There is no requirement in Subchapter M for new construction oversight by the Coast Guard or a TPO; however, TPOs who will be providing such oversight should develop their own oversight process and incorporate the same into their Quality Management System.
New towing vessels are required to verify compliance with Subchapter M design standards prior to issuance of the initial COI. Deviations from the verified design standards will need to be corrected before the vessel enters service. Existing towing vessels must have their proposed modifications verified for compliance with design standards prior to the modifications.
Verification of compliance with design standards conducted by a licensed professional engineer (PE) or a classification society are not conducted under the guidance of NVIC 10-82 or NVIC 10-92, so these verifications are not required to be submitted to the Coast Guard for final approval or authorization.
If the owner or managing operator would like the Coast Guard to conduct the design verification, they must first submit Form CG-3752, “Application for Inspection of U.S. Vessel,” to the cognizant OCMI where the construction will take place. The local OCMI will then provide guidance as to which plans are required for submission and identify which, if any, will be forwarded to the MSC for review.
Items to check:
- Required design verification complete IAW 46 CFR Part 144
- No deviations from verified design standards
46 CFR 144.135 Verification of compliance with design standards
46 CFR 144.140 Qualifications
46 CFR 144.145 Procedures for verification of compliance with design standards
NVIC 10-82, CH-2 Acceptance of Plan Review and Inspection Tasks Performed by the American Bureau of Shipping for New Construction or Major Modifications of U.S. Flag Vessels
NVIC 10-92 CH-2 Coast Guard Recognition of Registered Professional Engineer Certification of Compliance with Coast Guard Requirements
Marine Safety Center Technical Note 01-17, Guidance on Design Verification for Subchapter M Towing Vessels
Marine Safety Center Design Verification Guideline Number H1-18, Review of General Arrangements for Towing Vessels