TVIB – RCP MANAGEMENT AUDIT WORKSHEET WITH AWO … · these recommended items is optional at the...

COPYRIGHT © TOWING VESSEL INSPECTION BUREAU (TVIB) – 2017

TVIB – RCP MANAGEMENT AUDIT WORKSHEET

WITH AWO APPROVED RCP POLICIES AND EXPECTATIONS

AWO Approved Policy & TVIB Policy Regarding RCP Compliance

AWO Approved RCP Definitions

Section 2 – Safety Policy and Program

Section 3 – Security Policy and Program

Section 4 – Environmental Policy and Program

Section 5 – Company Employees Responsibilities and Authorities

Section 6 – Resources and Personnel

Section 7 – Plans and Procedures for Vessel Operations

Section 8 – Emergency Response Procedures

Section 9 – Incident Investigation and Review

Section 10 – Vessel Maintenance

Section 11 – Auditing and Review Procedures

Section 12 – Document Control

Section 13 – Risk Management APPROVED BY AWO STANDARDS BOARD 10.23.2015 Last Revised: 01.01.2017

FM-RCP-01.12 (3.0)

COPYRIGHT © TOWING VESSEL INSPECTION BUREAU (TVIB) – 2017 TVIB RCP MANAGEMENT AUDIT WORKSHEET - (1) – 01.01.2017

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AWO Approved Policy Regarding RCP Compliance The following policy regarding RCP Compliance is being provided to help clarify AWO’s position regarding compliance with the RCP in preparation for use by TVIB to train auditors and instruct them in how to make compliance determinations during RCP audits. In the AWO RCP manual we find two paragraphs which provide policy guidance in the introduction to the Management Section on page II-1. That guidance is repeated here below in plain text. The items presented in italics are intended to provide clarification for all stakeholders who are involved in the RCP process. Each towing company should develop and document written policies and procedures covering at a minimum, those items outlined below (in the RCP). The RCP then goes on to list all of the required elements of the Management Section of the RCP.

Third-Party Auditors who are auditing an RCP management system on behalf of an AWO member company should expect to find written policies, procedures, plans, programs, documented processes, checklists, etc., which cover all the required items listed in the RCP program manual. Items denoted in the manual as being recommended are only there for clarification and the company’s compliance with these recommended items is optional at the company’s discretion.

Companies should abide by these policies (and procedures) in conducting their operations and should ensure that their employees are aware of, and trained in, those policies and procedures which affect their job responsibilities.

Third-Party Auditors should expect to find written policies and/or procedures that describe the company’s expectations in regard to the subject matter addressed by each policy and/or procedure and should find employees of that

company who are aware of, and trained in, those policies and procedures which affect their job responsibilities.

Companies should develop a mission statement expressing their commitment to abide by their established policies and procedures and to ensure employee awareness and knowledge thereof.

Third-party auditors should expect to find a written mission statement that expresses the company’s commitment to abide by their established policies and/or procedures and to ensure employee awareness and knowledge thereof.

All AWO carrier members, as a baseline, should be in compliance with all applicable federal laws and regulations concerning marine safety and environmental protection.

Third-party auditors should expect to find each towing company to be in compliance with all applicable federal laws and regulations concerning Marine Safety and Environmental Protection. It seems apparent that applicable Federal Law, USCG and EPA regulations, and any other government regulations which address issues relating to Marine Safety and Environmental Protection should be addressed by each towing company intending to comply with the RCP. (See OSHA regulations addressed below)

All company policies and procedures should be consistent with applicable law and regulation and with the guidelines provided in the Equipment and Inspection and Human Factors sections of the AWO Responsible Carrier Program.

Third-party auditors should expect to find written company policies and/or procedures that are consistent with applicable law and with applicable guidelines provided by AWO throughout the RCP.


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Required procedures are to be documented and implemented.

Third-party auditors should expect to find written documentation to show compliance with their company policies and procedures. Third-party auditors should be aware that all items listed in the checklists which are provided for use by third-party auditors are required for a company to be considered compliant with the RCP.As of the January 1, 2016 revision, recommended practice items have either been made required or removed from the checklist; there is no longer any recommended items.

Parenthetical items preceded by “e.g.,” (or “for example”) may not be applicable in all situations and are intended to serve only as examples of the types of items which company policies and procedures may address. Compliance with OSHA Safety and Health Standards:

While compliance with applicable federal law and government regulations concerning marine safety and environmental protection are required by the RCP, compliance with OSHA Safety and Health Standards which do not address issues of marine safety or environmental protection are left up to the discretion of the member company. The one exception to this policy is OSHA’s Hazard Communication (Right-to-know) standard. This standard listed in 29 CFR 1910.1200 which is made a part of the management section of the RCP. Since OSHA standards in most cases do not address marine safety or environmental protection issues, the RCP does not require those companies intending to comply with the RCP to be in compliance with all OSHA standards. However, it is the intent of the RCP that each company intending to comply with the RCP should consider all safety and health hazards that may impact their employees and take such action as the

company may deem necessary to ensure the safety and health of its employees in the workplace. AWO believes that some OSHA standards have considerable value as guidelines for companies wishing to protect employees’ safety and health and encourages those companies to use the OSHA standards as guidelines whenever they appear to be applicable in their workplace. Note: All other references to any specific OSHA Safety and Health standards throughout this document are placed there as additional information only and are not to be interpreted as being the only OSHA standards that may apply to work being done in the member company workplace. In other words, these references are not intended to be referred to as an all-inclusive list of OSHA standards.


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TVIB Policy Regarding RCP Compliance The following policy regarding RCP Compliance is being provided to help clarify TVIB’s position regarding auditors’ compliance with the intent of the RCP. This policy is intended to serve as a guide for TVIB to use to train auditors and instruct them in how to make compliance determinations in accordance with AWO approved guidelines and interpretations during RCP audits of AWO member companies. The policy of TVIB is for TVIB Certified AWO RCP Auditors to follow the instructions issued by TVIB at all times when engaged in making objective determinations as to RCP compliance during an RCP audit of an AWO member company. TVIB will endeavor to ensure that there is no conflict between the information provided in the AWO “approved” overarching policy regarding compliance with the RCP which immediately precedes this TVIB policy in this document and the processes, information and training materials TVIB will utilize to train and certify TVIB Certified AWO RCP Auditors who will be expected to accomplish RCP audits in accordance with these documents. TVIB will also endeavor to ensure that all training materials, auditor certification processes, and TVIB developed RCP Audit Tools that are utilized by TVIB to train and certify TVIB Certified AWO RCP Auditors will be in agreement with the written guidance that is contained in the AWO approved definitions section of this document and in the AWO approved RCP Checklists that are also a part of this document and which immediately follow this policy. TVIB will endeavor to continually improve its auditor certification processes and its RCP audit processes in accordance with its agreement with AWO and will endeavor to remain in compliance with AWO approved documents, definitions, checklists, and written instructions at all times.

