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• Towing vessels must meet Watertight and • July 19, 2022 – 100% of ? eet; Weathertight Integrity standards by July 20, 2016; • Companies using the TSMS option must have • New Installations not “Replacements in Kind” a Safety Management System Certi? cate in place on a vessel for at least six months before the vessel made after July 20, 2016, must perform a can be issued a COI.

Veri? cation of Compliance with Design Standards, meeting the requirements for “New Vessels;”

Many changes were made in the ? nal rule for existing • Major Conversions must perform a Veri? cation towing vessels as it pertains to Machinery and Electrical of Compliance with Design Standards, meeting the requirements for “New Vessels;” Systems and Equipment. The proposed rulemaking, Part • New Towing Vessels, those with a “keel laid” date 143 contained two sections addressing “deferred machin- after July 20, 2017, must obtain a COI before ery” requirements for vessels. In the ? nal rule publication, entering service.

these two sections were removed, and most requirements contained moved to “New Vessels Only” requirements.

The regulations include a compliance phase-in period, Existing towing vessels now only have two delayed imple- allowing industry to complete the required dry-dock ex- mentation engineering requirements for Towing Machin- aminations, and the Coast Guard to inspect and issue ves- ery and the Pilothouse Alert System. The Pilothouse Alert sel COI’s. The owner or operator has ? ve years from the System will only be required on vessels greater than 65 feet.

date the COI is issued to complete any delayed implemen-

One thing is for certain as organizations begin to take tation requirements. The compliance phase-in dates are: the steps to comply with the ? nal rule, no one size ? ts all • July 22, 2019 – 25% of ? eet; solution exists. It is important for organizations, regardless • July 20, 2020 – 50% of ? eet; of size, to make sure they ? nd the right mix of compliance • July 19, 2021 – 75% of ? eet; options to meet their speci? c and unique needs.

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