Utilizing the RCP to Comply with Subchapter M GNOBFA Subchapter M Forum February 2, 2016

RCP Acceptance as Existing SMS “The U.S. Coast Guard has determined the AWO Responsible Carrier Program is an existing Safety Management System that complies with the requirements of Subchapter M, Title 46, Part 138.225(b) of the Code of Federal Regulations. With confirmation of full compliance with the RCP and of the requirements in Part 138.225 by a third-party organization, the TPO may issue [an AWO] member company a TSMS Certificate.”

Responsible Carrier Program® Accepted as a USCG-approved TSMS RCP changes effective January 1, 2016 RCP Addenda changes effective November 15, 2016 Mid-Period Audit Requirement 180, 90 and 30 day audit reminders New member RCP onboarding AWO-ACC Memorandum of Agreement Relationships with TPOs Post-RCP audit surveys/questionnaires RCP Standards Board Subchapter M implementation

Third-Party Auditing Organizations …provide members with a large, geographically dispersed pool of well trained, well qualified auditors to conduct RCP audits to facilitate the implementation of Subchapter M…

RCP Accepted as SMS RCP auditing options: Recognized classification societies: ClassNK and ABS Coast Guard-approved third-party organizations: TVIB Other TPOs seeking AWO authorization As a reminder, RCP Standards Board has recommended and AWO Board has endorsed: Sunset prescriptive RCP requirements and revise addenda as of July 20, 2018 Develop one-stop-shop compliance guide for members

Coast Guard-AWO Dialogue Bimonthly meetings with Coast Guard Implementation Team Working with Coast Guard to ensure seamless transition to Subchapter M audit regime AWO Towing Vessel Inspection Working Group providing input on prioritization of pending FAQs

TSAC Subchapter M Implementation Subcommittee Reviewing and providing input on Coast Guard’s draft implementation policy and guidance Marine Safety Manual Vol. III Report accepted in October TPO Guidebook Report to be considered in April Forthcoming TSMS and compliance guidebooks

What We’re Working On One-stop-shop Subchapter M compliance guide What you must include in your TSMS What you may include in your TSMS Issues for RCP-certified companies transitioning to Subchapter M compliance

Survey Program Policies and procedures for complying with external or internal survey program requirement

Other Requirements or Allowances Permit to Proceed and/or Permit to Carry an Excursion Party procedures Policies and procedures for employing and documenting an underwater survey in lieu of drydocking Requirements of Part 140: Safety orientation and training requirements Health and safety plan Recordkeeping procedures

Other Requirements or Allowances Alternative compliance arrangements, if applicable Alternate lifesaving or firefighting arrangements or equipment

Transition Issues Will the Coast Guard accept internal survey report as objective evidence for COI application? Answer: Yes Will the Coast Guard accept external management audits or vessel audits conducted by organization that was not approved as TPO at time of audit for issuance of TSMS Certificate/COI? Answer: Yes, with conditions Will the Coast Guard accept external vessel audit that took place prior to issuance of TSMS Certificate? Answer: TBD

Questions & Discussion Mark Wright mwright@americanwaterways.com Caitlyn Stewart cstewart@americanwaterways.com Brian Bailey bbailey@americanwaterways.com