It is the intention of TVIB that all opinions issued by TVIB Certified AWO RCP Auditors involving interpretation of RCP standards are to be issued in accordance with written guidance approved by the American Waterways Operators. When TVIB discovers that written guidance from AWO pertaining to interpretation or understanding of any RCP standards is not in alignment with a written TVIB policy or instruction to auditors, TVIB will immediately contact AWO and seek written guidance from the appropriate parties within AWO before continuing the process.


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AWO Approved RCP Definitions (as of 01/01/2017)

The following definitions are being incorporated into the RCP in order to provide consistent guidance for both companies and third-party auditors as they go about complying with and auditing the RCP. All stakeholders should make themselves familiar with the following definitions. As issues and questions become known over time, additional definitions will be added to this document. Authority The power or right to give orders, make decisions, and enforce obedience. Essentially, authority is what you can do (as opposed to/compared with responsibility). Chain Guards See definition for safety/guard chains. Clarity: The ability of a process, idea, concept, or element of a program to be communicated and understood by the people. To provide clarity means to provide intent, sufficient detail and specificity so as to make it easy for something to be communicated and to be understood by the people in the same context intended by the writer. A process that has clarity is clearly defined. Compliance with Official Instructions (Maritime Security) Compliance with official instructions in the context of maritime security refers to instructions from an official organization or a member of an official organization during a security related activity or event. (In the event of a terrorist attack, security related emergency or threat the USCG or other official organization may communicate instructions to a towing company or a towing vessel and in that type of situation, those official communications from official organizations or individuals must be complied with).

Conformity The fulfillment of a requirement. To conform means to meet or comply with requirements and a requirement is a need, expectation or obligation. Controlled Document Any document identified by the document control program as being included in the program. Corrective Action Action to eliminate or mitigate the cause or reduce the effects of a detected nonconformity or other undesired situation. Critical Equipment and Systems Those equipment and/or systems, the sudden failure of which may place the vessel, crew or environment into a hazardous situation. Critical Operating Policies and Procedures Those procedures that are included in the company’s document control program. Document Control Program A documented procedure that applies to the control of all documents used in the company’s RCP or ISM Safety Management System. This would include all operating policies, procedures, forms and records used within the RCP or ISM. The document control program would include a process for approval, identification, distribution, review, revision and control of obsolete documentation, and also include records retention. Documents used within the system could be in paper, electronic or similar format.


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Documented Process A documented process may consist of a written procedure which implements a written inspection process which utilizes a written safety checklist that contains multiple items. (Typically some, but not all of the items addressed by the safety inspection checklist are required by RCP to be addressed in the company’s safety program. The implementing procedure should identify who is responsible for conducting the inspection, identify which safety inspection checklist is to be used for the inspection, outline details concerning conducting the inspection including frequency of inspection, and describe the corrective action process to be followed to address non-conformities, follow-up to the corrective actions, and record keeping). A documented process, like a written procedure, must close all the loops in the process that is being utilized. Emergency Boat Operation Emergency boat operation is intended to mean operation of any type of small boat such as a skiff, yawl, or motorboat that may be carried onboard a towing vessel and may be used during an emergency response to an incident such as a man over board or other emergency situation as appropriate. Emergency Response Drills Emergency response drills are hands-on practice which challenge towing vessel crewmembers with a particular emergency situation allowing the crews to practice and demonstrate understanding of, and compliance with the company’s written emergency response procedures. (Proper application of emergency response drills should result in a rapid and coordinated response by crewmembers in the event an actual emergency were to occur. A drill should also provide an opportunity to review the requirements of the emergency response procedure. The overall intent of emergency response drills in the marine environment is to test employee performance in accordance with a written procedure and to offer an opportunity to continually evaluate the integrity of each written emergency response procedure).

Emergency Response Training Emergency response training consists of formal hands-on training for towing vessel crewmembers who are expected to become engaged in carrying out a response to different types of emergency situations and should address how those crewmembers are expected to respond as they comply with the company’s written emergency response procedures for a particular emergency situation. Emergency Notification (Maritime Security) Emergency notification in the context of maritime security is any notification required by an official organization or by members of an official organization in the event of a security related emergency or security threat. Face Wires, Spring Lines and Push Gear The USCG uses the term face wires, spring lines and push gear to describe the rigging that is normally used to make up a tow of barges or to face up the towing vessel to its tow when the towing vessel is pushing ahead or towing alongside. The term spring lines and push gear might include ratchets, face wires and rigging wires, chain links, shackles and pins, and various sizes and types of synthetic lines. Essentially, all of the rigging components in use on a towing vessel and its tow when underway would fall under the term face wires, spring lines and push gear as used in 33 CFR 164.76 (33 CFR 164.76) – The owner, master, or operator of each vessel towing alongside or pushing ahead shall ensure that the face wires, spring lines, and push gear used----(a) Are appropriate for the vessel’s horsepower; (b) Are appropriate for the arrangement of the tow; (c) Are frequently inspected; and (d) Remain serviceable. Great Lakes Great Lakes means the Great Lakes and their connecting and tributary waters including the Calumet River as far as the Thomas J. O'Brien Lock and Controlling Works (between mile 326 and 327), the Chicago River as far as the east side of the Ashland Avenue Bridge (between mile 321 and 322), and the Saint Lawrence River as far east as the lower exit of Saint Lambert Lock. (33 CFR 83.03(m))


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Initial Training Each company is expected to define what initial training means to that company and describe whether it is conducted at the time of hire or within a certain specified time period after the employee has been hired. Inland Waters Inland Waters means the navigable waters of the United States shoreward of the navigational demarcation lines dividing the high seas from harbors, rivers, and other inland waters of the United States and the waters of the Great Lakes on the United States side of the International Boundary. (33 CFR 83.03(o)) Waters upon which Inland Rules 9(a)(ii), 14(d), and 15(b) apply: Inland Rules 9(a)(ii), 14(d), and 15(b) apply on the Great Lakes, the Western Rivers, and the following specified waters: (a) Tennessee-Tombigbee Waterway. (b) Tombigbee River. (c) Black Warrior River. (d) Alabama River. (e) Coosa River. (f) Mobile River above the Cochrane Bridge at St. Louis Point. (g) Flint River. (h) Chattachoochee River. (i) The Apalachicola River above its confluence with the Jackson River. (33 CFR 89.25) Waters upon which Inland Rule 24(i) applies: (a) Inland Rule 24(i) applies on the Western Rivers and the specified waters listed in 33 CFR 89.25 (a) through (i). (b) Inland Rule 24(i) applies on the Gulf Intracoastal Waterway from St. Marks, Florida, to the Rio Grande, Texas, including the Morgan City-Port Allen Alternate Route and the Galveston-Freeport Cutoff, except that a power-driven vessel pushing ahead or towing alongside shall exhibit the lights required by Inland Rule 24(c), while transiting within the following areas: (1) St. Andrews Bay from the Hathaway Fixed Bridge at Mile 284.6 East of Harvey Locks (EHL) to the DuPont Fixed Bridge at Mile 295.4 EHL.

