or semi-portable fire extinguishers found onboard towing vessels that have no markings or proof they meet UL or Coast Guard standards?

Ans. If the vessel representative wants to keep the extinguisher(s) in service onboard the vessel, he/she will have to prove it is UL or CG approved. If the vessel representative is unable to provide proof the extinguisher(s) is an approved type, it will need to be replaced with an approved extinguisher(s).

46 CFR 25.30-5(b) requires all hand portable and sem-iportable fire extinguishers on board UTVs to be an approved type (i.e. Coast Guard approved). Navigation and Vessel Inspection Circular (NVIC) No. 13-86 provides guidance for accepting certain UL listed extinguishers as meeting the carriage requirements for approved extinguishers for commercial vessels. Design specifications for portable fire extinguishers can be found in 46 CFR 162.028. Design specifications for semi-portable fire extinguishers can be found in 46 CFR 162.039.

Search the Coast Guard approved equipment list.

Search the UL online certification directory.

For vessels contracted for prior to November 19, 1952 see 46 CFR 25.30-90 for possible acceptance of existing equipment that have no markings or proof they meet UL or Coast Guard standards.


Q. Where can I find information on maintenance and inspections required for portable fire extinguishers?

Ans. National Fire Protection Association (NFPA) 10 Standard for Portable Fire Extinguishers.

You may obtain a copy of NFPA 10 through the National Fire Protection Association.

IAW 46 CFR 27.100(d), the owner of a towing vessel is required to test and maintain all the equipment required by this part in accordance with the attached nameplate or manufacturer's approved design manual. All USCG/UL approved portable fire extinguishers will have a statement on the label indicating the extinguisher is to be inspected and maintained IAW NFPA 10. NFPA 10 chapter 7 is guidance for inspection, maintenance, and recharging of portable fire extinguishers. NFPA 10 chapter 8 is guidance for hydrostatic testing of portable fire extinguishers.


Q. 27 CFR 27.301 (e) allows for a self-priming/power driven portable fire pump in lieu of a fixed fire-pump. What does self-priming mean?

Ans. The term self-priming means the fire pump is able to create its own suction by priming itself independently without adding water to the pump casing or the suction hose. A device attached to the pump such as an exhaust primer or hand primer that requires the operator to pull the air out of the pump or suction hose is acceptable.

Note: Some pumps that are sold as self-priming pumps might not be fitted with an exhaust primer or hand primer. This type of self-priming pump will typically have a water reservoir built into the casing that allows the pump to self prime by recirculating water within the pump when it is first started. These pumps only have self-priming capability if the pump retains priming water from the previous pumping cycle. Self-priming pumps with a water reservoir that have been stored for a long period of time, or which are used in below-freezing weather, may not be able to pump effectively if the reservoir is low on water.

Owner operators are reminded of the requirement in 46 CFR 27.100(d) to maintain all fire-fighting equipment in accordance with the manufacturer's instructions. 46 CFR 27.209(a)(1)(i) requires all crewmembers to know how to operate all of the fire-extinguishing equipment on board the vessel. 46 CFR 209(c)(2) requires breaking out emergency equipment during the monthly drill. If the manufacturer's instructions don't require a shorter interval for operational testing of the pump, at a minimum, monthly testing by vessel crewmembers is highly recommended to ensure the pump is properly maintained, is ready for immediate use in an emergency and the crew is proficient in its operation. 

 Notes, Recommendations, and/or Discrepancies


Q. How long can deficiencies (discrepancies) issued during an industry initiated examination remain open before a new UTV examination will be required?

Ans. As a general rule, a maximum of ninety (90) days can be allowed at the local level before the UTV examination will have to be completely redone. Typically, the time given to correct deficiencies issued during an UTV examination should be a much shorter timeframe (i.e. 30 days or less). The 90 day time limit at the local level is to allow the COTP the ability to work with the owner/operator if extenuating issues exist (i.e. a part needs to be ordered/delivered).


Q. When is it appropriate to issue a Captain of the Port Order versus CG-835 to a towing vessel which does not conform to applicable laws or regulations?

Ans. In accordance with 33 CFR 160.111, The Captain Of The Port order may be issued to an inspected or uninspected towing vessel when the COTP has reasonable cause to believe that the vessel is not in compliance with any regulation, law or treaty or that the vessel does not satisfy the conditions for vessel operations specified in 33 CFR 160.113 or that the COTP order is justified in the interest of safety by the condition of the vessel.

The COTP order is an operational tool and should be used prudently and judiciously.

The CG-835 is issued to a non-conforming inspected vessel only, such as a seagoing towing vessel greater than or equal to 300 GRT. Therefore, CG-835 is not appropriate for use on uninspected towing vessels.



Q: What is Assistance Towing?

