On 12/31/2019, we communicated with you the successful result of our appeal that resulted in the allowance of 90-days before and 90-days after the COI issue date for annual surveys performed under a company’s internal survey program. The USCG first communicated this revised interpretation in the TPO Guidebook (CVC-Policy Letter 17-04 change 2 on 12/31/2019).
Today the USCG issued change 4 to CVC-WI-013 Towing Vessel COI Inspections Under TSMS Option (dated 12/31/2019) that further confirms this position as a work instruction for use by USCG Marine Inspectors. You can find this revision on page two, item D 1 a. i. We have not completed an exhaustive review of the document yet to determine if there are additional changes but we’re proud to have been the leader on this issue with the USCG which resulted in a positive outcome for all companies that have elected to use an internal survey program under the TSMS option.