(2) Pensacola Bay, Santa Rosa Sound and Big Lagoon from the Light “10” off of Trout Point at Mile 176.9 EHL to the Pensacola Fixed Bridge at Mile 189.1 EHL. (3) Mobile Bay and Bon Secour Bay from the Dauphin Island Causeway Fixed Bridge at Mile 127.7 EHL to Little Point Clear at Mile 140 EHL. (4) Mississippi Sound from Grand Island Waterway Light “1” at Mile 53.8 EHL to Light “40” off the West Point of Dauphin Island at Mile 118.7 EHL. (5) The Mississippi River at New Orleans, Mississippi River-Gulf Outlet Canal and the Inner Harbor Navigation Canal from the junction of the Harvey Canal and the Algiers Alternate Route at Mile 6.5 West of Harvey Locks (WHL) to the Michoud Canal at Mile 18 EHL. (6) The Calcasieu River from the Calcasieu Lock at Mile 238.6 WHL to the Ellender Lift Bridge at Mile 243.6 WHL. (7) The Sabine Neches Canal from mile 262.5 WHL to mile 291.5 WHL. (8) Bolivar Roads from the Bolivar Assembling Basin at Mile 346 WHL to the Galveston Causeway Bridge at Mile 357.3 WHL. (9) Freeport Harbor from Surfside Beach Fixed Bridge at Mile 393.8 WHL to the Bryan Beach Pontoon Bridge at Mile 397.6 WHL. (10) Matagorda Ship Channel area of Matagorda Bay from Range “K” Front Light at Mile 468.7 WHL to the Port O'Connor Jetty at Mile 472.2 WHL. (11) Corpus Christi Bay from Redfish Bay Day Beacon “55” at Mile 537.4 WHL when in the Gulf Intracoastal Waterway main route or from the north end of Lydia Ann Island Mile 531.1A when in the Gulf Intracoastal Waterway Alternate Route to Corpus Christi Bay LT 76 at Mile 543.7 WHL. (12) Port Isabel and Brownsville Ship Channel south of the Padre Island Causeway Fixed Bridge at Mile 665.1 WHL. (33 CFR 89.27) Internal Audit An audit performed within an organization to periodically measure compliance with its safety management system. Internal Auditor The person or persons who conduct the internal audit of the


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company. The auditor must meet training and qualification requirements as specified by the company and be independent of the area being audited, unless it is impractical based on the size of the organization. Major Non-Conformity A non-conformity that poses a serious threat to personnel, vessel safety or the environment, and requires immediate corrective action. Management Office An office that has management oversight of towing vessels. Management Review: An evaluation of the management system that a company has in place that occurs at planned intervals and includes the assessment of opportunities for improvement through effective objective setting. Near Coastal Near Coastal means ocean waters not more than 200 miles offshore. (46 CFR 10.107) Near-Miss An event, or sequence of events, that did not result in an injury or incident but which, under slightly different circumstances, could have done so. Nonconformity An observed situation where objective evidence indicates the non-fulfilment of a specified requirement. Ocean Oceans means the waters seaward of the Boundary Lines as described in 46 CFR part 7. (46 CFR 10.107) Opportunity for Improvement (“OFI”) An audit finding of a recommended item that could be improved upon, but that is not a requirement of the company’s RCP certification.

Periodic Drills (Maritime Security) Maritime security drills are required for crewmembers who are employed onboard towing vessels. The content and frequency of required security drills is specified in the regulations for those companies that operate in accordance with a USCG approved security plans or USCG acknowledged alternative security programs. Companies who are not required to comply with USCG Maritime Security regulations can determine the scope and frequency of security drills for its employees, if any. Periodic Training (Maritime Security) Maritime security training is required for crewmembers who are employed onboard towing vessels. The content and frequency of required training is specified in the regulations for those companies that operate in accordance with a USCG approved security plan or USCG acknowledged alternative security program. Each company can determine the scope and frequency of security training for its employees. Plan (as in security plan, vessel response plan, etc.) A plan is similar to a program and is a term that is often used in regulatory text. A plan is usually comprised of more than a procedure, but less than a program. A plan is used to guide performance and behavior in the accomplishment of a prescribed goal or task. Policy A policy is a high level written document that outlines principles or rules intended to guide decision making and achieve expected outcomes. A policy is a statement of an intent. Policy statements are usually implemented by one or more detailed written procedures that the company determines are necessary to adequately implement the policy. Preventive Action Action taken by a company to mitigate the risk of potential issues in an attempt to prevent their occurrence or recurrence.


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Procedure A procedure is a detailed written document in the form of a step-by-step instruction which is intended to be used by employees to achieve an intended result in a specific situation or over the course of an activity or event. (Every written procedure should include as many of the following elements as are appropriate to that procedure and should be written in the same format as other written procedures contained within the SMS. A written procedure may contain various headings such as: purpose, scope, definitions, responsibility, procedure (the procedure itself which may contain numerous elements as needed to describe the company’s expectations for that procedure), required training, required records, and a revision history. Other heading terminology may be used to define the structure of procedures as determined by the company. A written procedure must contain sufficient structure as needed to be able to close all the loops in the process or activity that is being implemented by the procedure). Program A high level plan of action defined by a series of detailed written procedures which are aimed at accomplishing clear business objectives. (Examples of programs in use in the maritime industry are: Employee Safety & Health Programs, Environmental Compliance Programs, Security Programs, the Responsible Carrier Program, etc). Records Required elements of the RCP must be accomplished in an acceptable manner as specified by the company. Complete records must be readily available at the time of an audit and must provide sufficient documentation to verify that the company’s expectations for compliance with a required element were met and that lists the names of the persons involved in those actions or responsible for having taken those actions. Relevant Materials (II.A.3) All policies, procedures, manuals and forms pertaining to the management of the RCP or other towing safety management system.

