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Initial Certificate of Inspection Issuance for Subchapter M Vessels Utilizing the Towing Safety Management System Option


This MSIB is issued to address the issuance of an initial Certificate of Inspection (COI) for subchapter M inspected towing vessels that utilize the Towing Safety Management System (TSMS) option. Those seeking an initial COI by utilizing the Coast Guard option will be addressed in a future MSIB.

Those companies choosing the TSMS option will have a Coast Guard approved third party organization (TPO) conduct independent verifications to assess whether their TSMS complies with the requirements of subchapter M.


Owners and operators electing the TSMS option may submit requests for COIs to the local Officer in Charge, Marine Inspections (OCMI) by submitting the below required information as outlined in 46 CFR 136.210. NOTE: Priority will be given to vessels that have a valid UTV decal.


  1. Thirty days prior to the vessel undergoing the initial inspection for certification, owners and managing operators must submit Form CG-3752, "Application for Inspection of U.S. Vessel," to the cognizant OCMI where the inspection will take place.
  2. Vessel Particulars.
  3. A manning proposal.
  4. Vessel route.
  5. A description of any modifications to the vessel made since new construction.
  6. TSMS Certificate issued by a TPO at least six months prior to the scheduled initial COI issuance date. Compliance with ISM may also be used IAW CG-CVC Policy Letter 17-02 dated May 24, 2017, Use Of Existing Safety Management Systems To Obtain An Initial Certificate Of Inspection Under 46 CFR Subchapter M.
  7. Objective evidence of compliance with the TSMS certificate.
  8. A report in accordance with 46 CFR 137.135 and 137.202(a) stating the vessel's structure, stability, and essential systems comply with Subchapter.
  9. Certificate of Documentation.
  10. If applicable, Fresh Water Intent Letter for hull exam intervals as per 46 CFR 137.300 (a).


NOTE:  Objective Evidence may include, but is not limited to, summaries of TPO independent verifications, audit findings, marine surveyor reports, and/or professional engineer certification.


At OCMI discretion, towing vessels possessing a valid Uninspected Towing Vessel (UTV) decal issued in the Sector Houston-Galveston zone will not require Coast Guard Marine Inspectors to physically attend prior to COI issuance.


For more information, please contact the applicable inspections office below:


  • Sector Houston-Galveston: (281) 464-4733 or send email to
  • MSU Texas City: (409) 682-1903 or send email to


    This bulletin shall remain active until rescinded or superseded by future direction.

    MSIB 02-18 Initial COI for TSMS Option Towing Vessels.pdf









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