AWO RCP Accepted as Existing SMS Under Subchapter M

The U.S. Coast Guard formally accepted the American Waterways Operators (AWO) Responsible Carrier Program (RCP) as an existing Safety Management System that complies with the requirements of Subchapter M.

In a letter conveying the acceptance, RADM Paul Thomas, Assistant Commandant for Prevention Policy, wrote, “This is a significant milestone in the implementation of Subchapter M and... your staff and your members are to be commended on this remarkable achievement. This is an important first step in instilling a culture of safety across the towing industry.”

Subchapter M, which was published in the Federal Register on June 20, establishes two paths to compliance for towing vessel operators: either annual Coast Guard inspections or the implementation of a Towing Safety Management System (TSMS) audited by a Coast Guard-approved third-party organization (TPO). RADM Thomas’s letter confirms that “with confirmation of full compliance with the RCP and of the requirements in Part 138.225 by a [TPO], the TPO may issue a[n AWO] member company a TSMS certificate.”

The RCP provides AWO member companies with a framework for continuously improving safety and environmental performance. AWO members of all sizes use the RCP to develop company-specific safety and environmental policies and programs tailored to their unique operations. Since 2000, compliance with the RCP has been a condition of AWO membership.

“AWO is gratified by the Coast Guard’s acceptance of the RCP, the most widely used safety management system in the tugboat, towboat and barge industry, as an existing Safety Management System that meets the requirements of Subchapter M. We are committed to continuing to work with the Coast Guard to facilitate our members’ use of the RCP as a practicable vehicle for compliance with the TSMS option,” said Jennifer Carpenter, AWO Executive Vice President & COO.