Refresher Training Each company is expected to define what refresher training means to that company and describe the frequency and method for refresher training as long as all refresher training is conducted at least once every five years. Responsibility The state or fact of having a duty to deal with something, or having control over someone. Responsibility is what you must do (as opposed to/compared with authority). When someone is responsible for some action or has to take the responsibility for the consequences of actions, taken either by themselves or by somebody else for whom they are responsible. Risk Analysis The systematic use of information to identify sources and to estimate the risk. Risk Assessment A process that includes identifying hazards and analyzing or evaluating the risk associated with those hazards to determine if existing controls are adequate, or if additional controls to eliminate or reduce the risk to an acceptable level to the organization are needed. Risk Control Measures Actions or modifications taken to proactively manage, reduce or eliminate risks. Risk Identification (sometimes called Risk Discovery) Risk identification is a process to determine, recognize and describe the risks that could affect personnel, vessels the environment and that are introduced by changes to equipment, staffing or procedures. Risk Management Coordinated activities to direct and control an organization with regard to risk.


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RCP Required Training RCP required training is defined as being initial training (training that occurs at the time an employee is first hired or at the initial implementation of the program), and refresher training that must occur at least once every five years for each affected employee. The company is expected to include materials and information to describe their training programs in their written program. It is up to the company to determine training needs and methods, as long as the RCP requirements are met and satisfactory training records and course information are kept. Safety Chains / Guard Chains Safety chains are usually provided on towing vessels that do not have bulwarks around the lower deck perimeter and are typically installed along the outboard side of the main deck perimeter to prevent a person from falling overboard. Other terms that are also used to describe a method for prevention of falls overboard from the lower deck or guard deck of a towing vessel are “guard chains” and “guard ropes” or “safety ropes”. Safety Management Systems (SMS) A comprehensive business management system designed to manage safety elements in the workplace. (An SMS may incorporate numerous other components beyond elementary safety and for the towing vessel industry the requirements addressed by an SMS may include but are not limited to, employee health, environmental protection and response, maritime security, company employee responsibilities and authorities, resources and personnel, plans and procedures for towing vessel operations, emergency response, incident investigation and review, maintenance and repair of towing vessels, internal auditing and document control, etc). Safety Rules Written safety rules are frequently organized in a list format that specifically address multiple safety issues and are intended to minimize or eliminate accidents and injuries in the workplace. Safety rules may be in any form that a company desires, and must be readily available to and understood by employees in the workplace.

Scheduled Maintenance A system of periodic maintenance of or service to equipment intended to preserve or restore reliability of operation and prevent equipment failure. Scheduled maintenance activities are generally applied based on some interval of time: hours of operation, daily, weekly monthly, etc. Scheduled maintenance could include but is not limited to: tests, measurements, adjustments, lubrication or parts replacement. Scheduled maintenance could occur as reactive maintenance rather than planned maintenance should indicators develop requiring unplanned maintenance to correct the defect identified by the indicator factor; e.g., add water as a result of a low day/expansion tank level alarm. Simple Easy to understand, deal with, use, etc., presenting no difficulty. Systematically Given to or using a system or method; in a methodical way Understood by Employees For a policy or procedure to be “understood by employees” means that employees interviewed had a basic familiarity with the policy/procedure and the overall concept(s), if not all of the details of the document, procedure or process. Employees with a basic understanding should be able to apply a majority of the elements of the concept in the workplace. Well Documented To be well documented means a policy and/or procedure must be in written form and be widely disseminated so as to be readily available to employees in the workplace. Western Rivers Western Rivers means the Mississippi River, its tributaries, South Pass, and Southwest Pass, to the navigational demarcation lines dividing the high seas from harbors, rivers, and other inland waters of the United States, and the Port Allen-Morgan City Alternate Route, and that part of the Atchafalaya River above its junction with the Port


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Allen-Morgan City Alternate Route including the Old River and the Red River. (33 CFR 83.03


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SECTION 2 – SAFETY POLICY AND PROGRAM TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

Safety Policy

2.1 Does a written company safety policy exist? (RCP II-C-1)

The company must have a written safety policy. For a compliant answer, the written safety policy must satisfy the RCP definition for a written policy and must include one or more written policy statements that outline the company’s expectations regarding employee safety.

2.1.1(a) Does the safety policy include employee accountability? (RCP II-C-1a)

The company’s written safety policy must include employee accountability to safety. For a written safety policy to be compliant in this regard, it must include a written statement that outlines the company’s expectations regarding employee accountability to safety.

It is up to the company to determine what their definition of “employee accountability” is.

2.1.1(b) Does the safety policy include employees’ commitment to safety? (RCP II-C-1a)

The company’s written safety policy must include language which addresses company employees’ commitment to safety. For a written safety policy to be compliant in this regard, it must include a written statement that outlines the company’s expectations regarding its employees’ commitment to safety.

2.2 Is the company’s safety policy well documented? (RCP II)

The company’s written safety policy must be in written form and be widely disseminated so as to be readily available to employees in the workplace.

The auditor should verify if the policy on the boat is the current version and verify against the policy in the manual.

Safety Program

2.3 Does a written safety program exist within the company? (RCP II-C-2)

For a compliant answer, the written safety program must satisfy the RCP definition for a written program.


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? # Question RCP Expectation Additional Information

2.3.1

Does the written safety program include painting in enclosed spaces? (RCP II-C-2a)

This question does not apply to a company if none of the company’s employees engage in painting operations within enclosed spaces in their workplace. For a company that has employees who conduct painting activities within enclosed spaces, the company’s safety program must include written procedures that describe the company’s expectations for safely conducting painting operations which are being conducted within enclosed spaces. Each company has the responsibility to determine the extent of their level of compliance. These procedures must also satisfy the RCP definition for a written procedure. “Enclosed spaces” here refers to not ventilated or exposed to the outside, for painting purposes only.

For companies with employees that have an occupational exposure to the hazards of painting within enclosed spaces, some guidance for these activities as may affect general industry applications may be found in 29 CFR 1910.94 and 29 CFR 1910.107. For activities which may affect shipbuilding, shipbreaking and marine repair or marine terminal applications, guidance may be found in 29 CFR 1915.35 and 29 CFR 1917.153. Marine construction activities may find guidance in 29 CFR 1926.57. Additional guidance may also be found in other standards located in 29 CFR.

2.3.2

Does the written safety program include non-skid surfaces on motor vessels? (RCP II-C-2b)

The company’s written safety program must include written procedure(s) to require non-skid surfaces on motor vessels, or utilize a documented process that addresses non-skid surfaces on motor vessels. In addition to requiring non-skid protection, the written procedure may also address installation and maintenance of non-skid protection which should be applied at exterior doorways, the top and bottom of exterior stairways and ladders, on designated walkways, and work areas around the exterior of the towing vessel, and where deemed necessary by the company, within the interior of the vessel.

