Final Deadline for Subchapter M Phase-in Drawing Near

January 31, 2022

The U.S. Coast Guard on Monday issued a reminder to towing vessel owners and operators that the July 19, 2022 deadline for 100% Subchapter M phase-in is fast approaching. At that time, all towing vessels meeting the applicability criteria found in 46 CFR § 136.105 will be required to have on board a valid Certificate of Inspection (COI) issued by the Coast Guard.

Per 46 CFR 136.202, towing vessel owners and operators are responsible for ensuring that all their towing vessels receive a Certificate of Inspection (COI) before July 19, 2022. Failure to meet vessel certification requirements may result in CG-835V deficiencies, vessel delays, civil penalties, or additional enforcement actions.

© Ferrer Photography / Adobe Stock
© Ferrer Photography / Adobe Stock

Initial certification should be scheduled with the local Officer in Charge, Marine Inspection (OCMI) at least three months in advance of the desired inspection date, the Coast Guard said. Therefore, towing vessel owners and operators should schedule vessel initial inspections as soon as possible, but no later than April 20, 2022.

The Coast Guard noted that attendance is required for initial certification for both the Coast Guard Option and Towing Safety Management System (TSMS) Option, as described in 46 CFR § 136.130. Application for inspection should be made using the CG-Form 3752, “Application for Inspection of a U.S. Vessel.” OCMI contact information can be found on the Marine Inspectors Contact List on the CVC-1 webpage.

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