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

2. 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 (b) of the Code of Federal Regulations. With confirmation of full compliance with the RCP and of the requirements in Part by a third-party organization, the TPO may issue [an AWO] member company a TSMS Certificate.”

3. 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

4. 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…

5. 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

6. 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

7. 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

8. 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

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

10. 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

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

12. 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

13. Questions & Discussion
Mark Wright
Caitlyn Stewart
Brian Bailey