The auditor should expect to find a vessel inspection report that would contain records from crewmember inspections of the walking surfaces and adequacy of the non-skid on those walking surfaces.

2.3.3

Does the written safety program include flammable and combustible liquids? (RCP II-C-2c)

The company’s safety program must include written procedures which address safe handling and storage of flammable and combustible liquids, or utilize a documented process that addresses safe handling and storage of flammable and combustible liquids on motor vessels.

Additional guidance regarding use and storage of flammable liquids may be found in 29 CFR 1910.106, 29 CFR Parts 1915, 1917 and 1926. Other resources such as 33 CFR Parts 154, 155 & 156, and NFPA Standards, etc., may also contain guidance to help address these items.


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2.4 Does the company’s written safety program include written safety rules? (RCP II-C-2)

For a compliant answer to this question, the company’s safety program must include a list of written safety rules which satisfy the RCP definition for written safety rules. The written safety rules may be in any form, such as contained within a written policy or procedure specifically for the purpose of documenting the company’s safety rules, displayed on a poster that is located at various locations throughout the workplace, or contained in a separate publication such as a booklet of the company’s safety rules. Other methods of providing written rules addressing safe operations by a company may also be considered as meeting this intent.

2.5 Do the written safety rules include:

2.5.1

If applicable, do the company’s written safety rules address painting in enclosed spaces? (RCP II-C-2a)

This question does not apply to a company if none of the company’s employees engage in painting operations in enclosed spaces. For a company that has employees who conduct painting activities within enclosed spaces, the company’s written safety rules must include individual rules that address the company’s expectations for safely conducting painting operations which are conducted within enclosed spaces. Each company has the responsibility to determine the make-up of their safety rules. These written safety rules must also satisfy the RCP definition for written safety rules.

Each company has the responsibility to determine the make-up of their safety rules. For companies with employees that have an occupational exposure to the hazards of spray painting within enclosed spaces, some guidance for these activities as affect general industry applications may be found in 29 CFR 1910.94 and 29 CFR 1910.107. For activities which may affect shipbuilding, shipbreaking and marine repair or marine terminal applications, guidance may be found in 29 CFR 1915.35 and 29 CFR 1917.153. Marine construction activities may find guidance in 29 CFR 1926.57. Additional guidance may also be found in other standards located in 29 CFR.

2.5.2

Do the company’s written safety rules include use and condition of non-skid surfaces on motor vessels? (RCP II-C-2b)

The company’s written safety program must include written safety rules which address the use and condition of non-skid surfaces on motor vessels.


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2.5.3

Do the company’s written safety rules include use and storage of flammable and combustible liquids? (RCP II-C-2c)

The company’s written safety program must include written safety rules which address use and storage of flammable and combustible liquids.

Additional guidance regarding use and storage of flammable liquids may be found in 29 CFR 1910.106, 29 CFR Parts 1915, 1917 and 1926. Other resources such as 33 CFR Parts 154, 155 & 156, and NFPA Standards, etc., may also contain guidance to help address these items.

2.6

Is there a written safety manual, or is the safety manual a subset of the SMS? (RCP II-C-1)

Companies must have either a written safety manual or the safety manual must be a subset of the SMS.

Most companies have either a separate written safety manual, a separate set of written safety policies and procedures that are contained within its written safety management system, or some combination of these two options, as follows. Some companies have a separate written safety manual that includes all of the company’s safety policies and procedures and no additional documents. Some companies have a safety management system manual that contains a separate set of written policies and procedures that include the elements of its safety program, but does not have a separate document designated as a safety manual. Some companies have a separate safety manual that intentionally includes only a portion of the policies and procedures which make up its overall safety program, and the remaining elements of the program are contained within the safety management system. Other combinations are possible, as the company is responsible for how it addresses these items.

2.6.1 Is the safety manual easily available to any employee? (RCP II)

The company’s safety manual must be easily available to any employee and available in a location that is always accessible to the employee.


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2.6.2 (a) Does the safety manual/safety program reflect current practices? (RCP II) (RCP II-A-3)

The company’s safety manual/safety program must appear to the auditor to reflect current practices. In some cases, a company’s safety manual/safety program may reflect the current practices the company intends for its employees to follow and should be updated in accordance with the company’s continuous improvement process. In other cases, a company’s safety manual/safety program may reflect current towing industry best practices and should appear to have been updated in accordance with the company’s continuous improvement process. Other combinations are possible, as the company is responsible for how it addresses these items.

2.6.2 (b) Does the safety manual/safety program reflect current technology? (RCP II-A-3)

The company’s safety manual/safety program must specify in writing how the safety manual/safety program reflects current technology. The company is responsible for determining what “current technology” means as it relates their program. In some cases a company may address this issue by keeping the information in a location where it is readily available to employees in either a paper or electronic format. Other companies may address this issue by having policies and procedures that address the safe use of electronic technology in the workplace and/or how to implement specific technologies. Other combinations are possible, as the company is responsible for how it addresses items.


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2.6.3 What is the date of the last revision to the safety manual/safety program? (RCP II-A-3)

The company must keep track of changes to the safety manual/safety program and be able to provide the date of the most recent revision to the safety manual/safety program during an audit. If the safety manual/safety program has not been updated since the last RCP management audit, the company should expect to be asked to provide an explanation of the situation and their intentions regarding future updates to the auditor.

2.7 Personal Protective Equipment

2.7.1 Does the safety program include one or more personal protective equipment (PPE) policies or procedures which satisfy the RCP definition for a written policy, or one or more written procedures? (RCP II-C-3)

For a compliant answer, the company’s safety program must include one or more written personal protective equipment policies or procedures and satisfy the RCP definition for a written policy/procedure.

Additional information regarding use of personal protective equipment may be found in 29 CFR 1910.Subpart “I” or 29 CFR 1915 Subpart “I”, and 46 CFR Parts 25 and 160. See also, the RCP policy regarding compliance with OSHA standards.

2.7.2 (a) Does the company’s personal protective equipment policy (procedure) include respiratory protection? (RCP II-C-3a)

For a compliant answer, the company’s personal protective equipment policy or procedure must include respiratory protection against exposure to safety or health hazards affecting their respiratory system.

One place where additional information regarding respiratory protection may be found is in 29 CFR 1910.134.

2.7.2 (b) Does the company’s personal protective equipment policy or procedure include fall arrest protection? (RCP II-C-3a)

For a compliant answer, the company’s personal protective equipment policy or procedure must include fall arrest protection and must ensure that employees who are exposed to falls from height are protected by fall arrest protection in accordance with the company’s written PPE policy or procedure(s).

Additional information regarding fall protection in general and fall arrest protection specifically may be found in 29 CFR 1926.500 - 503, and 29 CFR 1918.2.


