Officers in Charge, Marine Inspection (OCMIs) should reference this guidance when issuing a COI under 46 CFR Subchapter M for inspected towing vessels choosing the TSMS option. A flow chart is included in the Work Instruction to illustrate the TSMS compliance process.
The Towing Vessel National Center of Expertise (TVNCOE) reports that approximately 750 COIs have been issued with another 450 currently in the queue. They believe this represents approximately 22% of the 25% of the fleet towing vessels needing COIs in by July 22, 2019 (year one of the four-year phase-in).
They estimate that 219 companies have received a TSMS certificate/DOC and are using an SMS for compliance that those companies represent roughly 3,250 towing vessels.