46 CFR 2.10-20 requires a vessel owner to pay an annual inspection fee before inspection or examination services are provided. Annual inspection fees are listed in 46 CFR Table 2.10-101. Failure to pay the required fees can result in vessel inspection delays and/or penalties as outlined in 46 CFR 2.10-135.

Items to check:

• Annual inspection fees paid.
• Delinquent inspection fees, if any, paid.

Regulatory Cites:

46 CFR 2.10-20 General requirements
46 CFR Table 2.10-101 Annual Vessel Inspection Fees for U.S. and Foreign Vessels Requiring a Certificate of Inspection
46 CFR 2.10-135 Penalties

Items to check:

• Annual inspections completed within three (3) months of the COI anniversary date.
• Inspection completed by cognizant OCMI.
• Coast Guard Endorsement on current COI after satisfactory Annual Inspection, or CG-835 retained for correction of deficiencies.

Regulatory Cite:

46 CFR 137.200 Documenting Compliance for the Coast Guard Inspection Option

Items to check:

• Annual survey completed within three (3) months before or after the COI anniversary date.
• Surveys completed by Surveyor from a TPO.
• TSMS procedures followed for survey.
• Conduct of survey follows 46 CFR 137.215.
• Applicable TSMS sections available to Surveyor.
• TPO issued a survey report as required by 46 CFR 137.205(b).

Regulatory Cites:

46 CFR 137.202 Documenting compliance for the TSMS inspection option
46 CFR 137.205 External survey program
46 CFR 137.215 General conduct of survey
46 CFR 137.220 Scope

Items to check:

• Annual survey conducted as one event or scheduled so that each required item is surveyed with successive surveys not exceeding one(1) year on an individual item.
• Company issued a report that meets requirements in 46 CFR 137.135.
• TSMS includes:
  • Procedures for survey and testing that follow 46 CFR 137.215.
  • Equipment, systems and onboard procedures to be surveyed.
  • Identification of items that would keep the vessel out of service; deficiencies, non-conformities, survey deficiencies, corrective action reports.
  • Procedures for documenting and reporting non-conformities and deficiencies.
  • Procedures for reporting and correcting major non-conformities.
  • Responsible person in management who can:
    • Stop vessel operations pending correction of non-conformities and deficiencies.
    • Oversee compliance activities.
    • Track and verify that non-conformities and deficiencies were corrected.
  • Procedures for recordkeeping.
  • Procedures for assigning competent personnel as surveyors.    

Regulatory Cites:

46 CFR 137.135 Reports and documentation required for the TSMS option.
46 CFR 137.202 Documenting compliance for the TSMS inspection option

46 CFR 137.210 Internal survey program

46 CFR 137.215 General conduct of survey
46 CFR 137.220 Scope

Certain types of equipment are required to be approved by the Coast Guard to meet specific standards. Typically lifesaving and fire protection equipment fall under this category.  If a piece of equipment is “Coast Guard Approved” it will list its approval series, typically a six digit number. A searchable list of Coast Guard Approved equipment and approval series can be accessed through the Coast Guard Maritime Information Exchange, USCG Approved Equipment Listing Database (EQList).

Items to check:

• Lifesaving equipment Coast Guard approved.
• Portable extinguishers, semi-portable fire extinguishers and fixed fire extinguishing systems Coast Guard approved.      

Regulatory Cites:

46 CFR 136.110 Definitions: “Approval Series” and "Fixed fire-extinguishing system"

46 CFR 136.175 Approved Equipment

46 CFR 141.200 Approved Equipment “Lifesaving”

46 CFR 142.215 Approved Equipment “Firefighting”

Items to Check:

• Valid COI on board vessel.
• Vessel in compliance with terms of the COI.
• Original COI on board and properly posted or, if posting is impracticable, properly stored and readily available.

Regulatory Cites:

46 CFR 136.200 Certificate Required

46 CFR 136.220 Posting

46 CFR 136.230 Routes Permitted

46 CFR 140.205 General Vessel Operation

When submitting an application for inspection, the owner or managing operator will need to specify which inspection option (TSMS or Coast Guard) will be implemented on the vessel.

Items to check:

• Please see CVC WI-013 Towing Vessel COI Inspection under TSMS Option for amplifying information when submitting an COI application for TSMS Option.
• Schedule Inspection for Initial Certification with cognizant OCMI at least 3 months (90 days) before inspection for certification.
• Submit Form CG-3752 “Application for inspection of U.S. Vessel” at least 30 days prior to inspection for certification.
• For Initial Certification:
  • Vessel Particular Information.
  • Number of Persons in addition to crew.
• For Renewals:
  • Any changes to the information provided on the previous CG-3752 (application for inspection).
  • A description of any modifications to the vessel.