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2.7.3 Does the company’s personal protective equipment policy or procedure include: use, inspection, maintenance and replacement of PPE? (RCP II-C-3a,b,c,&d)

For a compliant answer, the company’s personal protective equipment policy or policies and/or procedure(s) must include use, inspection, maintenance and replacement of PPE.

Additional information regarding use of personal protective equipment may be found in 29 CFR 1910.Subpart “I” or 29 CFR 1915 Subpart “I”, and 46 CFR Parts 25 and 160. See also, the RCP policy regarding compliance with OSHA standards.

2.7.4 Does the company require critical PPE for employees (e.g. PFDs, hard hats, eye protection, respirators & gloves) appropriate to the job each person is performing? (RCP II-A-1c) (RCP II-C-3)

The company’s safety program must include personal protective equipment policies/procedures to address: PFDs, hard hats, eye protection, respirators & gloves. Each company may choose to supply additional items of PPE according to their own needs and the requirements of their written safety program.

Additional information regarding use of personal protective equipment may be found in 29 CFR 1910.Subpart “I” or 29 CFR 1915 Subpart “I”. See also, the RCP policy regarding compliance with OSHA standards.

2.8 Does the safety program address reporting of safety deficiencies and/or nonconformities? (RCP II-C-4)

For a compliant answer, the company’s safety program must address reporting of safety deficiencies and/or nonconformities. Typically, these items are addressed in either written procedures or in a documented process.

The auditor should ask how deficiencies are reported. The auditor should verify if management personnel can locate the deficiency reporting (or similar) procedure and verify the presence of reported safety deficiencies. It is possible this might not be located within the safety program but within deficiency reporting.

2.8.1 Does the safety program address the use of a corrective action process? (RCP II-B-8)

For a compliant answer, the company’s safety program must address the use of a corrective action process. Typically, these items are addressed in either one or more written procedures or in a documented process.


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2.9 Does the safety program address confined space entry? (RCP II-C-5)

For a compliant answer, if the company expects or allows employees to enter confined or enclosed spaces, the company’s safety program must address confined space entry and must have one or more written procedures to describe the company’s expectations for employees who are required to enter confined (or enclosed) spaces in the workplace. Companies that explicitly prohibit their employees from entering confined (or enclosed) spaces must have a written policy expressing this.

Additional information regarding confined or enclosed space entry may be found in 29 CFR 1910.146 and 29 CFR 1915 Subpart “B”. See also, the RCP policy regarding compliance with OSHA standards.

2.10 Safe Use Of Equipment:

2.10.1 Does the safety program address the safe use of deck machinery? (RCP II-C-7-a)

For a compliant answer, the company’s safety program must address the safe use of deck machinery and must have one or more written procedures to describe the company’s expectations for employees who are working around or working with deck machinery.

Additional information regarding machinery guarding may be found in 29 CFR 1910 Subpart “O”. See also, the RCP policy regarding compliance with OSHA standards.

2.10.1.1 Do written procedures address the safe use of capstans? (RCP II-C-7-a)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, addressing the safe use of capstans.

The procedure(s) could include safety precautions when working with capstans, where installed.

2.10.1.2 Do written procedures address the safe use of winches? (RCP II-C-7-a)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, addressing the safe use of winches.

The procedure(s) could include safety precautions when working with powered and manual winches, where installed.

2.10.2 Does the safety program address the safe use of rigging? (RCP II-C-7-b) (RCP III-E-1)

For a compliant answer, the company’s safety program must address the safe use of barge and boat rigging and must have one or more written procedures to describe the company’s expectations for employees who are working around or working with rigging. For inland vessels, the company’s safety program must also address the safe use of all of the following elements of rigging and equipment: wires, ropes, chains, shackles, ratchets, winches. The company must have written procedures which specifically address the safe use of each of these items.


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2.10.3 Does the safety program address the safe use of welding and/or cutting equipment? (RCP II-C-7-c)

For a compliant answer, the company’s safety program must address the safe use of welding and/or cutting equipment and must have one or more written procedures to describe the company’s expectations for employees who are working around or working with welding and/or cutting equipment.

Additional information regarding safe use of abrasive wheel machinery may be found in 29 CFR 1910.251, 252, 253, 254 & 255 and 29 CFR 1915 Subpart “D”. See also, the RCP policy regarding compliance with OSHA standards.

2.10.4 Does the safety program address the safe use of hand tools? (RCP II-C-7-d)

For a compliant answer, the company’s safety program must address the safe use of hand tools and must have one or more written procedures to describe the company’s expectations for employees who are working around or working with hand tools.

Additional information regarding safe use of powered hand tools may be found in 29 CFR 1910.243 & 244. See also, the RCP policy regarding compliance with OSHA standards.

2.10.5 Does the safety program address the safe use of portable ladders? (RCP II-C-7-e)

For a compliant answer, the company’s safety program must address the safe use of portable ladders and must have one or more written procedures to describe the company’s expectations for employees who are working around or working with portable ladders.

Additional information regarding safe use of portable ladders may be found in 29 CFR 1910.25 & 26. See also, the RCP policy regarding compliance with OSHA standards.

2.10.6 Does the safety program address the safe use of abrasive wheel machinery? (RCP II-C-7-f)

For a compliant answer, the company’s safety program must address the safe use of abrasive wheel machinery and must have one or more written procedures to describe the company’s expectations for employees who are working around or working with abrasive wheel machinery.

Additional information regarding safe use of abrasive wheel machinery may be found in 29 CFR 1910.215 & 1910.243. See also, the RCP policy regarding compliance with OSHA standards.

2.11 Does the safety program address cargo knowledge? (RCP II-C-8)

For a compliant answer, the company’s safety program must address cargo knowledge and must have one or more written procedures to describe the company’s expectations for employees who are working around or working with cargoes that may be hazardous to the employees or the environment, or that might require special knowledge or special handling.

Additional information regarding cargo knowledge may be found in 33 CFR Parts 154, 155, & 156; 46 CFR numerous parts; and 29 CFR 1910.1200. See also, the RCP policy regarding compliance with OSHA standards.

2.12 Does the safety program address hazard communication procedures? (Right to Know) (RCP II-C-9) (29 CFR 1910.1200)

For a compliant answer, the company’s safety program must provide written hazard communication procedures and must comply with applicable requirements of 29 CFR 1910.1200.


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2.13 Does the safety program address blood borne pathogens? (RCP II-C-10)

For a compliant answer, the company’s safety program must address blood borne pathogens and have one or more written procedures to describe the company’s expectations for employees who might come in contact with blood borne pathogens.

