Do I need A New CG Certificate of Inspection?

I recently purchased a 38-foot charter boat that is located in South Carolina. The prior owner operated the boat in an active charter business with a Coast Guard Certificate of Inspection that expires in 2017. I plan to move the boat Lake Michigan to start a charter business on the Great Lakes, but I’m not sure if I can do that with the existing Certificate of Inspection. Do I need to start from scratch with a new COI? Who should I contact to make this happen?

Federal law requires a Coast Guard Certificate of Inspection (COI) for any vessel that is carrying passengers for hire on U.S. navigable waters. More specifically, this requirement is set forth in 46 U.S. Code sections 2101(22), 2101(35), and 3301, which when read together require comprehensive Coast Guard inspections of the vessel’s structural condition, fuel, electrical, fire and mechanical systems, safety equipment, and other components if the vessel will have more than six passengers aboard (or 12 passengers if the vessel measures greater than 100 gross tons).            

The Coast Guard updates the technical requirements for a COI from time to time.  The changes or updates in the technical requirements are enacted to enhance safety as vessel design evolves through the years, but those changes typically increase the cost of obtaining and maintaining a COI for a charter vessel.  Older boats may get some relief from these increased costs if the boat owner complies with the strict renewal requirements for the vessel’s COI, which then generally allows an older bo

at to continue as an inspected vessel under its original technical requirements.  This brings us to our reader’s issue.             Our reader is concerned that he may lose the COI for his newly acquired boat if he moves it from South Carolina to the Great Lakes, which could lead to a significant expenditure in terms of both time and money.  He should, however, be OK, assuming he keeps the Coast Guard informed about his plans.            

Coast Guard operations are divided around the country into different districts, each with its own command structure.  Here in California, Coast Guard operations are under the 11th District, based in Alameda.  Our reader plans to relocated his inspected vessel from the 7th District, based in Miami, Florida, to the 9th District, which is based in Cleveland, Ohio.             

Each district is further broken down into operating units and divisions, which include everything from Aids to Navigation teams to cutters and air stations.  Mariner licensing and vessel inspection is handled by the Marine Safety Offices (MSO) or Marine Safety Units (MSU) for each particular Coast Guard District. Each district typically has three or four MSO or MSU offices in different locations throughout the district. A map of the districts with links to their operating units may be found on the internet at:            

Whenever an inspected vessel relocates from one Coast Guard District to another, the vessel owner must contact the MSO or MSU for both the old and the new districts, and comply with the instructions received from both offices. The old office will transfer the file to the new office. The new office may or may not require a new out of water inspection of the vessel, depending on its internal policies and the history and overall apparent condition of the vessel. But assuming the COI remains current and the requirements of both offices are complied with in a timely manner, the vessel will generally not require a new COI.             Dealings with the Coast Guard, like all legal issues, vary considerably for each case, so boat owners should consult with their own maritime attorney if they have specific questions. But they should in any case start by contacting the Coast Guard and keeping the Coast Guard informed of the owner’s plans.  

David Weil is licensed to practice law in the state of California and, as such, some of the information provided in this column may not be applicable in a jurisdiction outside of California. Please note also that no two legal situations are alike, and it is impossible to provide accurate legal advice without knowing all the facts of a particular situation. Therefore, the information provided in this column should not be regarded as individual legal advice, and readers should not act upon this information without seeking the opinion of an attorney in their home state.  

David Weil is the managing attorney at Weil & Associates ( in Long Beach. He is an adjunct professor of Admiralty Law at Loyola University Law School, is a member of the Maritime Law Association of the United States and is former legal counsel to the California Yacht Brokers Association. He is also one of a small group of attorneys to be certified as an Admiralty and Maritime Law Specialist by the State Bar of California. If you have a maritime law question for Weil, he can be contacted at (562) 438-8149 or at   Ask your question online at

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