Towing vessels that engage in international (foreign) voyages must be in compliance with all applicable international requirements.  Determining applicability of international requirements can be a complex and confusing process.  Each vessel is evaluated on a case by case basis taking into account the vessels build date, the application of the proper tonnage system and when the provisions of the international conventions became effective.  Key to making certificate and equipment carriage determinations is being able to apply the proper tonnage system to the vessel.  The Coast Guards primary document to determine the applicability of tonnage measurement systems to a vessel is NVIC 11-93 Ch-3.  

Vessels built on or after July 18, 1994, must comply with ALL international requirements using their GT ITC and should have a complete suite of international certificates to engage in foreign voyages.  

Vessels built before July 18, 1994 can use their GRT for many international requirements, but they must comply with certain international requirements using their GT ITC:  

A vessel built before 18JUL1994 can use GRT for:

  • MARPOL (currently all annexes except Annex VI) 
  • SOLAS (with the exception of ISM and ISPS) 
  • Safe Manning Document.  

 A vessel built before 18JUL1994 must use GT ITC for:

  • LRIT
  • ISM
  • ISPS
  • MARPOL Annex VI
  • STCW 

There have been instances of foreign governments requiring certain certificates/documents to be onboard U.S. flagged vessels while in their ports even when those certificates/documents are not required by an international convention – i.e Safe Manning Documents (SMD) and International Ship Security Certificates (ISSC).  To facilitate the operation of the U.S. maritime industry, upon request, the CG can issue international certificates to a U.S. flag vessel even when an international convention does not apply to the vessel.  Owners and operators of towing vessels that engaged on international (foreign) voyages should be encouraged to take advantage of this opportunity to avoid delays while conducting business in a foreign port.  

Items to check:

  • All applicable certificates current and valid.
  • Vessel meets carriage requirements of certificates.
  • All required equipment is properly maintained, in serviceable condition and ready for immediate use.    

Additional Guidance:

NVIC 11-93 Ch-3 Applicability of Tonnage Measurement Systems to U.S. Flag Vessels
CVC-WI-004 U.S. Flag Interpretations on ISM Code