USCG Office of Commercial Vessel Compliance (CG-CVC)
Mission Management System (MMS) Work Instruction (WI)
Category
Title
SerialDisclaimer:

References:

Enclosure
ChangeSummary:

Inspected Towing Vessel Program
Towing Vessel COI Inspections Under TSMS Option
CVC-WI-013(7)Orig. Date
18Sep18

Rev. Date

06Nov23

This guidance is not a substitute for applicable legal requirements, nor is it itself a rule. It is not intended
to, nor does it impose legally-binding requirements on any party. It represents the Coast Guard’s current
thinking on this topic and may assist industry, mariners, the public, and the Coast Guard, as well as otherfederal and state regulators, in applying statutory and regulatory requirements. You can use an alternative
approach for complying with these requirements if the approach satisfies the requirements of theapplicable statutes and regulations. If you want to discuss an alternative approach (you are not required to
do so), you may contact the Coast Guard Office of Commercial Vessel Compliance (CG-CVC) at CGCVC@uscg.mil who is responsible for implementing this guidance.

(a) Title 46 Code of Federal Regulations (CFR), Chapter I, subchapter M – Towing
Vessels(b) Navigation and Vessel Inspection Circular (NVIC) No. 04 03, CH-1, Enclosure (1),
Guidance for verification of vessel security plans (VSP) on domestic vessels inaccordance with the Maritime Transportation Security Act (MTSA) regulations andInternational Ship & Port Facility Security (ISPS) Code(c) G-MOC Policy Letter 00-02: Five-Year COI and SOLAS Survey Intervals(d) CG-CVC Work Instruction CVC-WI-010(series), OCMI guidance on special
consideration for 46 CFR Subchapter M vessels(e) 46 United States Code (U.S.C.) § 3305(d), Scope and standards of inspection(f) CG-CVC Policy Letter 17-10, Deficiency recording and reporting for vessels using a
Towing Safety Management System (TSMS) option, dated November 28, 2017(g) CVC-FM-004(series) Towing Vessel Particulars(1) 46 CFR Subchapter M Compliance Timeline: TSMS Option(2) COI Inspection Table for Subchapter M
The following is a list of major changes found in revision 7.
• Removed original reference (b) CG-CVC Policy Letter 17-01, Use of UTV Decals,from the document, as the policy has been cancelled.
• Removed original reference (c) and incorporated CG-CVC Policy Letter 17-02,
CH.2, Use of Existing Safety Management Systems to Obtain an Initial Certificate ofInspection Under 46 CFR Subchapter M. The policy is cancelled and incorporated inparagraph D.2.d.2.
• Added new reference (c) providing guidance on 5-year COI issuance.
• Incorporated CG-CVC Policy Letter 18-01, CH. 2, Audit Schemes for TSMS Option
Vessels. The policy is cancelled and incorporated within paragraph D., D.1.a, D.1.b,
D.1.b.2, D.1.b.3, D.1.b.4, D.1.b.5, and D.2.
• Renumbered paragraphs in accordance with CVC-TM-001(series).
• Clarified required timelines for surveys for renewal in paragraphs D.1.a.1-2.
• Provided guidance on the Equivalency to the Fifth Year CG Inspection for Renewal
at 100% in D.1.a.3.
• Clarified language for audit requirements in paragraphs D.1.b.
• Clarified ‘initial COI’ language in paragraph D.2.
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Added COI renewal date language in paragraph D.3.
Clarified OCMI expectations for renewal COIs in paragraph D.3.b.
Outlined pilothouse alerter and towing machinery requirements for applicable vessels
in paragraph D.3.i.
Clarified change in inspection options in paragraphs D.4.
Clarified drydock endorsement requirements in paragraph E.4.
Added paragraphs F. Appeals and G. Questions.
Updated Enclosure (1) Subchapter M Compliance Timeline: TSMS Option.
Added Enclosure (2) COI Inspection Table for Subchapter M.

A. Purpose. This instruction provides guidance on the U.S. Flag Administration’s interpretations on theapplication and implementation of towing vessel Certificate of Inspection (COI) issuance under the
Towing Safety Management System (TSMS) option. Where no additional instructions orinterpretations are provided, reference (a) should be applied as written.
B. Background. As of July 20, 2018, all towing vessels must comply with the requirements of reference(a) and have received, or are making plans to receive, a COI from the Coast Guard in accordancewith 46 CFR § 136.202. Per reference (a), there are two options for documenting compliance forcertification: (1) the Coast Guard option or (2) the TSMS option.
C. Action. Officers in Charge, Marine Inspection (OCMI) should reference this guidance when issuing
a COI under 46 CFR subchapter M for inspected towing vessels choosing the TSMS option.
Enclosure (1) provides a flow chart to illustrate the TSMS compliance process.
D. Discussion. The TSMS option provides owners and managing operators (OMO) with the flexibility
to tailor their safety management systems (SMS), while ensuring an overall level of safety. The
verification of compliance with applicable regulations is confirmed through surveys and audits
completed by a Third Party Organization (TPO). OMOs electing the TSMS option must submit
applications for inspection to the cognizant OCMI where the inspection will take place, as outlinedin 46 CFR § 136.210.
1. Surveys and Audits.
a. Surveys: A survey is an annual examination of the vessel and systems to verify compliancewith applicable requirements. 1 Whether operating under an internal or external survey
program, the surveyor shall conduct a survey in accordance with 46 CFR § 137.215 andreport the same per 46 CFR § 137.135. Whichever survey program chosen by the OMO,
either internal or external (per 46 CFR part 137, subpart B), it shall be the same program fordrydock and internal structural surveys within 46 CFR part 137, subpart C. (i.e., internalsurvey program 46 CFR § 137.210 and internal survey program notifications for drydock 46
CFR § 137.315.)1) (Internal) The OMO completes a vessel survey under the internal survey program with
TPO oversight of the same. The OMO has two options as outlined below to complete thesurvey, Over Time or as a Single Event.
a) (Over Time) If the TSMS prescribes the internal survey to be conducted on a schedule
over time, the interval between successive surveys of any items cannot exceed 1 year
(365 days) per 46 CFR § 137.210(b).

