Certifying a Vessel for Passengers for Hire

The question often comes up, What would it take to get my boat licensed for carrying passengers?  Many assume that if their boat is well built and met all ABYC standards when it was built, that it shouldn't be a big deal. That may be true if you don't need to take more than 6 (or if your boat is over 100 Gross Tons (domestic), in which case you can take up to 12).  Those boats can operate as "Uninspected Small Passenger Vessels", and no formal Coast Guard approval is required.  

However, to exceed those passenger limits, the vessel must be an "Inspected Small Passenger Vessel" and carry a valid "Certificate Of Inspection" (COI) from the Coast Guard. To obtain a COI requires formal submittals of drawings, calculations, and tests to be approved by a Coast Guard Inspector. 

First, here is some clarification of some common mis-conceptions:

  1. You cannot bareboat charter a boat and then hire yourself back as captain -- that used to be the case some years ago, but it is expressly prohibited now.
     
  2. Just because a boat is well built doesn't mean it will be no problem getting certified. You still have to a.) Prove it (with plans, tests, and calculations), and b.) meet the letter of all requirements, not just be good marine practice. (Are the handrails 39.5" high? No, they're only 39"? You have to raise them! Do you have 32" wide exit doors? Of course not -- better get the sawsall out!)
     
  3. The Subchapter T construction and arrangement regulations apply to all boats carrying more than 6 passengers for hire (or more than 12 if the boat is over 100 Gross Tons (domestic)). Generally the boat must be US built though, which means Willards are certainly eligible.

Bottom line is that you need to jump through quite a few hoops to get any boat certified -- new or used. The Coast Guard needs to confirm that the hull is built to a classification standard such as ABS or Lloyds Rules (doesn't have to be CLASSED, just built to a standard.) All mechanical, electrical, and plumbing systems need to meet either the Coast Guard regulations in Subchapter T, or if the passenger count and vessel length are smaller, ABYC standards. She needs to pass an intact stability standard, which usually requires physical testing (even if there are near sister vessels operating that have passed.) (A Damage Stability standard is not required if under 65 feet.) A collision bulkhead is required if operating on Exposed or Partially Protected waters. (It must be located between 5 and 15% of the waterline length aft of the stem, so even if you have one, it's gotta be in the right place.)

And all of the above needs to be documented to the satisfaction of the Coast Guard, which means accurate plans need to be drawn up and calculations submitted for approval. It can certainly be done, and is done all the time, but you need to be aware that it can take time and money to get that COI in your hands. Lots more to it than just being "seaworthy and not leaking fluids"!

My experience with the Coast Guard is that they are there to help you through the process, and they generally are very helpful in outlining the requirements and explaining the reasoning. However they do have a huge and varied mission, so there's definitely a limit to the amount of hand-holding they can do. So it's good to do a little homework before proceeding. The first step is to review the Regs (see the links below) and make a list of questions. Then contact your local Coast Guard Inspections office (OCMI, Officer in Charge Marine Inspection). They will assign an Inspector for the boat only if you can convince them you are serious -- i.e. you actually own the boat and are actively planning to make the necessary changes to put her into service. Then you can work closely with your inspector to work out what needs to be done and what documentation the Coast Guard will need. (My advice: don't try to fight them - it's worth developing a friendly, cooperative rapport with them.)

References:

-Rick Etsell, P.E., naval architect