47
JUNE 2026
Some examples where a major con-
version determination could be 
made include: 
• Converting a non-passenger car-
rying vessel to a passenger or small 
passenger vessel
• Adding a mid-body
• Gutting a vessel and replacing/
updating all components
PREVIOUS CONFUSION
The Coast Guard’s Marine Safety 
Manual, Volume II, provides language 
cited in the work instruction stating 
“A vessel whose COI has lapsed may 
be required to meet inspection for cer-
tification requirements as a new vessel 
as determined to be appropriate by the 
OCMI. Per reference (b) [the Marine 
Safety Manual], the OCMI may re-
quire a formerly certificated vessel to 
be inspected as a new vessel.” This has 
resulted in OCMIs defaulting to the 
new vessel determination more often 
than not. 
	
Fortunately, we now have qualify-
ing language that follows the above 
guidance “A previously certificated 
vessel does not automatically qualify 
as an ‘existing’ vessel, nor does it au-
tomatically become a ‘new’ one when 
returning to service. This status will 
be determined by the OCMI, who 
will consider all relevant factors, par-
ticularly structural modifications or 
extended periods out of service.” 
	
RETURNING A VESSEL TO 
PASSENGER SERVICE 
If the owner or operator of a vessel 
with a previously surrendered or 
lapsed COI seeks to return the vessel 
to service, they need to submit an Ap-
plication for Inspection of U.S. Vessel 
(Form CG-3752) to the local OCMI 
and schedule a Coast Guard Marine 
Inspector to attend the vessel. If the 
vessel has a new owner, that owner 
should notify the local OCMI of the 
change in ownership.
	
The local OCMI will determine ap-
plicable standards prior to issuing of 
a new COI. According to the revised 
work instruction, when determining 
the applicability of existing or new 
standards for a previously laid-up ves-
sel, the local OCMI should consider 
the following: 
	
1. Existing or planned modifications 
that may result in the determina-
tion of a major conversion, per 46 
U.S.C. § 2101;

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