ANS: Assistance towing is defined in 46 CFR 10.107 as towing a disabled vessel for consideration. A disabled vessel is a vessel that needs assistance, whether docked, moored, anchored, aground, adrift, or underway, but does not mean a barge or any other vessel not regularly operated under its own power.

Q: Is the Coast Guard's Towing Vessel Bridging Program focused on vessels used for assistance towing?

ANS: No. The Towing Vessel Bridging Program's objective is to ease the uninspected towing vessel operator's transition into an inspected status. Only towing vessels that are subject to the proposed Subchapter M fall under this Program. Under the current proposed rule, assistance towing vessels (along with workboats, and towboats under 26 ft. that do not tow hazardous cargoes) will potentially be addressed in a future rulemaking, and therefore should not be targeted in any phase of the Towing Vessel Bridging Program.


Q: What does the term replacement in kind mean and what is the significance of the term?

ANS: Components (parts) of a vessel's system wear out and/or become outdated over time necessitating replacement. When replacing a component in a Coast Guard type approved or certified system on a vessel it should be a replacement in kind which means it meets the specifications and functionality of the original component and the installation does not require modifications to other system components. If replacement in kind components are not used then the type approval and/or the system certification may become invalid.

For example, fire detection systems on UTVs should be both type approved and certified as complying with the requirements in 46 CFR 27.203 by a Registered Professional Engineer or a recognized classification society. If the fire control panel for the system needed to be replaced and the approval number for the replacement panel matched the original panel, you can consider it to be a replacement in kind. If the system is a laboratory listed system, as permitted in the regulations, and the panel is made by the same manufacturer, the manufacturer states that new panel is designed to be a drop-in replacement for the old panel, and there are no changes in wiring to and/or from the panel, then you can consider it a replacement in kind. A letter from the manufacturer, not a vendor, would be good objective evidence that the new panel was a replacement in kind. This could also be addressed in the manufacturer's design manual for the system or updated parts listing. If there are any changes to the system design (i.e. power demands, wiring, etc.) or compatibility issues with other components (i.e. detectors), then it should not be considered a replacement in kind and verification of type approval and recertification by a Registered Professional Engineer or a recognized classification society should be required.


Q: When can a vessel use gross register tonnage (GRT) instead of convention tonnage (GTITC) for applicability of US laws and international conventions?

Ans: Each vessel will have to be considered separately. The key document UTV examiners should use to determine the applicability of tonnage measurement systems to UTVs is NVIC 11-93 Ch-3. Notes on NVIC 11-93: On page 2 of the cover letter to the NVIC in paragraph 2.g the date “July 18, 1982 should read July 18, 1994. In Table 5 of the NVIC in the all other vessels paragraph within the International Conventions section both instances of the date July 18, 1982 should read July 18, 1994.

Key points to remember: (1) Vessels built after July 18, 1994, must comply with ALL applicable U.S. and international requirements using their GTITC and should have a complete suite of international certificates to engage in foreign voyages; and (2) Vessels built before that date must comply with certain U.S. and international requirements using their GTITC (including ISM, ISPS, and LRIT), but they can use their GRT for many other U.S. and international requirements (some parts of SOLAS and MARPOL) that became law before July 19, 1994.

If initial question(s) about tonnage applicability for towing vessels cannot be answered by NVIC 11-93 Ch-3, the question(s) should be directed to CG-5431 (Scott Kuhaneck or Erik Johnson). They can be contacted directly via telephone or email. In addition, you can send e-mail inquiries to

In some cases, the question may be more appropriately answered by the Tonnage Division at the Coast Guard Marine Safety Center (MSC-4). This is particularly true when a question regarding tonnage applicability cannot be answered by CG-5431 or when a formal, vessel-specific interpretation of tonnage application is needed/desired. If a determination from MSC-4 is sought, they would like the owner to seek interpretation of tonnage applicability by submitting a request formally to the MSC using the MSC email process ( ), this is similar to plan review. As an alternative, the local Coast Guard Sector can submit a similar request on behalf of the owner, so that a more formal response can be promulgated and used for future reference.


Q: How is manning determined if a vessel has tonnages measured under both conventional (GT ITC) and regulatory (GRT) measurement systems?

Ans: The Coast Guard Headquarters, Office of Commercial Vessel Compliance has provided a table to illustrate the applicability of tonnage based manning requirements for dual-tonnage vessels. This table clarifies that for vessels measured under both 46 U.S.C. Chapters 143 and 145, the Regulatory Measurement System (GRT) is used to determine the number of crew required and, in certain cases depending on voyage and vessel particulars, the Convention Measurement System (GT ITC) is applied for determining the tonnage level of MMC/STCW endorsements. This table is intended to compliment Marine Safety Manual Volume III.