In October 2014, the AWO Board of Directors approved changes to the Responsible Carrier Program to ensure its acceptance by the U.S. Coast Guard as a Towing Safety Management System (TSMS) under Subchapter M. In June 2015, the Coast Guard confirmed its intent to accept the RCP as a TSMS based on its assessment that the RCP is substantively equivalent to the ISM Code and achieves the audit frequency required by Subchapter M. The Coast Guard commended the AWO Board of Directors and membership for their commitment to safety leadership and continuous improvement of the RCP. Now that Subchapter M has been released, AWO is working with the Coast Guard to identify any additional changes to the RCP needed to finalize its acceptance as a TSMS.
Implementation of the Board-approved changes to the RCP, which took effect January 1, 2016, will be essential to the smooth implementation of Subchapter M.
A memo to third-party auditing organizations with clarifications and directives from the most recent RCP Standard Board Meeting can be found here.
You can find a proposed revised clean copy of the RCP here, and proposed revision mark ups to the RCP here. These proposed changes would go into effect in July 2018 to coincide with Subchapter M effective date. Additionally, these revisions have been proposed by the RCP Standards Board to align the RCP with Subchapter M. Comments, concerns, and questions are requested by COB Friday, September 15th to Brian Bailey at email@example.com.
The changes and additions to the RCP include the following:
- Changes to internal and external audit frequency
- Changes to internal audit procedures
- Near-miss reporting/lessons learned and corrective actions program
- Risk assessment procedures to assess and manage risks to personnel, vessels and the environment
- Identification of critical or essential equipment/systems
- Authority of the master, crew and shoreside personnel
- Addition of document control procedures
- Tracking of number and volume of spills in performance measurement requirements
Materials on each topic are provided here to assist AWO members in implementing the changes. This website should be your first resource for information about the RCP revisions.
For more information, please contact Brian Bailey at (703) 841-9300, ext. 252, or firstname.lastname@example.org.