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 under Subchapter M. In June 2015, AWO received confirmation from the Coast Guard that the changes to the RCP position the agency to formally accept the RCP as a TSMS when the towing vessel inspection regulations are published as it has concluded that the revised RCP is substantively equivalent to the ISM Code and that the revised external audit schedule is consistent with the requirements of the Subchapter M NPRM. The Coast Guard commended the AWO Board and membership for their commitment to safety leadership and continuous improvement of the RCP.

Implementation of the Board-approved changes to the RCP by all AWO members will be essential to the smooth implementation of Subchapter M. On May 22, at the recommendation of the RCP Standards Board, the AWO Board set January 1, 2016, as the effective date for the changes.

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. In addition, AWO will conduct webinars on each topic and keep an updated page of Frequently Asked Questions to address questions as they arise. This website should be your first resource for information about the RCP revisions.

For more information please contact Brian Bailey, (703) 841-9300, ext. 252, or bbailey@americanwaterways.com.