In a letter to the American Waterways Operators June 1, the Coast Guard has indicated that it intends to accept AWO’s Responsible Carrier Program (RCP) as a Towing Safety Management System (TSMS) under the new Subchapter M regulations. The new projected date for publication of the Subchapter M final rule is February 2016.
The letter was in response to a November 2014 AWO letter that requested that the Coast Guard accept RCP as a TSMS under Subchapter M. A TSMS designee will be able to inspect a vessel instead of the Coast Guard.
“While the specific requirements of Subchapter M are not final, and will not be so until the final rule is published, we have conducted a preliminary review of the RCP against the requirements of 33 CFR Part 96 (U.S. regulations implementing the ISM code) and the Subchapter M NPRM,” Capt. K.P. McAvoy, chief, office of commercial vessel compliance, said in the letter. “Based on this review, we conclude that the RCP is substantively equivalent to the ISM code and that the revised external audit frequency comports with the requirements proposed in the Subchapter M NPRM.”
While not officially accepted as a TSMS under Subchapter M's NPRM, the Coast Guard said in the letter that when the final Subchapter M rule is published, "we will work with AWO to identify any changes to the RCP that are needed to formally accept the RCP as a TSMS under Subchapter M."