Additional information regarding blood borne pathogens may be found in 29 CFR 1910.1030. See also, the RCP policy regarding compliance with OSHA standards.

2.14 Does the safety program include a benzene handling policy or procedure? (RCP II-B-9a)

For a compliant answer, the company’s safety program must provide a benzene handling policy or procedure for towing vessel employees if one or more of the company’s towing vessels handles benzene and must have one or more written procedures to describe the company’s expectations for employees who are handling, working around or working with benzene.

Additional information regarding benzene handling may be found in 46 CFR 30.25-3 and 46 CFR Part 197.

2.15 Does the safety program address fall overboard prevention? (RCP II-C-11)

For a compliant answer, the company’s safety program must address fall overboard prevention and must have one or more written procedures to describe the company’s expectations for employees who are working around or over the water where there is an exposure to falling overboard.

See also Lesson Plans concerning fall overboard prevention that were developed by the AWO Safety Committees.

2.16 Does the safety program address hearing conservation? (RCP II-C-1b)

For a compliant answer, the company’s safety program must address hearing conservation and must have one or more written procedures to describe the company’s expectations for employees who are working in and around high noise areas or working with noisy tools and equipment.

Additional information regarding hearing conservation may be found in 29 CFR 1910.95. See also, the RCP policy regarding compliance with OSHA standards.

2.17 Safety Training, Safety Drills and Safety Meeting (Including Station Bill) (RCP II-C-6):

2.17.1 Does the safety program include regular safety training? (RCP II-C-6b)

For a compliant answer, the company’s safety program must include regular safety training. Regular safety training is defined in the RCP as being initial training (training that occurs after a new employee is hired or at the initial implementation of the program as determined by the company), and refresher training that must occur at least once every five years. The company should utilize one or more written procedures or a documented process to manage its safety training.

NOTE: (46 CFR 27.209) USCG requires that each crewmember must participate in monthly firefighting drills and receive firefighting training that is to be conducted at least once each month. Crewmembers who are not regular employees of the same towing vessel who join the vessel after the firefighting drills and training have taken place must receive a safety orientation as prescribed by 46 CFR 27.209.


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2.17.2 Does the safety program include regular safety drills? (RCP II-C-6b)

For a compliant answer, the company’s safety program must include regular safety drills. Regular safety drills must be accomplished at least once each quarter. The company should utilize one or more written procedures or a documented process to manage its safety drills.

NOTE: (46 CFR 27.209) USCG requires that each crewmember must participate in monthly firefighting drills and receive firefighting training that is to be conducted at least once each month. Crewmembers who are not regular employees of the same towing vessel who join the vessel after the firefighting drills and training have taken place must receive a safety orientation as prescribed by 46 CFR 27.209.

2.17.3 Does the safety program include regular safety meetings? (RCP II-C-6b)

For a compliant answer, the company’s safety program must include regular safety meetings. Regular safety meetings should be held at least once each quarter. The company should utilize one or more written procedures or a documented process to manage its safety meetings.

The auditor should verify the safety meeting program is in place and documented. If safety meeting minutes are required to be submitted, the auditor should verify this is occurring.

2.17.4 Does the safety program include use of towing vessel station bills? (RCP II-C-6)

For a compliant answer the company’s safety program must include the use of towing vessel station bills. The RCP does not specify a format for station bills; the company is expected to use its own discretion. (The company should be providing written station bills on all of its towing vessels.)

2.17.5 Does the safety program include safety drills to cover critical components such as: (see below) (RCP II-C-6a)

2.17.5 (a) Does the safety program include safety drills to cover first aid/CPR? (RCP II-C-6a)

For a compliant answer, the company’s safety program must include safety drills to cover first aid/CPR. The company should utilize a written procedure or a documented process to manage its safety drills. Safety drills must meet the definition for Emergency Response Drills.


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2.17.5 (b) Does the safety program include safety drills to cover marine firefighting for towing vessel crewmembers? (RCP II-C-6a) & (Addendum C - Audit Issues, Item 14 of RCP 2016)

This element of the RCP requires masters, mates (pilots), engineers and tankermen to participate in periodic safety drills for firefighting which includes emergency response to fires onboard a towing vessel and following the company’s emergency response procedure for fighting fires onboard a towing vessel. The company should utilize one or more written procedures or a documented process to manage its safety drills. Safety drills must meet the definition for Emergency Response Drills.

This requirement is explained in detail in item 14 of Addendum C to the RCP which addresses “Audit Issues.” NOTE: (46 CFR 27.209) USCG requires that each crewmember must participate in monthly firefighting drills and receive firefighting training that is to be conducted at least once each month. Crewmembers who are not regular employees of the same towing vessel who join the vessel after the firefighting drills and training have taken place must receive a safety orientation as prescribed by 46 CFR 27.209. This orientation is for a crewmember who is new to the vessel.

2.17.5 (c) Does the safety program require a safety orientation be provided to a crew member who has not participated in a fire drill and instruction within 24 hours of reporting for duty, covering the contingencies listed in 46 CFR 27.209(a)? (46 CFR 27.209 (d) & (e)

A safety orientation must be provided to each crew member who has not participated in the required drills and received the required instruction within 24 hours of reporting for duty, covering the contingencies listed in 46 CFR 27.209(a). The company must utilize one or more written procedures or a documented process to manage the safety orientation process for crewmembers.

The company must have arrangements for conducting safety orientations for crewmembers who join a vessel after the monthly drills and training have occurred and records should be available to confirm that required supplemental training was completed as required. The supplemental training is for a crewmember who is new to the vessel.

2.17.5 (d) Does the safety program address safety drills to cover emergency boat operation? (RCP II-C-6a)

Emergency boat operation is defined as: “operation of any type of small boat such as a skiff, yawl, or motorboat that may be carried onboard a towing vessel and may be used during an emergency response to an incident such as a man over board or other emergency situation as appropriate.” The company should utilize a written procedure or a documented process to manage its safety drills. Safety drills must meet the definition for Emergency Response Drills.


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2.17.5 (e)

If applicable to this company’s operations, does the safety program include safety drills to cover use of life rafts? (RCP II-C-6a)

If USCG regulations require the company to provide life rafts on any of its towing vessels or if the company chooses to use life rafts on any of its towing vessels even though life rafts are not required by the USCG, the company must conduct safety drills to cover the use of life rafts. Safety training must meet the definition for RCP required training. The company should utilize a written procedure or a documented process to manage its safety training. Safety drills must meet the definition for Emergency Response Drills. If USCG regulations do not require the company to use life rafts on any of its towing vessels and the company does not otherwise provide life rafts for any of its towing vessels, this question is not applicable to that company.