1

46 CFR § 136.110.

2b) (Single Event) If the TSMS prescribes the internal survey is to be conducted as asingle event, then the survey shall be based on the anniversary date of the COI andmay take place within a six-month window, between 3 months prior to and 3 months
after the anniversary date of the COI. 2
2) (External) External surveys shall be managed in accordance with 46 CFR § 137.205 andconducted annually, within three months of the anniversary date of the COI. 3
3) Equivalency to the Fifth Year CG Inspection for Renewal COI at 100%.
a) Current Regulatory Requirement. Towing vessels subject to inspection undersubchapter M and using the TSMS option will be inspected at least once every 5
years per 46 CFR § 136.212. Vessels using the TSMS option must receive annual
surveys between the initial and renewal CG inspections 4 (i.e., CG inspection at initial
COI issuance and then another CG visit for the inspection for certification at the fiveyear renewal. Five annual surveys are required.) The CG inspection for Renewal of
the COI shall be in accordance with the CG-840 job aid and include 100% of theinspection items within the guidance document (i.e., a full CG inspection).
b) Reduced Risk-Based Inspection and Certification. Internal or external surveys, which
are conducted annually, serve to validate the compliance with 46 CFR subchapter M
and are an examination of the vessel, including its systems and equipment, to verify
compliance with applicable regulations, statues, conventions, and treaties. Thesesurveys are conducted by a third party (TPO or OMO) on TSMS option vessels to
replace the traditional CG annual inspection. In accordance with 46 CFR § 136.115,
as an equivalent level of safety, a reduced CG inspection at the time of COI renewal
may be conducted,i.

if an OMO provides the objective evidence that a full TSMS survey was
conducted that year;ii.

the TPO provides objective evidence that the vessel has no major nonconformities in the last 5 years; andiii.

the vessel has not been issued any code 30 deficiencies by the Coast Guard in
the last 5 years.

The CG inspection should be reduced in scope to the essential systems as noted in the
CG-840 book, labeled “T” for TSMS Option; however, if the CG Marine Inspector
finds significant deficiencies on essential systems, the exam will be expanded to a fullinspection.
c) The Reduced-Risk Based Inspection in paragraph b) must be documented by the
OCMI in MISLE (Special Note and within an Inspection Activity Narrative). The
request for this equivalency may be included with the CG-3752 application as with all
the other requirements per 46 CFR § 136.210. It should also be documented in the
TSMS procedures. Request and approval of this equivalency should be submitted to
the local OCMI, where the renewal inspection is to be completed. Requests forfurther equivalencies related to 46 CFR §§ 136.210, 136.212, 137.205 and 137.210,
shall only be sent to COMDT (CVC-1) for consideration.

46 CFR § 137.210(b).
46 CFR § 137.205(a)(3).
4
See Inspection of Towing Vessels, 81 Fed. Reg. 40022 (Jun. 20, 2016).
2
3

3

Year 00a) Current:
COI Initial
Issuance
Survey required.

Year 01

Year 02

Year 03

Year 04

Year 05

AnnualSurveyAnnualSurveyAnnualSurveyAnnualSurvey

COI Renewal(per 46 CFR §137.205/.210)(per 46 CFR §137.205/.210)(per 46 CFR §137.205/.210)(per 46 CFR §137.205/.210)

Annual Survey completed
and CG Inspection
completed (100% of items in
CG Job Aid 840 book)

AnnualSurveyAnnualSurveyAnnualSurveyAnnualSurvey

COI Renewal(per 46 CFR §137.205/.210)(per 46 CFR §137.205/.210)(per 46 CFR §137.205/.210)(per 46 CFR §137.205/.210)(per 46 CFR §136.210/137.135)b) Reduced RiskBased COI
Renewal :COI Initial
Issuance
Survey required.
(per 46 CFR §136.210/137.135)(per § 136.210)

Annual Survey completed
and submitted to the CG / nonon-conformities / no code
30s, etc. = CG Inspection
Reduced (CG Job Aid 840
book ~ 30% (“T” symbol))(per § 136.115)

b. Audits: An audit is a systematic, independent, and documented examination to determine
whether activities and related results comply with the TSMS or other approved SMS. 5 The
International Safety Management (ISM) Code is an internationally mandated SMS for
vessels subject to the International Convention for the Safety of Life at Sea, 1974, as
amended (SOLAS). The ISM Code is an international framework that requires two scheduled
vessel audits during the period of validity of the Safety Management Certificate to ensure
consistent application of the SMS on a vessel. Management and vessels are subject tointernal and external audits to assess compliance with the TSMS and the vessel standards ofSubchapter M.
1) (Internal) Internal management audits, per 46 CFR § 138.310, are conducted by aqualified auditor that has a direct affiliation to the vessel, owner, or managing operator
being audited. The auditor must be independent of the procedures being audited unless
this is impracticable due to the size and nature of the organization. The auditor may not
be the designated person, or any other person, within the organization that is responsiblefor development or implementation of the TSMS. 6 While the internal management audit
results must be documented and made available to the Coast Guard upon request, theaudit results are not required to be submitted as the objective evidence referenced in 46
CFR § 136.210(b)(1) for issuance of a COI. Internal management audits must be
conducted annually, to include all the OMOs towing vessels to which the TSMS applies,
within 3 months of the anniversary date of the TSMS certificate. 72) (External) External audits for obtaining and renewing a TSMS certificate are conducted
through a TPO and must include both management and vessel audits under 46 CFR §138.315. The TPO completes an external management audit prior to the issuance of the

46 CFR § 136.110.
46 CFR § 138.310(d).
746 CFR § 138.310.
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initial TSMS Certificate 8 and will conduct an external vessel audit either prior to or after
initial issuance of the COI depending on how long the vessel has been owned or operated
and subject to the TSMS. 9 This does not explicitly require these activities 10 to exist
within the TSMS at the time of an external audit for issuance of an initial TSMS
Certificate and should be verified by the TPO during subsequent audits to determine
compliance. The OMO will be issued a TSMS Certificate by a TPO when theirorganization is deemed in compliance with the TSMS requirements. 11 Therefore, TPOs
may issue an initial TSMS Certificate to an OMO after the TPO:a) Verifies that the OMOs TSMS meets the functional requirements and elements under
46 CFR §§ 138.215 and 138.220; and,b) Completes an external management audit to verify that the necessary policies andprocedures have been documented and implemented throughout the organization,
shore-side and on relevant vessels, to ensure a functional TSMS. Implementation
should include, at a minimum, the necessary policies, processes, and procedures are
published, promulgated, and rendered mandatory. 12
In accordance with 46 CFR §138.315(b)(1), vessels subject to an OMOs TSMS that havebeen owned or operated for 6 or more months are required to conduct an external vessel
audit prior to issuance of the initial COI. For vessels that have been owned or operated
for fewer than 6 months, 46 CFR § 138.315(b)(2) requires that an external vessel audit
must be conducted no later than 6 months after the issuance of the initial COI.
3) (Random External) An external audit of all vessels covered by a TSMS Certificate must
be conducted during the 5-year period of validity of the TSMS Certificate. 13 The vessels
must be selected randomly and distributed as evenly as possible. 14 The purpose of this is
to both promote a culture of continuous compliance and promote flexibility. The
following criteria should be used to ensure compliance with 46 CFR § 138.315:a) The vessel external audits are distributed as evenly as possible throughout the 5-year
validity of the TSMS Certificate;b) The vessels covered under the TSMS Certificate are selected at random for a given
external vessel audit; and,c) Each vessel covered under the TSMS Certificate receives no less than one external
vessel audit within the 5-year validity of the TSMS Certificate.
The random audit program should be developed by the approved TPO issuing the TSMS
Certificate. A TPO’s random external vessel audit program must be distinctly different
from an audit program with a fixed schedule for each vessel over the validity of the
TSMS Certificate. The scheduling, random vessel selection, and audit notification
process may occur upon issuance of the TSMS Certificate, or anytime thereafter within
the 5-year validity of the TSMS Certificate. The audit should generally occur within 3
846 CFR § 138.315(a)(1). A mid-period external management audit must be conducted between the 27th and 33rd month of
the [TSMS] certificate’s period of validity. 46 CFR § 138.315(a)(2).
946 CFR § 138.315.
10The Coast Guard interprets “activity” to mean the act of performing a procedure, not the procedure itself.
11
46 CFR § 138.305(a).
12
46 CFR § 138.410.
13
No random external vessel audits were required during the phase-in period listed in 46 CFR § 136.202, per the CVC Policy
Letter 18-01 Ch.1 (February 2022). Vessels associated with a TSMS certificate issued prior to the July 2022 deadline were
not expected to begin the random audit regimen, until the renewal of their associated TSMS certificate.
14
46 CFR § 138.315(b)(3).

