American Waterways Operators Annual Report 2017 2017AnnualReport - Page 11

SUBCHAPTER M :

Improving Safety , Promoting Efficiency

AWO worked with the Coast Guard throughout 2017 to ensure a practical approach to implementing the new Subchapter M regulations that elevates industry safety standards without disrupting navigation or imposing undue burdens on vessel operators . AWO also continuously provided members with information and resources to facilitate a seamless transition to Subchapter M compliance .
To support members in understanding and implementing the regulations , AWO maintained an ongoing dialogue with the Coast Guard ’ s Subchapter M implementation team ; secured publication of Coast Guard policy letters to facilitate the transition to Subchapter M for companies that choose the Towing Safety Management System compliance option ; created a TSMS Option Compliance Guide for member use ; and launched the Countdown to Compliance communications campaign , consisting of weekly updates as well as panel discussions with industry and Coast Guard experts .
Throughout this process , the AWO Board of Directors reaffirmed AWO ’ s foundational commitment to fostering a culture of safety , not merely a culture of compliance , reiterating the requirement for compliance with a safety management system as a condition of AWO membership . At the same time , AWO sought to increase flexibility and expand compliance options for members by allowing the use of safety management systems equivalent to the Responsible Carrier Program to satisfy AWO membership requirements ; developing a process to align Subchapter M and RCP audit recertification dates ; securing publication of a Coast Guard policy letter to provide credit under Subchapter M for previous RCP management and vessel audits ; and adding three new Coast Guardapproved third-party organizations as RCP audit partners .
2017 ANNUAL REPORT DELIVERING VALUE 9
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