You've built your SMS, completed Form 85-0547A and Form 85-0547B, and sent your package to Transport Canada. Now what?
A lot of operators submit their application and then wait in silence, not knowing whether no news is good news or whether their package is sitting in a pile somewhere. Here's what TC actually does with your submission and what you can expect at each stage.
The 45-Day Rule
Transport Canada has up to 45 business days from receipt of a complete application to issue your Canadian Maritime Document. That's roughly nine calendar weeks - just over two months - assuming your submission is complete and doesn't require any back-and-forth.
Two things to understand about that number:
- It's 45 business days, not calendar days. Weekends and statutory holidays don't count. Factor this in when you're planning your timeline.
- The clock starts on receipt of a complete package. If TC receives your package and something is missing or incorrect, they'll contact you to request the outstanding information. The 45-day clock doesn't start - or restarts - from when the complete package is in their hands.
For Class 4B operators already past the July 2025 grace period: Every day your application is incomplete or contains errors is another day you're operating non-compliantly. Get it right the first time.
What TC Does During the Review
What TC Is Actually Looking For in Your SMS
TC reviewers see hundreds of SMS submissions. The ones that sail through review share certain characteristics:
- They're specific to the vessel. Vessel name, official number, trade area, and operational specifics appear throughout the document - not just on the cover page.
- Emergency procedures match the actual vessel layout. Muster stations, life raft locations, fire extinguisher positions - these are named specifically, not left as blanks or placeholders.
- The Ship Manager and AR information is consistent. The same names and contact information appear on Form 85-0547A, Form 85-0547B, and throughout the SMS manual.
- All required elements from TP 15566 Part 3 are present. Nothing is missing. The annual review process is documented. Non-conformity reporting is addressed.
- The document looks like it will actually be used. Procedures are written in plain language that crew members can follow. Checklists are practical. The whole thing is organized so it can be found and used quickly on the water.
Common Reasons Applications Are Returned
Based on the pattern of what TC flags, these are the most common problems:
- Missing or unsigned Form 85-0547A or Form 85-0547B
- SMS manual that is clearly a generic template with minimal customization
- Emergency procedures that don't match the actual vessel (wrong equipment locations, wrong crew numbers)
- Missing required elements - particularly non-conformity reporting and annual review processes
- Inconsistency between forms and the SMS documentation
- Missing Certificate of Registry or crew certificates
- Vessel information on the forms that doesn't match the Certificate of Registry
After You Get Your CMD
Receiving your Canadian Maritime Document is not the end of the process - it's the beginning of the ongoing compliance obligation.
- Keep your CDOC and CSMC aboard the vessel at all times
- Conduct your annual SMS review on schedule (from your implementation date, not your CMD date)
- Update your SMS any time your operation, vessel, crew, or trade area changes materially
- Notify TC if your Ship Manager changes
- Maintain crew training records and ensure new crew are familiarized with the SMS before operating
- Report marine occurrences as required
TC can inspect at any time. Keep your SMS current, keep your records organized, and make sure your crew can speak to the procedures. A TC inspector may ask crew members directly about emergency procedures - if your crew don't know where to find the life raft, that's a problem regardless of what the SMS document says.
Want to make sure your application goes through the first time?
AMSG prepares TC-ready application packages and follows up through to CMD issuance. We know what TC looks for because we've been through the process with operators across Ontario.
Start Free Assessment Call 416-938-6671