How to Prep for a Subchapter T COI Inspection: A 12-Point Checklist From an Operator

The first time I sat through a Subchapter T COI inspection as operator of record, I'd done what most owners do — I checked the equipment. PFDs counted. Fire extinguishers serviced. EPIRB registered. The inspector showed up, said good morning, and then said the seven words that put me on my heels: "Can I see your drill log, please?"

Not the COI. Not the licenses. The drill log. Most Sub T inspections are won or lost on paper, not on equipment. Equipment usually works. Paperwork usually doesn't.

This is the 12-point checklist I run 30 days before any annual COI inspection on a Sub T vessel. It's the same one we wired into Binnacle AI's Inspection Pack module.

Why this matters

• Sub T inspections are getting more rigorous since 2023. Inspectors are spending more time on credentials and drill logs and less time on hardware they can verify visually.
• A failed inspection costs revenue days. If you re-inspect 7-14 days later you've lost a peak-season weekend. For a 49-pax catamaran at $79/seat, that's $30k+ in revenue gone.
• Most failures are paperwork, not equipment. Out of every five Sub T failures I've seen, four were credential expirations or missing drill records. One was equipment.

The 12-point pre-inspection checklist

1. The COI itself

Sounds dumb. It's not. Pull your current COI and check three things: expiration date, routes/operations endorsed, and that it's mounted in a visible location accessible to the master. 46 CFR §176.105 requires the COI be carried on board and posted under glass or plastic in a conspicuous location.

The gotcha: if you've changed routes, added overnight operations, or modified the vessel since issuance, you may be operating outside scope. Pull the COI, read it, and confirm what you're doing matches what's printed.

2. Master + Mate licenses (46 CFR §10.207)

Pull every credential held by anyone scheduled to stand a watch in the next 90 days. For a 79-foot Sub T with 49 passengers near-coastal, you need:

• Master <100 GT Near Coastal with valid MMC and unexpired medical cert (46 CFR §10.203)
• Mate per the manning table if operations require one
• Radar Observer endorsement for any officer standing a navigation watch (46 CFR §10.480)
• Original credential aboard — not a photocopy, not a phone screenshot

The MMC is a 5-year credential; the medical cert is 2 years. They expire on different cycles, and "valid MMC" with an expired medical cert is the single most common credential finding I see.

3. TWIC for every crew member (49 CFR §1572)

Every credentialed mariner needs a TWIC — required for license issuance under 46 CFR §10.107. 5-year renewal. Check expirations. The renewal pipeline at TSA is currently 6-8 weeks. If anyone expires inside that window, start the renewal now.

4. Drug & alcohol program (46 CFR Part 16 + 49 CFR Part 40)

Paperwork-heavy. Have ready:

• Written DOT-compliant drug testing policy signed by the company
• C/TPA contract if you use a Consortium/Third Party Administrator
• Random pool roster with covered employee count
• 25% annual random testing rate documentation
• Pre-employment test results for every covered employee
• Post-accident testing protocol per 49 CFR §40.285
• Reasonable suspicion training records for supervisors

Annual MIS report (CG-4617) is required if you have 50+ covered employees. Most small Sub T operators don't, but document why you're below threshold.

5. Drill records (46 CFR §199.180)

This is the one you'll get asked about first. The Coast Guard wants to see:

• Monthly fire drill for the past 12 months
• Monthly abandon-ship drill for the past 12 months
• Quarterly man-overboard drill
• Crew participation logged per drill (who, what role, what was practiced)
• Deficiencies noted and corrected — a "perfect" drill log every month for two years is suspicious

If your drill log has gaps, don't fabricate. Inspectors compare drill dates against AIS movement records and crew schedules. Backfilling looks exactly like backfilling. Better a real gap with a remediation plan than a fake-perfect log.

6. Posted muster list (SOLAS III + 46 CFR §185.514)

The muster list must be posted in conspicuous locations visible to passengers before getting underway. Inspectors walk passenger spaces looking for it. The list must show every crew member's emergency station, signals, and assigned actions in fire/abandon ship/MOB scenarios. Update it every crew change — stale muster lists with former crew is a common finding.

7. PFDs — count, condition, sizing

Per 46 CFR §180.70:

• One adult PFD per passenger and crew (Type I for ocean, Type I or II for coastal)
• Plus 10% additional stored in marked locations
• Child-sized PFDs for any passenger under 90 lbs
• Infant PFDs for any passenger under 35 lbs

Inspect for serviceable straps, no mildew or compression, retroreflective tape intact, light + whistle attached. Pull a random 10% sample and physically inspect each one.