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months before or after the scheduled date of the audit to ensure flexibility with
operational constraints. There is no requirement for an external audit to be completed
prior to the renewal of the COI. 15 During the COI inspection, the OCMI will verify that arandom external vessel audit has been completed for the vessel within the current or
previous 5-year validity of the TSMS Certificate depending on the timing of the COI
inspection in relation to TSMS Certificate date. The COI renewal package should include
objective evidence of conformity with the TSMS which may include survey reports,
internal audit reports, and other supporting information.
4) Equivalency to Random External Vessel Audit. As an equivalent to meeting therequirements of the random external vessel audit requirement under 46 CFR §138.315(b)(3), an OMO may request the TPO to perform two planned (i.e., non-random)
audits during the 5-year validity of the TSMS Certificate. 16 If this equivalency is used,the external audit should follow the audit scheme found in the ISM Code as much aspracticable, which is one planned external vessel audit conducted between the second andthird anniversary date of the TSMS Certificate with a second audit before the TSMS
Certificate renewal. This provision provides certainty to when vessels will be audited
while still promoting a culture of continuous compliance. In accordance with 46 CFR §136.115, this alternative arrangement is considered an equivalent level of safety that does
not require specific OCMI or CVC-4 approval but must be documented in the TSMS
applicable to the vessel.
5) (Delayed) For vessels subject to 46 CFR § 138.315(b)(1), the OCMI may issue a COI to a
vessel in substantial compliance with material, equipment, and operational requirements
and monitor progress towards full implementation of the TSMS and verify compliance
upon completion of the first mandatory external audit six months after issuance of theinitial COI. The process by which the OCMI may ensure substantial compliance is asfollows:a) Per 46 CFR § 136.210, the OMO must schedule the initial inspection for certification
at least three months in advance and submit an “Application for Inspection of U.S.
Vessels” via CG Form 3752 at least 30 days before the vessel will undergo theinspection. Additionally, under this regulation, the OMO must notify the OCMI ifthey intend to use the TSMS option and provide additional information to facilitate
Coast Guard certification. The OMO should further notify the OCMI that they request
inspection for certification and cannot meet the external vessel audit requirement
under 46 CFR § 138.315(b)(1).
b) The OCMI will review all necessary vessel and OMO information and may requestfrom the cognizant TPO additional information to establish objective evidence ofcompliance and determine whether an inspection for certification is appropriate basedon the circumstances of the case.
c) The OCMI will conduct an inspection for certification. Upon verification that thevessel is in substantial compliance with material, equipment, manning, andoperational requirements, the OCMI will issue the COI and CG-835V 17 (Code 705) 18
requirement with a compliance date six months from issuance. The CG-835V muststate:
46 CFR § 138.315 applies to the 5-year validity of the TSMS Certificate.
46 CFR § 136.115.
17
46 CFR § 2.01-10(a).
18
OCMIs should not issue a “work list item” under this provision.
15
16

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Provide objective evidence of a satisfactory external audit conductedby the cognizant third-party organization within six months of issuanceof the initial COI. Failure to complete and provide evidence of thisaudit will result in the vessel being reverted to the Coast Guard
inspection option, suspension of vessel operations, or COI revocation,
as determined by the OCMI.
d) If the vessel fails to satisfy the CG-835V requirement, the OCMI must determine the
OMOs intentions for the vessel and either revert the vessel to the Coast Guard
inspection option under 46 CFR § 137.200, suspend operations until the requirementsof reference (a) and any other relevant deficiencies are satisfied, or revoke the COI.
2. Initial Certification for Inspection Requirements. An initial COI is the first COI that a vessel
receives under 46 CFR subchapter M, regardless of the option chosen by the OMO. If an OMO
changes the inspection option from the USCG to TSMS option after the initial COI, the OMO
will be required to submit additional verifications per 46 CFR § 136.130(e) and 46 CFR §136.210(a)(2) and (b). As this is the first (new) COI issued under this new option, such vessels
shall receive a survey and external vessel audit from the TPO within the timeframes outlined tofulfill “the requirements for the new option.” (See § D.3. for more information regarding change
in inspection options after the initial COI has been issued.) If a vessel changes the inspection
option from TSMS to USCG option, a CG inspection for a new COI is required.
a. Six (6) Months Before Initial 19 COI Inspection. Per 46 CFR § 138.115, OMOs that selectthe TSMS option must obtain a TSMS certificate issued under 46 CFR § 138.305 at least six
months before obtaining a COI for any of their vessels covered under the TSMS certificate.
There is no requirement for a TPO to verify that an OMO has implemented a TSMS for atleast six months before issuing the TSMS Certificate. The effect of this requirement is on thevessel, not the OMO. The list of TPOs can be found on the Towing Vessel National Centerof Expertise (TVNCOE) website.
b. Three (3) Months Before Initial COI Inspection. The OMO shall schedule the initialinspection for certification at least three (3) months before the vessel is to undergo theinspection. 20 Upon receipt of the initial inspection request from the OMO, the OCMI must
create a MISLE Activity in accordance with the Subchapter M MISLE user guide.
c. Thirty (30) Days Before Initial COI Inspection. Thirty (30) days prior to the vessel
undergoing the initial inspection for certification, OMOs must submit Form CG-3752, titled"Application for Inspection of U.S. Vessel," to the cognizant OCMI where the inspection willtake place. 21 Along with the CG-3752, the OMO should provide the OCMI with:
1) The towing vessel particulars information. 22 The OCMI may use this information tocomplete an ITV Particulars Form, CVC-FM-004(series). Not all information on the ITVParticulars Form (for example, photos) is required for issuance of a COI. The OCMI will
determine the minimum items on the form that are necessary to complete the COI andprovide adequate MISLE data.
2) The towing vessel route(s) on the CG-3752. 23
The word “initial” denotes the first COI issued to a towing vessel inspected under 46 CFR subchapter M.
See 46 CFR § 136.210 – Obtaining or renewing a COI.
21
See id.
22
46 CFR § 136.210(a)(1)(i).
23
Pursuant to 46 CFR § 136.230, the area of operation for each towing vessel and any necessary operational limits are
determined by the cognizant OCMI and recorded on the vessel’s COI.
19
20

