NVIC 05-91: Inspecting river barges carrying occupied RVs

Last reviewed: October 14, 2026

This circular gives guidance to OCMI's and the marine industry on inspecting and certifying barges that carry occupied RV's. The Coast Guard determined that these barges are a passenger carrying situation. Regardless of size, they should be inspected in accordance with 46 CFR Subchapter H -Passenger Vessels.

Applies toThe circular applies to barges carrying occupied RV's, and it gives guidance to OCMI's and the marine industry.

What it says

  1. The circular provides guidance to OCMI's and the marine industry on inspecting and certifying barges that carry occupied RV's.

    “The purpose of this Circular is to provide guidance to OCMI's and the marine”

  2. The Coast Guard determined that a passenger carrying situation exists when barges carry occupied RV's.

    NVIC 05-91 a.“a passenger carrying situation has been determined to exist in these instances.”

  3. The Coast Guard determined that the size of the vessel does not adequately reflect the safety risks of this type of operation.

    NVIC 05-91 a.“it has also been determined that the size of the vessel does not adequately reflect the safety risks involved.”

  4. Regardless of size, these vessels should be inspected in accordance with 46 CFR Subchapter H -Passenger Vessels.

    NVIC 05-91 a.“regardless of size, these vessels should be inspected in accordance with 46 CFR Subchapter H -Passenger Vessels.”

  5. The Coast Guard states that it is impossible for the RV's to meet the Subchapter H standards for accommodations on passenger vessels, because of the large amount of wood, aluminum, and plastic used in their construction.

    NVIC 05-91 b.“it is impossible for these vehicles to meet the standards for accommodations on passenger vessels as specified in Subchapter H.”

Common questions

How should barges carrying occupied RVs be inspected?

Regardless of size, these vessels should be inspected in accordance with 46 CFR Subchapter H -Passenger Vessels.

“regardless of size, these vessels should be inspected in accordance with 46 CFR Subchapter H -Passenger Vessels.”

Is a barge carrying occupied RVs considered a passenger carrying situation?

Yes. The Coast Guard determined that a passenger carrying situation exists in these instances.

“a passenger carrying situation has been determined to exist in these instances.”

Why were RV barge tows operating without Coast Guard inspection?

The regulations in Title 46 CFR do not specifically address this type of operation, so the tows operated under bareboat charter without Coast Guard inspection and certification.

“these tows have been operated under bareboat charter without the benefit of Coast Guard inspection and certification.”

The text of NVIC 05-91

U.S. Coast Guard, NVIC 05-91 (main body; enclosures not shown)

Inspection and Certification of River Barges Carrying Occupied Recreational Vehicles (RVs)

United Stales COMDPTPUB P16700.4 Coast Guard NVIC 5-91 8 Mar 191 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 5-91 Electronic Version for Distribution on the World Wide Web Subi: Inspection and Certification of River Barges Carrying Occupied Recreational Vehicles (RV's)

Inspection and Certification of River Barges Carrying Occupied Recreational Vehicles (RVs) — PURPOSE. The purpose of this Circular is to provide guidance to OCMI's and the marine

industry for the inspection and certification of barges carrying occupied RV's

Inspection and Certification of River Barges Carrying Occupied Recreational Vehicles (RVs) — BACKGROUND.

a. Several proposals have recently been presented to the Coast Guard by private citizens and organizations involving scenarios where occupied RV’s are carried on the decks of barges and operated on inland waters. b. Previously, RV tours have been available on piggyback trains and ferries. One of the proposed operators has been in business since 1975, conducting these tours in Alaska, Canada, and Mexico. These recent proposals involve the use of several deck barges in tows of varying lengths. At least one proposal involved former tank barges that have been gas freed and modified for this service. c. Since the regulations in Title 46 CFR do not specifically address this type of operation, these tows have been operated under bareboat charter without the benefit of Coast Guard inspection and certification.

Inspection and Certification of River Barges Carrying Occupied Recreational Vehicles (RVs) — DISCUSSION.

a. The Coast Guard has explored the question of whether barges with occupied RV's on board could be certificated. Upon review, a passenger carrying situation has been determined to exist in these instances. Due to the uniqueness of this type of operation, it has also been determined that the size of the vessel does not adequately reflect the safety risks involved. Accordingly, regardless of size, these vessels should be inspected in accordance with 46 CFR Subchapter H -Passenger Vessels. b. Several significant issues are apparent when attempting to make these converted barges conform to Coast Guard passenger vessel regulations. Due to the large amount of wood, aluminum, and plastic used in the construction of the RV's, it is impossible for these vehicles to meet the standards for accommodations on passenger vessels as specified in Subchapter H. Cooking and heating equipment typically found in the RV's would not be of marine quality and built to the marine standards for inspected vessels.

The plain-English explanation on this page was written with AI from the regulation text above and checked automatically before publishing: every quote appears in the text, every number comes from it, and a second model confirmed each statement adds nothing the text doesn't say. The regulation text governs. RegKnot is not affiliated with the U.S. Coast Guard.