8. Pre-departure passenger briefing log (46 CFR §185.506)

Every voyage requires a pre-departure briefing covering emergency signals, PFD location and donning, muster station, no-smoking areas, and emergency exits. Most operators have it scripted; what they don't have is a log showing the briefing happened on every voyage. Simplest fix: a one-line entry on every voyage manifest confirming the briefing was given.

9. Lifesaving equipment + service tags (46 CFR Part 180)

Walk the vessel with a flashlight. Check:

• Liferafts — annual service tag from a USCG-approved facility, HRU in date
• EPIRB — battery date, registration current with NOAA, HRU in date
• Pyrotechnics — 43 months from manufacture for SOLAS-grade, in approved container
• Lifebuoys — minimum count per 46 CFR §180.78, retroreflective tape, lights working

Service tags are the easy gotcha. If a liferaft was last serviced 14 months ago, you're past due. Schedule before inspection, not after.

10. Fire suppression equipment (46 CFR Part 181)

• Portable extinguishers — annual inspection tag, monthly visual check log
• Fixed fire suppression (engine room) — semi-annual professional service, hydrostatic test current
• Fire pumps — operational test logged
• Fire detection — every detector tested, log retained

Inspectors pull a random extinguisher and check the tag. They'll ask for the monthly visual check log and to see the fixed system armed.

11. Bilge pumps + general alarms (46 CFR §182.520, §183.520)

Demonstrate that every bilge pump runs from its designated power source, the general alarm sounds throughout the vessel from every activation point, the PA reaches every passenger space, and battery backup engages when shore/main power is removed. Test before the inspector arrives — a general alarm that doesn't sound in the head is a finding you should have caught in pre-check.

12. Stability + load line (if applicable)

If your vessel is 79 feet or longer or operates internationally, you have stability and load line obligations. For most coastal Sub T vessels this is a documentation check — stability letter from an approved naval architect, maximum capacity posting per 46 CFR §177.480, and loading conditions documented for normal operations. International voyages need an Assignment of Load Lines per 46 CFR Part 42.

A real example: 79-ft coastal catamaran

Vessel: 79-ft aluminum catamaran, 79 GT, 49 passengers, coastal/near-coastal, 4 crew (Master, Mate, 2 deckhands).

A complete Inspection Pack is roughly 45 pages as a single PDF: cover with vessel particulars, current COI photo, Master/Mate/deckhand credential summary (MMC, medical, TWIC, Radar Observer with expirations), 12-month drill log, posted muster list, drug testing documentation, PFD inventory, lifesaving and fire equipment service tags, bilge/alarm test log, briefing log sample, stability letter, and last 30 days of voyage manifests.

The first time I built one of these by hand it took 4 hours. Now we generate it in one click from data already in the system, which is the point of the Inspection Pack module.

Common gotchas

The medical cert that expires before the MMC. Two-year cycle on the medical, five-year on the MMC. Set independent reminders.

Drill log gaps you forgot about. If a deckhand was sick for the August fire drill and you skipped it, that's a gap. Catch it now and run a make-up drill before inspection — and document the make-up clearly.

Stale muster list with former crew. Update it every crew change. Inspectors notice when the muster list shows a captain who left six months ago.

Liferaft service tag in date but tag illegible. Salt and sun fade the printed dates. If the tag is unreadable, schedule re-service even if the date is technically still valid.

TWIC renewal lag. TSA's pipeline runs 6-8 weeks. Plan accordingly. Crew operating without TWIC during a renewal lag is a finding even if the renewal is in process.

What Binnacle AI does for this

Binnacle AI's Inspection Pack module pulls every item on this checklist into a one-click PDF formatted for the inspector. Credential expirations alert you 90/60/30 days out. Drill logs auto-populate when crew records the drill. Service tag photos attach to equipment records. The pack regenerates whenever you ask for it, so the data is always current. For $99/month per organization, you stop assembling COI prep packets manually and start handing the inspector a complete bundle on arrival.

Try the free calculator

Before you commit to anything — ours or anyone else's — pull a real CFR checklist for your specific vessel:

[Try the free compliance calculator →](/compliance-calculator)

Enter your vessel's subchapter, GT, route, and passenger count. Get a checklist of 46 CFR sections that apply, with citations, in under two minutes. Bring it to your next pre-inspection prep session. Use the eCFR and your local USCG Sector Homeport page for any sector-specific overlays.

Capt J is the founder of Binnacle AI. He runs a small maritime tech company on Oʻahu that builds compliance tools for commercial fleets. None of this article is legal advice and Binnacle AI is not affiliated with the U.S. Coast Guard. Consult a qualified maritime attorney for specific regulatory questions. All CFR citations refer to the current Code of Federal Regulations as of publication date; confirm against eCFR before filing or inspection.