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3) A manning proposal for each route sought as well as persons in addition to crew. [Forexample: domestic voyages (two watch systems) versus international route (potential
three watch or two watch system)] 24.
4) Objective evidence that the OMO complies with the TSMS per 46 CFR § 136.210(b)(1).
A valid TSMS Certificate or DOC is sufficient.
5) Objective evidence that the vessel complies with the TSMS per 46 CFR § 136.210(b)(2).
For a vessel operating under a TSMS Certificate, the company should provide evidence
demonstrating the vessel operates under said TSMS. Vessels that have been owned or
operated for 6 months or more should submit a copy of the external vessel audit results.
For a vessel under the ISM Code, an SMC is sufficient objective evidence.
6) A survey report that meets requirements of 46 CFR § 137.135 stating the vessel's
structure, stability, and essential systems are fit for the intended route and service
requested. The OMO should clearly communicate whether the vessel will operate underan external or internal survey program. For vessels operating under an external survey
program, the TPO provides the company a survey report. For vessels operating under aninternal survey program, the company provides a survey report.
7) Inform the OCMI if a vessel is expected to be exposed to salt water more than 6 months
in any 12-month period or not more than 6 months in any 12-month period to establish
hull exam intervals prescribed by 46 CFR §137.300(a). A drydock exam (DDE) andinternal structural exam (ISE) is NOT required for the initial COI. The date of the initial
COI sets the schedule for DDE and ISE intervals. As per 46 CFR §137.300, the cognizant
OCMI may require additional examinations of the vessel prior to issuance of the COI if
the OCMI discovers or suspects damage or deterioration to hull plating or structuralmembers that may affect the seaworthiness or fitness for the route or service of a vessel.
8) If applicable, any international documents and certificates appropriate for the vessel
from its Recognized Organization, and the Coast Guard Inspected Towing Vessel (ITV)International Addendum, CVC-FM-003(series).
9) If applicable, requested equivalents 25 and special considerations 26 for the vessel andinform the OCMI whether the OMO considers it to be an excepted vessel. 2710) If the MTSA is applicable and a towing vessel has not received a VSP (MTSA)
verification by the Coast Guard within five years, then it will be necessary for the OCMI
to verify the VSP prior to issuance of a COI. 28 The OCMI can coordinate with the OMO
to harmonize the VSP verification date with the COI issuance date.
11) An OMO and a TPO of vessels choosing the TSMS option and seeking to obtain avessel’s initial COI may use the following options to provide objective evidence of avessel’s use of an ISM-based SMS or Coast Guard accepted TSMS as provided for in 46
CFR § 138.225.
a) Coast Guard accepted existing safety management system (such as the Responsible
Carrier Program (RCP)) - with an external management audit completed within three
years: A TPO may reduce the breadth and depth of the external management audit
See 46 CFR §§ 2.01-5 and 15.501, MARINE SAFETY MANUAL Vol. III (COMDTINST 16000.8B), 46 CFR § 136.210(a)(1),
and 46 U.S.C. § 3304(a).
25
46 CFR § 136.115.
26
46 CFR § 136.120.
27
46 CFR § 136.110.
28
See paragraph 3.B of reference (b).
248required for the TSMS Certificate. This may include only a sample of the TSMS
elements to verify compliance. A vessel using this option must have been creditedwith an external vessel audit within three years, and successfully completed a survey
in accordance with 46 CFR § 137.202(a) within one year prior to the date the vessel isscheduled for its initial COI issuance. Also, there must be no outstanding major nonconformities associated with either the vessel's audit or survey on the date the vesselis scheduled for its initial COI issuance. Consistent with 46 CFR § 138.225(d), theOCMI who will be conducting the initial COI inspection, must be able to examine thematerials submitted by the OMO at least 30 days before the date the vessel isscheduled to be inspected to see if it contains objective evidence that nonconformities were identified and corrected. Per 46 CFR § 138.410(a), any external
audit (management/vessel) must be conducted by an auditor from a TPO.
b) Coast Guard accepted existing safety management system (such as RCP) - no external
vessel audit within three years: If the OMO has been issued a TSMS Certificate, but avessel associated with the TSMS certificate has not undergone an external vessel
audit, or the audit is beyond three years of the date the vessel is scheduled for its
initial COI issuance, the TPO must conduct a vessel audit and confirm the completionof a satisfactory survey per Subchapter M regulations. The survey may either be an
external survey performed by a TPO or an internal survey performed by appropriately
qualified in-house or contract personnel. An internal survey program is subject to theoversight of a TPO, but that oversight need not include a visit to the vessel unless the
TPO has reason to question the validity of the survey report or otherwise determines avisit is needed. Consistent with 46 CFR §§ 136.210, 137.130(c), 137.202(a), and138.225(d), the OCMI who will be conducting the initial COI inspection must be able
to examine the materials submitted by the OMO at least 30 days before the date thevessel is scheduled to be inspected to see if it contains objective evidence that nonconformities were identified and corrected.
c) ISM Code existing safety management system: The OCMI will verify that theDocument of Compliance (DOC) and Safety Management Certificate (SMC)
associated with a vessel using an ISM Code SMS are current and properly endorsed.
Provided the verification was completed within the time frame specified by 33 CFR §96.330(f), the OCMI may accept the most recent DOC audit as objective evidence ofcompliance with 46 CFR § 138.315(a)(1). In addition, the OCMI may accept SMC
audits conducted within three years of the date the vessel is scheduled for its initial
COI issuance as objective evidence the vessel complies with 46 CFR § 138.315(b)(l).
Additionally, the OCMI should be provided with objective evidence such as
documentation of an internal or external survey that demonstrates the vessel complies
with the applicable portions of Subchapter M. The audit and survey must indicate that
there are no outstanding major non-conformities associated with the vessel or its
TSMS. Consistent with 46 CFR §§ 136.210, 137.130(c), 137.202(a), and 138.225(d),the OCMI who will be conducting the initial COI inspection must be able to examine
the materials submitted by the OMO at least 30 days prior to the date the vessel isscheduled to be inspected to see if it contains objective evidence that nonconformities were identified and corrected.
d) Three-year Objective Evidence Equivalency. For the purposes of issuance of avessel's initial COI, 46 CFR § 138.115 states, “the owners or managing operators
selecting the TSMS option must obtain a TSMS Certificate at least six months before
obtaining a COI for any of their vessels covered by the TSMS certificate.” In lieu of9meeting 46 CFR § 138.115, a company may submit objective evidence to the Coast
Guard that it and its vessels have been operating under an existing safety management
system per 46 CFR § 138.225, for a minimum of three years, as an equivalent level ofsafety, and will not be required to have a TSMS Certificate 6 months prior to theissuance of a vessel’s initial COI. This objective evidence includes, but is not limited
to, external management audit reports covering a minimum of three years prior to thedate of the issuance of a vessel's initial COI. The company must possess TSMS
Certificate prior to the date of the issuance of a vessel's initial COI, if this “3-year
objective evidence” equivalency is used by the company.
e) OCMIs shall be guided by the information in this WI when towing vessel OMO areseeking to use ISM or other existing safety management systems to meet certain
requirements under subchapter M for a vessel's issuance of an initial COI. When a
COI is issued under the provisions of this work instruction, the following
endorsement will be added to the vessel’s COI to indicate use of this WI:This COI is issued in consideration of the provisions contained in 46 CFRPart 138, on the basis of objective evidence provided by [insert name of
TPO or TPOs], an approved Third Party Organization, and the vessel
possesses [pick one either a: a valid TSMS Certificate or both a valid
Document of Compliance and Safety Management Certificate] for the
existing safety management system used on the vessel. This vessel is underan [pick one: external or internal] survey program.
12) The OCMI should ensure that the items received in paragraph D.2.c. (1)-(11) are properly
documented in MISLE. Inspectors will document survey program type in the MISLE
narrative in accordance with the Subchapter M MISLE user guide.
3. Renewal Certification for Inspection Requirements.
a. Thirty (30) Days Before COI Inspection. Per 46 U.S.C. § 3309(c) and 46 § CFR § 2.01-3,
at least 30 days prior to the expiration of the COI, a vessel’s owner, charterer, managing
operator, agent, master or individual in charge shall notify the Coast Guard in writing if thevessel will be required to be reinspected for certification or will be operated in such a manneras to not require a COI.
b. Renewing a COI Prior to its Expiration Date. A COI is valid for 5 years. 29 When an
inspection has been made and a vessel has been found to be in compliance with therequirements of law and regulation, a COI shall be issued to the vessel. 30 COI renewal
inspections may be conducted at any time prior to expiration. 31 Per reference (c), a five-year
COI should not be issued unless an inspection for certification was successfully completed.
When the inspection for renewal certification is conducted up to three months before the COI
expires, the new COI expiration date is based on the previous anniversary date. An inspection
for certification conducted more than three months before the COI expires will reset theanniversary date of the COI. (See reference (c)) After a towing vessel receives an initial COI,
the OCMI will inspect the vessel at least once every 5 years and must ensure that the towing
vessel is suitable for its intended route. The OCMI may direct the vessel to get underway andmay adopt any other suitable means to test the towing vessel and its equipment, to include
drills.
46 CFR § 136.215.
46 U.S.C. § 3309(a).
31
For example, this may be to align statutory certificates or for contract convenience.
29
30

