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RCP v. Subchapter M

The proposed rule containing regulations for the inspection of towing vessels, known as Subchapter M, is due to be published in a few months.  It is expected that these regulations will include a towing vessel safety management systems. Many towing vessel companies currently have a safety management system (SMS) in place known as the American Waterways Operators (AWO) Responsible Carrier Program (RCP).  Having been both a U.S. Coast Guard marine inspector and an AWO RCP auditor, I have noticed a different expectation regarding the level of implementation required between inspected vessel's SMS and RCP. I suspect that some RCP companies might have a difficult time with Subchapter M enforcement if they don't step up the level of implementation.


An interesting marine casualty report has been published by the Coast Guard regarding the unfortunate death of a U.S. merchant mariner. I recommend anyone involved in an SMS click on the link below, and/or if the link times out: go to Homeport, Investigations, & scroll down and open "S/R Wilmington Personnel Casualty," and take note of the emphasis placed on the SMS in this accident report, and how the Coast Guard intends to step up SMS enforcement.


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