Regulatory Cite:

46 CFR 136.130 Options for documenting compliance to obtain a Certificate of Inspection
46 CFR 136.210 Obtaining or renewing a COI

Additional Information:

CG-CVC Policy Letter 20-01 - Subchapter M Enforcement Posture for Certificate of Inspection Phase-In Requirements
CVC Work Instruction WI-013 - Towing Vessel COI Inspection under TSMS Option
CVC Work Instruction WI 015 - Determinations for a Vessel's Keel Laid Date or Similar Stage of Construction
CVC Work Instruction WI 018 - Laid up Inspected/Examined Vessels

Regardless of the option chosen to obtain a COI, upon obtaining the initial COI each towing vessel must conduct drydock and Internal structural examinations (ISE) at the appropriate interval based on Fresh or Saltwater Service:

• For freshwater service (exposed to saltwater less than 6 months in any 12-month period since last examination) at least once every 5 years.
• For saltwater service (exposed to saltwater more than 6 months in any 12-month period since last examination) at least twice every 5 years, with not more than 36 months between examinations. 

As an alternative, a towing vessel can comply with drydock and ISE requirements by:

• Maintaining a valid load line certificate – see 46 CFR 137.320; or,
• Maintaining class by ABS or another recognized classification society accepted by the Coast Guard – see 46 CFR 137.322. 

Note: In instances where a vessel is required to conduct two drydocks and ISEs for salt water service, the allowance to accept load line or class drydock and ISEs only counts for one of the required two examinations.  

U.S. vessel owners and operators desiring to utilize an underwater survey in lieu of drydocking (UWILD) should review the guidance in NVIC 1-89, Underwater Survey Guidance.  UWILD is an optional compliance option and, if utilized, permits the owner to alternate drydocks with underwater surveys.  For instance, a vessel in salt water service that would normally be drydocked at years 2.5, 5, 7.5, 10, 12.5, and 15 could conduct these alternate underwater surveys instead of drydocking at years 2.5, 7.5, and 12.5.

Items to check:

• Valid Load Line Certificate.
  OR
• Vessel maintains class and meets RCS rules on drydocking and ISE requirements.
  OR
• Complete drydock (or Coast Guard approved UWILD) and ISE at the correct interval:
• Salt-Water: Twice every five (5) years, with not more than thirty six (36) months between examinations.
• Fresh-Water: At least once every five (5) years.

Regulatory Cites:

46 CFR 137.300 Intervals for drydock and internal structural examinations

46 CFR 137.320 Vessels holding a valid load line certificate

46 CFR 137.322 Classed Vessels

46 CFR 137.335 Underwater survey in lieu of drydocking

Additional Guidance:

NVIC 1-89, Underwater Survey Guidance

CVC WI-029 - Drydock Exams, Underwater Survey in Lieu of Drydocking and Drydock Extension Policy Clarifications

CVC-PL 21-03 - Use of Doublers for Repairs

Items to check:

• Additional documentation submitted with Form CG-3752 “Application for inspection of U.S. Vessel”:
  • Valid TSMS Certificate.
  • Report of a Survey, per 46 CFR 137.215 that vessel complies with Sub-M.
  • Objective Evidence that operator and vessels are in compliance with TSMS.
  • Objective Evidence of External or Internal survey program.
  • Objective Evidence that vessel has undergone drydock and internal structural examination.
• Copy of valid TSMS certificate on board vessel.
• External vessel audit conducted prior to issuance of initial COI for vessels operated for six (6) months or more by owner or managing operator.
• External vessel audit conducted no later than six (6) months after issuance of initial COI for vessels operated for six(6) months or less prior to receiving the initial COI.
• External vessel audit conducted at least once during the five (5) year period of validity of the TSMS certificate.
• Results of external vessel audits submitted to cognizant OCMI within 30 days of completion.

Regulatory Cites:

46 CFR 136.210 Obtaining or renewing a COI

46 CFR 137.202 Documenting compliance for the TSMS option

46 CFR 137.305 Documenting compliance for the TSMS option

46 CFR 138.305 TSMS Certificate

46 CFR 138.315 External audits for TSMS certificate

46 CFR 138.505 Submittal of External Audit Results

Additional Guidance:

CG-CVC Policy Letter 17-03 Certificate of Inspection (COI) Phase-In Period for Existing Towing Vessels Using the TSMS Option Under 46, Code of Federal Regulation (CFR)Subchapter M