10

Example:

Renewal (5 years)

COI Issuance
Date
August 9th,2018

Renewal “early” within
3 months prior to COI
expiration.
Inspection completed:May 9th, 2023
Renewal “early” morethan 3 months prior to
COI expiration.
Inspection completed:February 1st, 2020

COI
Expiration
Date
August 9th,2023

New COI
Issuance
Date

New COI
Expiration
Date

August 9th,2023

August 9th,2028

February 1st,
2020

February 1st,2025

c. Per 46 CFR § 136.210(a)(2), the application for a COI renewal will include any changes tothe information included in the previous COI application and a description of any
modifications to the vessel. Applicable items are noted in reference (g) with an asterisk. This
document may be used, but is not required, to prepare and submit a COI renewal package.
The timeline for scheduling and applying for a COI is the same as for the initial COI
application.
d. Per 46 CFR § 136.210(b)(1) the OMO must provide the OCMI objective evidence that the
OMO, and vessel comply with the TSMS requirements of part 138 of subchapter M.
e. Per 46 CFR § 136.210 (b)(2) the OMO must provide the OCMI objective evidence of
external or internal survey programs as described in paragraph D.1(a) above.
Additionally, the OCMI should review the objective evidence for accuracy and completion.
f. MIs should verify compliance with any Special Note requirements or Special Considerations
entered into the MISLE database and approved by the Coast Guard in accordance withreference (d).
g. The OMO must provide the OCMI objective evidence of drydock exams and internal
structural exams conducted during the COI period 32. Documentation of credit for the exams
will be given in accordance with Marine Safety: Marine Inspection Administration
COMDTINST 16000.70 and CVC-WI-029 (series). The COI shall not be issued if the vessel
is past its required DDE/ISE dates, unless objective evidence is provided from the OMO thatan DD/ISE was completed. DDE/ISE dates shall be placed onto the COI at the time ofrenewal.
h. Coordination Across OCMI Zones: Per reference (e), an OCMI that disagrees with aninterpretation or decision made by the OCMI that issued the most recent COI for that vessel,
shall contact the OCMI that approved the COI and seek to resolve such disagreement inaccordance with CVC-PR-020 (series). If such disagreement cannot be resolved, the OCMI

Per 46 CFR § 137.305(c) Documenting Compliance for the TSMS Option: The OMO must provide objective evidence thatthe vessel has undergone a drydock and internal structural examination including options permitted in §§ 137.320 and
137.322.
32

11

shall submit to the Commandant (CG-CVC), through the cognizant Coast Guard District
Commander, a request for final agency determination. 33
i. Per 46 CFR § 143.200(c), no later than 5 years after the issuance of the first COI for thevessel, all applicable existing towing vessels inspected under Subchapter M, must meet the
Pilothouse Alerter 34 and Towing Machinery requirements. 35 Failure to meet this requirement
should result in a MISLE vessel deficiency outward facing on PSIX. It shall not be annotatedas a self-reported worklist item.
4. Change in Inspection Option. In accordance with 46 CFR § 136.130(e), requests to change
inspection options (USCG option to TSMS option, or TSMS option to USCG option) during theperiod of validity of an existing COI must be accompanied by an application for inspection(Form CG-3752) to the OCMI for a new COI. For a request to change from one TSMS option toanother TSMS option (e.g., change in TPO, SMS, or owner/operator), however requires anamended COI.
If the requirements for the new inspection option are met, then the OCMI will issue a new COI
following a COI inspection, with reset 5-year dates in accordance with 46 CFR § 136.215. DDE
and ISE dates will remain the same on the document and the due dates for the DDE and ISE
will not be reset. (See enclosure (2) or reference (f) for more information on what may be neededfor each COI inspection option).
a. If transitioning from USCG option to TSMS option. An OMO must obtain a TSMS
Certificate issued under 46 CFR § 138.305 at least six months before obtaining a new COI
for any of their vessels covered under the TSMS Certificate. 36 The vessel must receive astatutory inspection for certification by the Coast Guard per 46 U.S.C. §§ 3301 and 3309, 46
CFR §§ 136.130(e) and 136.212(c). The OCMI may issue a new COI to a vessel under a new
TSMS prior to the six-month requirement per 46 CFR § 138.115 with certain conditions andfollowing the below guidance.
1) For vessels subject to 46 CFR § 138.115, to show compliance with 46 CFR § 136.210(b)(1), the OCMI may issue a COI to a vessel in substantial compliance with material,
equipment, and operational requirements and monitor progress towards full
implementation of the TSMS.
2) Thirty (30) Days Before COI Inspection. The OMO must submit Form CG-3752 within
30 days of inspection, and the OMO must notify the OCMI if they intend to use the
TSMS option. The OMO must also provide additional information to facilitate the Coast
Guard certification, to include a copy of the TSMS Certificate and objective evidence inaccordance with 46 CFR §§ 136.210 and 137.202. This includes an initial external vessel
audit per 46 CFR § 138.315(b) as this is a new COI under the new inspection option.
3) The OMO should further notify the OCMI that they request inspection for certificationahead of the six-month TSMS Certificate requirement in 46 CFR § 138.115.
4) The OCMI will review all necessary vessel and OMO information and may request
additional information from the cognizant TPO to establish objective evidence ofcompliance and determine whether an inspection for certification is appropriate based on
the circumstances of the case.

