SUB M: COIs – After Year One and New Construction

Year Two COI Considerations and Requirements

  • TVIBs TPO customers lead the pack for meeting the 25% requirement for obtaining COIs in year one. 
  • Now is not the time slow up as the Coast Guard is squarely focused on the year two deliverable of 50% of an owner/managing operator’s fleet along with all of the one vessel owner/managing operators that must have their COI by July 20, 2020.

New Construction Vessel COI Requirements

  • A new towing is defined in §136.110 “means a towing vessel, subject to inspection under this subchapter, that: (1) Had its keel laid or was at a similar stage of construction on or after July 20, 2017; or (2) Underwent a major conversion that was initiated on or after July 20, 2017.”
  • §136.202(c) “A new towing vessel must obtain a COI before it enters into service.”
  • TSMS option vessels – §138.315(b)(2) “(2) An external audit must be conducted no later than 6 months after the issuance of the initial COI for vessels subject to the owner or managing operator’s TSMS that have been owned or operated for fewer than 6 months prior to receiving the initial COI.”
  • Owner/managing operators that are engaged in new construction should keep these items in mind.

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