Coast Guard Enforcement Posture To Change After July 19

On April 11,  the Coast Guard released CG-CVC Policy Letter 20-01, Change 1, to clarify its Subchapter M enforcement posture after the Certificate of Inspection (COI) phase-in period for towing vessels ends on July 19. That’s the date by which 100 percent of towing vessels are required to have a COI.

All towing vessels were expected to be in compliance with Subchapter M requirements by 2018, but the Coast Guard gave owners a four-year phase-in period in which to obtain the actual COIs, with 25 percent of vessels expected to have them by July 22, 2019; 50 percent by July 20, 2020; 75 percent by July 19, 2021; and 100 percent by July 19 of this year. 

The policy letter requires Officers in Charge of Marine Inspection to issue a CG-835V for non-compliance to any towing vessel that does not carry a valid COI beginning July 20 with deficiency code 60 (rectify deficiency prior to movement) to prohibit its operation until it is issued a COI or until its vessel status is changed to laid up or out of service.

Inactive towing vessels must continue to maintain a COI. The only other acceptable statuses are if vessels are laid up, out of service, scrapped or sunk. 

The full policy letter is available here.