46 U.S.C. § 3305(d).
46 CFR § 143.450.
35
46 CFR § 143.460.
36
46 CFR § 138.115.
33
34

12

5) The OCMI will conduct an inspection for certification. Upon verification that the vessel
is in substantial compliance with material, equipment, manning, and operational
requirements, the OCMI will issue a CG-835V 37 requirement with a compliance date six
months from issuance. The CG-835V must state:
Vessel is inspected under the TSMS option and the requirement of 46
CFR § 138.115 is satisfied. Provide objective evidence of TSMS
implementation for six months from the date of the COI. Failure tocomplete this requirement will result in removal of the TSMS
endorsement from the vessel’s COI, suspension of vessel operations, or
COI revocation, as determined by the OCMI.
6) If the vessel fails to satisfy the CG-835V requirement, the OCMI must determine the
OMOs intention for the vessel and either revert the vessel’s COI to the Coast Guard
inspection option under 46 CFR § 137.200, suspend operations until the requirements ofreference (a) and any other relevant deficiencies are satisfied, or revoke the COI.
b. Change from one TSMS option to another TSMS option.
1) OMOs should request a COI amendment with updated TSMS, TPO, and/or OMO
information from the OCMI who issued the original COI. 38 When switching from TSMS
option to TSMS option, there are several different scenarios to consider: “Is it a new
TPO, a new TSMS, a new company or temporary charter, or both? Is a new vessel being
added to an existing TSMS Certificate or being issued a brand-new certificate? Is the
TSMS certificate keeping the same TSMS cycle, for example to be valid for only 2 to 3
years, or is it a new TSMS certificate valid for 5 years?” The OCMI shall review allnecessary vessel, OMO, TPO and TSMS information, and may request additional
objective evidence from the previous or new TPO to establish compliance. Based on that
information the OCMI will determine whether a CG inspection is appropriate based on
the circumstances. 392) Continuation TSMS Certificate versus Maintaining the Existing TSMS Cycle. Renewingof a TSMS certificate (valid for 5 years) or continuing with a current or existing TSMS
cycle (keep original end date as a vessel is merged onto an existing TSMS, less than 5
years) should also be predicated on similar objective evidence as described in the above
paragraph, as determined by the TPO. 40 A new TSMS certificate, valid for 5 years, resets
the TSMS audits dates and requirements. 41 This can be advantageous if the OMO isdesiring to align the TSMS certificate with the COI or other statutory certificates. Being
issued a continuation TSMS certificate, keeping the same end date but having a new issue
date, would allow the company to continue with their current TSMS audit schedule.
There are pros and cons with each situation as to whether a TSMS certificate is renewed(new 5-year dates) or simply issued to conclude at the previous TSMS certificate cycle
and should be discussed between the OMO and gaining TPO.
c. New TPO Changeover.
1) If an OMO changes to a new TPO, the new TPO may not have conducted the initial orprevious surveys and audits for the TSMS certificate. Therefore, all previous audits,
OCMIs should not issue a “work list item” under this provision. Additionally, the vessel should continue to follow allpolicies, processes, and procedures under the TSMS to document objective evidence of activities under the TSMS.
38
46 CFR § 136.235(c).
39
46 CFR § 136.235(b).
40
46 CFR § 138.305.
41
A renewal TSMS certificate can initiate a new external management audit per 46 CFR § 138.315(a).
37

13survey results (reports), and any alternate arrangements approved (per 46 CFR 141.225),
should be provided to the new TPO. If the OMO cannot provide all the required audits,survey results, and approvals, the gaining TPO may request that the OMO authorize theprevious TPO to transfer copies of such information to the gaining TPO.
2) The gaining TPO should relay to the OMO, (i.e., based on the previous audits and survey
reports) the relevant outstanding surveys or audits that are due prior to the completion of
the continued TSMS certificate cycle, as applicable.
3) The gaining TPO should provide to the OMO (i.e., based on the results of previous audits
and surveys), a current list of outstanding deficiencies and/or nonconformities with theirdue dates.
d. New TPO and New TSMS. Outside the situation of when an initial TSMS certificate isissued for the initial COI, if there is a new TPO conducting oversight of a new company thatis implementing a new TSMS, a new TSMS certificate with new 5-year dates should be
issued. It is up to the gaining TPO if other situations and objective evidence warrant
additional audits or surveys beyond what is required as a minimum in regulation to ensure
the towing vessels comply with the provision of 46 CFR subchapter M. 42 These
circumstances above regulatory minimums, should be documented in the TPOs procedures,
TSMS, and contracts with OMOs.
When a new TPO carries out the functions to ensure compliance of a new TSMS, objective
evidence must be present for the gaining TPO to substantiate that all the criteria have been
met to issue a new TSMS certificate. The external management audit results for that new 5year TSMS certificate shall be submitted to the TVNCOE. 43 The following criteria for thisnew TSMS certificate are required:
1) Internal management audit (46 CFR § 138.310): conducted within 3 months of theanniversary date of the new TSMS certificate.
2) External management audit (46 CFR § 138.315(a)): conducted before the new TSMS
certificate is issued.
3) Mid-period external management audit (46 CFR § 138.315(a)(2)): conducted between
the 27th and 33rd month of new TSMS certificates period of validity.
4) External vessel audit: A new random vessel audit cycle 46 CFR § 138.315(b) begins assoon as the new TSMS certificate is issued.
e. New TPO but Same TSMS. If there is a new TPO, but the OMO retained the same TSMS,
the gaining TPO should:
1) Internal management audit and vessel audits. Verify and review the internal audits(management and vessel) under the existing TSMS. Continue with oversight ofcompany’s internal audit schedule. (See paragraph D.4.c. for reciprocity between TPOs)
2) External management audit: An external management audit is required when an initial or
renewal TSMS certificate is issued. If the TPO renews the TSMS certificate (valid for 5
new years) the audit is required (See D.4.b.2. above for more information).
3) Mid-period external management audit. If the new TPO intends to issue a continuation
TSMS certificate, assume oversight between the 27th and 33rd month of the certificatesvalidity, and the mid-period external management audit had not been conducted, the new42
43

