Coast Guard Clarifies Policy On Vessel Audits

On September 18, the Coast Guard released a revised policy letter, CG-CVC Policy Letter 17-02, Change-2, that credits external vessel audits conducted within three years prior to the issuance of a Certificate of Inspection (COI). The audits must have been conducted under a Coast-Guard-accepted safety management system, such as the American Waterways Operators’ Responsible Carrier Program (RCP).

In an email sent to members shortly after the initial publication of the policy letter in June, the AWO said that the policy letter confirmed the Coast Guard’s Office of Commercial Vessel Compliance’s longstanding interpretation of its policy, but its ambiguous wording had created confusion among some Coast Guard field units.

AWO and the Towing Vessel Inspection Bureau worked together to advocate for its clarification. Paragraph 6.a. of the policy letter now states, “A vessel using [a Coast-Guard accepted existing safety management system such as the RCP] must have been credited with 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 is scheduled for its initial COI issuance.”

AWO said it “appreciates the Coast Guard’s action to clarify the policy letter and resolve any lingering confusion about its intent.”