46 CFR § 139.115.
46 CFR § 138.505(a).

14TPO should conduct an external management audit prior to issuing the continuation
TSMS certificate. 44 If the TPO intends to issue a continuation TSMS certificate andassumed oversight after a recent mid-period external management audit, the TPO should
review the results of the recent management audit and may conduct a new externalmanagement audit, as deemed necessary.
4) External vessel audit. The TPO should conduct an external vessel audit 45 within thecurrent random audit cycle of the existing TSMS. No additional random external vessel
audit is required.
f. Same TPO and Vessels are Added to a TSMS. If a vessel changes TSMS (i.e., it is added
to a new or existing TSMS certificate due to new charter, new managing operator, or new
ownership) but retains the same TPO:
1) Internal management and vessel audits are still required annually. 46 All vessels added to
the new TSMS should be folded into those procedures and audited accordingly.
2) External management audit. In this instance, the TSMS certificate, which is issued to thecompany, would not be considered an initial or a renewal and therefore no externalmanagement audit would be required.
3) Mid-period external management audit. All vessels added to the new TSMS should befolded into those procedures and audited accordingly.
4) External vessel audit (Random). The vessel will enter into the new TSMS external vessel
audit, random cycle, where all vessels on that TSMS shall receive a random vessel audit
within the remaining TSMS certificate validity. (e.g., If there are only two years left on
the TSMS certificate that the new vessels were added to, regardless of having had arandom audit completed under the old TSMS certificate, these newly added vessels shallbe folded into that new random pool and have two years to complete a new random auditof how they implement the new TSMS.)
g. Surveys. In all cases, surveys are conducted around COI issuance dates and should continue
with the chosen program (internal/external). 47
h. If transitioning from TSMS option to USCG option. OMOs shall apply for a new COI in
accordance with 46 CFR § 136.210. The OCMI will indicate all the objective evidence
required to validate the vessel’s compliance for the COI.
E. Additional Guidance.
1. Per 46 CFR § 136.110, “objective evidence means quantitative or qualitative information,
records, or statements of fact pertaining to safety or to the existence and implementation of an
SMS element, which is based on observation, measurement, or testing that can be verified. This
may include, but is not limited to, towing gear equipment certificates and maintenancedocuments, training records, repair records, Coast Guard documents and certificates, surveys,
classification society reports, or TPO records.” Additionally, summaries of TPO independent
verifications, audit findings, marine surveyor reports, professional engineer certification, and gap
analysis from 46 CFR subchapter C to subchapter M regarding audit and survey requirements arealso valid objective evidence.

46 CFR § 138.315.
46 CFR § 138.315(b)(3).
46
46 CFR § 138.310.
47
46 CFR § 137.202.
44
45

15

2. Deficiencies or non-conformities noted by Coast Guard Marine Inspectors shall be addressed as
described in reference (f).
3. OCMIs should refer to reference (d) for suggested COI endorsements related to special
considerations.
4. An OCMI is not required to annually endorse or amend the COI for TSMS option vessels for thefollowing activities: annual surveys, vessel audits, DDE, and ISE as the Coast Guard may notattend these inspections during the 5-year cycle of the COI. The associated COI MISLE
activities are also not required, unless MI attendance is requested, warranted, or an amendment ismade to the COI. MIs will document verification that TPOs conducted the annual surveys andaudits required during the lifecycle of the COI at the renewal inspection for certification, toensure compliance for issuance of the 5-year COI renewal. However, if an OMO provided
objective evidence that a DDE or ISE was conducted and requests an amendment to the COI, thecognizant OCMI who issued the original certificate, should amend the COI accordingly anddocument it as a MISLE Administrative Activity.
5. As a result of the transient nature of the towing vessel industry, it may be common for towing
vessels to schedule the COI inspection in one OCMI zone and not be available in that zone when
the actual inspection date arrives. To facilitate the inspection process, it is imperative thatcomplete and accurate COI application information is entered into MISLE, and the relevant
documents uploaded. Should a schedule or location change be required, OMOs should promptly
communicate the same to the affected OCMI(s) to minimize inspection delays. Upon receipt of arequest to change the OCMI zones where the inspection is to be conducted, the OCMI may:a) Transfer the inspection to the receiving OCMI (preferred option). The OCMIs should discuss
the application to determine if additional information is required from the OMO. In general,
if a COI inspection has commenced in one OCMI zone and needs to be completed in another
OCMI zone, the OCMIs should communicate areas of the vessel already inspected to avoid
duplication. If the previously scheduled inspection is moved to another OCMI zone, the“Initial Certification” MISLE activity should be transferred to the OCMI where theinspection will take place. The MISLE activity narrative should clearly outline what portionsof the inspection have been completed and any applicable findings.
b) Reschedule or postpone the inspection so that it can be conducted by the OCMI that received
the initial CG-3752. The MISLE activity narrative should describe the timeline of events.
6. Coast Guard Towing Vessel Marine Inspectors may find instructions on how to complete a
TSMS-inspection MISLE activity by viewing the “MISLE Towing Vessel Data Entry Guide”
located on the MISLE 5.0 User Guide SharePoint site. The MISLE Activity shall be opened as“Initial Certification” or “COI-Inspection”, upon receiving a request from an OMO to schedule
an inspection. The activity shall have a status as “Open” “Scheduled, Action Pending” andchanged to “Open” “In Progress” once the exam has been conducted.
7. As parties to a COI under the Subchapter M TSMS compliance option, OCMIs are requested toprovide a copy of each TSMS option COI they issue to the TPO reflected in the endorsements.
The copy may be emailed or hard copy mailed to each TPO using the information available on
the TVNCOE website, located here.
F. Appeals. Appeals of decisions made regarding inspection issues should follow the appeal procedures
outlined in 46 CFR §§ 1.03 and 136.180.

16

G. Questions. For questions regarding this work instruction, please contact the Office of Commercial
Vessel Compliance at CGCVC@uscg.mil.

M. R. NEELAND
Captain, U.S. Coast Guard
Office of Commercial Vessel Compliance
By direction

Enclosure:(1) 46 CFR Subchapter M Compliance Timeline: TSMS Option(2) COI Inspection Table for Subchapter M

17

CVC-WI-013(7)Enclosure (1): 46 CFR Subchapter M Compliance Timeline: TSMS Option

46 CFR SUBCHAPTER M COMPLIANCE TIMELINE:
TOWING SAFETY MANAGEMENT SYSTEM (TSMS)COI Initial Timeline:
6 MONTHS PRIOR TO COITSMS Approval
TSMS Cert issued(valid for 5-years)
46 CFR 138.305
138.315

3 MONTHS PRIOR TO COI

EXTERNALVESSELTSMS AUDIT
Vessels owned ≥ 6months(Once every 5 years)
138.315(i) A vessel owned less than 6months must complete an
external TSMS audit within 6months of COI issuance.
(ii) OCMI to be no fied 72 hours
prior to audit as per 46 CFR
138.500

SCHEDULE
COAST GUARD
INSPECTION
WITH OCMI
136.210VESSELSURVEY(complete prior
to COI)
137.202SUBMITAPPLICATIONFOR INSPECTION
CG-3752

30 DAYS

Owner/managing
operator must submit:(i) CG‐3752(ii) Vessel par cular
informa on;(iii) Number of persons in
addi on to crew, if
requested

Companies choosinginternal survey op on
must meet requirements
in 46 CFR 137.210~ ~EXTERNAL
MANAGEMENTTSMS AUDIT

INITIAL
INSPECTION FOR
CERTIFICATION
COI issued(valid for 5-years)
136.212136.215LEGEND
Coast Guard Activity
Owner / Operator

A Document of Compliance(DOC) IAW ISM (CVC Policy
Le er 17‐02 CH.1) may be usedas credit for the ini al inspec on
to issue an ini al COI.

Third Party Org.
(TPO) Activity
Activity performedby TPO or Owner /Operator
Information

COI Renewal Timeline:~*Survey137.205/210**Internal
Mgmt
Audit
138.310*Survey137.205/
210

MID-PERIODEXTERNAL
MANAGEMENTTSMS AUDIT
46 CFR 138.315(a)(2)(27-33 MONTHS)**Internal
Mgmt
Audit
138.310**Internal
Mgmt
Audit
138.310*Survey137.205/210**Internal
Mgmt
Audit
138.310*Survey137.205/
210

ONCE EVERY 5 YEARSRENEWAL
EXTERNAL
MANAGEMENTTSMS AUDIT
138.315(a)(1)

RENEWAL
EXTERNALVESSELTSMS AUDIT
138.315(b)(3)TSMS
CERTIFICATERENEWAL(as applicable)
138.305(b)**Internal
Mgmt
Audit
138.310RENEWAL
INSPECTION FOR
CERTIFICATION*Survey137.205/210(not to exceed 5 years)
136.210 and 136.212(a)See paragraph D.1.a for applicablemeframe requirements for the survey
for renewal per survey program.
*Vessel surveys are completed Annually +/‐ 3 months of COI
anniversary date.
**Internal management audits are also required Annually, +/‐3 months of the TSMS cer ficate anniversary date.

*Dry Dock / Internal Structure Exam (ISE)Fresh Water = Once in 5 years after initial COI
Salt Water = Twice in 5 years after initial COI
A valid Load Line Document satisfies thisrequirement(< 36 months between exams) 137.300

Owner or managing operator must submit (30 days before inspec on):(i) Any changes to the informa on submi ed for ini al inspec on;(ii) A descrip on of any modifica ons to the vessel;(iii) Objec ve evidence of compliance with TSMS requirements in Part 138;(iv) Objec ve evidence that the vessel’s structure, stability, and essen al systems comply withthis Subchapter. May be in the form of a survey report or another form acceptable to the CG.

Enclosure (2) COI Inspection Table for Subchapter M
InitialCertification

Items required if
indicated by an “X”

Application for Inspection:(Form CG-3752)

Vessel Particulars:
46 CFR § 136.210(a)(1)(i)Persons in addition tocrew:
46 CFR § 136.210(a)(1)(ii)

Objective Evidence (OE) of
TSMS compliance:
46 CFR § 136.210(b)(1)

OE Vessel meets Sub M forintended route:
46 CFR § 136.210(b)(2)

CVC-WI-013(7)Renewals

Changing Options(46 CFR § 136.210)(46 CFR § 136.210)(46 CFR § 136.130)

USCG Option

TSMS Option

USCG Option

TSMS Option

TSMS to USCGUSCG to TSMS

Initial COI

Initial COI

Renewal COI

Renewal COI

New COINew COI

X

X

X

X

X

X

X

(§§ 138.115, and138.305)

X(§ 137.202(a) for initial
COI a survey report
described in§
137.215)

XX(§ 136.210(a)(2))(§ 136.210(a)(2))

X

X(if there are changes§ 136.210(a)(2)(i))(if there are changes§ 136.210(a)(2)(i))

XX(if there are changes§ 136.210(a)(2)(i))(if there are changes§ 136.210(a)(2)(i))

X(§§ 138.115, and 138.3051)

X(§ 137.202(b)(1) or (2): OE
of a survey program §137.205 or§ 137.210)

X(§ 136.130(e))

X(if there arechanges §136.210(a)(2)(i))

X(if there arechanges §136.210(a)(2)(i))

X(§ 136.130(e))

X(if there are changes§ 136.210(a)(2)(i))

X(if there are changes§ 136.210(a)(2)(i))

X(§§ 138.115, and138.3051)

X(§ 137.202(a))

X

TSMS option External
Vessel Audit
46 CFR § 138.315(b)(§ 138.315(b)(1) prior toinitial COI or (b)(2) if
new to company (lessthan 6 months old) within
6 months of issued initial
COI.

And

§ 138.315(b)(3) vessel
must be randomly audited
during the validity of the
TSMS certificate.)X(§ 136.235(c)(1) proof ofvessel audit and/or in random
audit program.

And§138.315(b)(3) vessel mustbe randomly audited during
the validity of the TSMS
certificate.2)X
And(§ 138.315(b)(3)vessel must be
randomly audited
during the validity of
the TSMS certificate.)1

Enclosure (2) COI Inspection Table for Subchapter M

CVC-WI-013(7)Initial Certification

Renewals(46 CFR § 136.210)

Items needed
Continued…

Changing Options(46 CFR § 136.210)(46 CFR § 136.130)

USCG Option

TSMS Option

USCG COI

TSMS COI

TSMS to USCGUSCG to TSMS

Initial COI

Initial COI

RenewalRenewal

New COINew COI

Verify Manning
Request or changes
requested3

X

X

X

X

X

X

COI Inspection:
46 CFR § 136.212

X

X

X

X

(§§ 136.130(e),136.212(c))(§§ 136.130(e),136.212(c))

Issued/Expiration
Dates on COI:
46 CFR § 136.2154

5 years

5 years

5 years

5 years

5 years

5 years

DD/ISE dates on COI

X

X

X

X

X

Routes listed on the
COI

X

X

X

X

X

X

As needed

As needed

As needed

As needed

As needed

As needed

COI Conditions andother Endorsements:(Ex. Special
Considerations orMulti-Service)(§ 137.305(c))(§ 137.305(c))

X

X

X

(§ 137.305(c))

The TSMS Certificate should be kept on file at the owner or managing operator’s shoreside office and available for review, at the request of the Coast Guard. The
requirements to obtain the TSMS Certificate are the audits required per 46 CFR Subchapter M, Subpart C.
2
On the first COI Renewal (after Subchapter M phase-in), proof of vessel audit(s) per 46 CFR 138.315(b)(3), may only include the one initial vessel audit completed
towards issuance of the initial COI. This should be accepted because the vessel may not have been selected randomly yet during that TSMS Certificate validity period.
If this is the case, objective evidence (OE) that the vessel is in a random vessel audit program by 138.315(b)(3) should be verified. OE that the vessel completed theRandom Audit should be provided at the next COI Renewal.
3
Refer to Marine Safety Manual Vol III B.2.W. for more information.
4
Refer to G-MOC Policy Letter 00-02 (dated May 22,2000) for guidance on harmonization of U.S. inspection schedules with SOLAS surveys.
12