2.17.5 (f)

If applicable to this company’s operations, does the safety program include safety drills to cover use of survival suits? (RCP II-C-6a)

If USCG regulations require the company to provide survival suits on any of its towing vessels or if the company chooses to provide survival suits on any of its towing vessels even though survival suits are not required by the USCG, the company must conduct safety drills to cover the use of survival suits. The company should utilize a written procedure or a documented process to manage its safety training. Safety drills must meet the definition for Emergency Response Drills. If USCG regulations do not require the company to provide survival suits on any of its towing vessels and the company does not otherwise provide survival suits for any of its towing vessels, this question is not applicable to that company.


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2.17.6 Does the safety program include safety training to cover critical components such as: (see below) (RCP II-C-6a)

2.17.6 (a) Does the written safety program include safety training to cover first aid/CPR? (RCP II-C-6a)

For a compliant answer, the company’s written safety program must include safety training to cover first aid/CPR. The company should utilize one or more written procedures or a documented process to manage its safety training. This required training must meet the definition for RCP required training and the definition for emergency response training.

The American Red Cross offers both first Aid and CPR courses that result in the employee receiving a wallet sized card certifying them as having completed the requirements for First Aid / CPR as appropriate. The American Heart Association also conducts similar courses through its HeartQuarters Training program designed specifically to address an individual company’s requirements for First Aid, CPR and AED training.

2.17.6 (b) Does the safety program include safety training to cover (marine) firefighting for masters, mates (pilots), engineers and tankermen? (RCP II-C-6a) & (Addendum C - Audit Issues, Item 14 of RCP 2016)

According to Addendum “C” of the RCP manual, the company’s safety program must provide training to masters, mates (pilots), engineers, and tankermen to address marine firefighting and fire prevention. It should be noted that the difference between marine firefighting and vessel firefighting is chiefly one of focus. Marine firefighting is broader, it includes greater detail and focuses on the overall firefighting response. These are skills that are essential for individuals in supervisory positions who will direct the firefighting effort. Subjects should include theory (of fire), firefighting tactics, and overarching issues such as vessel stability, personnel safety, and emergency communications. This difference recognizes the role that each of the above listed crewmembers must fulfill in the event of an actual emergency. Fire prevention training is required for all positions. This training can be as simple as proper storage of flammable materials, eliminating sources of ignition, and good housekeeping, especially in the galley and engine room. The company should utilize one or more written procedures or a documented process to manage its safety training. This required training must meet the definition for RCP required training and the definition for emergency response training.

This requirement is explained in detail in item 14 of Addendum C to the RCP which addresses “Audit Issues.” Here is a direct quote from the AWO RCP booklet: “...Using these broad guidelines, it is up to the company to determine the content of the training.” NOTE: (46 CFR 27.209) USCG requires that each crewmember must participate in monthly firefighting drills and receive firefighting training that is to be conducted at least once each month. Crewmembers who are not regular employees of the same towing vessel who join the vessel after the firefighting drills and training have taken place must receive a safety orientation as prescribed by 46 CFR 27.209.


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2.17.6 (c) Does the safety program include safety training to cover (marine) firefighting for towing vessel deck crews? (RCP II-C-6a) & (Addendum C - Audit Issues, Item 14 of RCP 2016)

According to Addendum “C” of the RCP, the company’s safety program must provide training to deck crew members to cover “vessel firefighting and fire prevention which should concentrate to a large degree on hands-on firefighting techniques, skills that will be necessary for the individuals who will have the primary responsibility for the actual fighting of the fire and on fire prevention.” “Fire prevention training is required for all positions. This training can be as simple as proper storage of flammable materials, eliminating sources of ignition, and good housekeeping, especially in the galley and engine room.” The company should utilize a written procedure or a documented process to manage its safety training. This required training must meet the definition for RCP required training and the definition for emergency response training.

This requirement is explained in detail in item 14 of Addendum C to the RCP which addresses “Audit Issues.” Here is a direct quote from the AWO RCP booklet: “...Using these broad guidelines, it is up to the company to determine the content of the training.” NOTE: (46 CFR 27.209) USCG requires that each crewmember must participate in monthly firefighting drills and receive firefighting training that is to be conducted at least once each month. Crewmembers who are not regular employees of the same towing vessel who join the vessel after the firefighting drills and training have taken place must receive a safety orientation as prescribed by 46 CFR 27.209.

2.17.6 (d) Does the safety program include safety training to cover emergency boat operation? (RCP II-C-6a)

Emergency boat operation is defined as: “operation of any type of small boat such as a skiff, yawl, or motorboat that may be carried onboard a towing vessel and may be used during an emergency response to an incident such as a man over board or other emergency situation as appropriate.” The company should utilize a written procedure or a documented process to manage its safety training. This required training must meet the definition for RCP required training and the definition for emergency response training.


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2.17.6 (e) If applicable to this company’s operations, does the safety program include safety training to cover the safe use of life rafts? (RCP II-C-6a)

For a compliant answer, the company’s written safety program must include safety training to cover the safe use of life rafts. The company should utilize a written procedure or a documented process to manage its safety training. Safety training must meet the definition for RCP required training. If USCG regulations require the company to provide life rafts on any of its towing vessels or if the company chooses to use life rafts on any of its towing vessels even though life rafts are not required by the USCG, the company must conduct safety training to cover the safe use of life rafts. If USCG regulations do not require the company to use life rafts on any of its towing vessels and the company does not otherwise provide life rafts for any of its towing vessels, this question is not applicable to that company. This required training must meet the definition for RCP required training and the definition for emergency response training.

2.17.6 (f) If applicable to this company’s operations, does the safety program include safety training to cover the safe use of survival suits? (RCP II-C-6a)

For a compliant answer, the company’s written safety program must include safety training to cover the safe use of survival suits. The company should utilize a written procedure or a documented process to manage its safety training. Safety training must meet the definition for RCP required training. If USCG regulations require the company to provide survival suits on any of its towing vessels or if the company chooses to use survival suits on any of its towing vessels even though survival suits are not required by the USCG, the company must conduct safety training to cover the use of survival suits. If USCG regulations do not require the company to use survival suits on any of its towing vessels and the company does not otherwise provide survival suits for any of its towing vessels, this question is not applicable to that company. This required training must meet the definition for RCP required training and the definition for emergency response training.


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2.17.7 Are there written records available to demonstrate the company’s compliance with its established policy regarding the frequency of safety meetings held for crewmembers employed onboard towing vessels? (RCP II) (RCP II-C-6b)

The company must comply with their established policy regarding the frequency of safety meetings held for crewmembers employed onboard towing vessels. There must be completed safety meeting records and/or documentation that the company is holding safety meetings for crewmembers employed onboard its towing vessels in accordance with its written policy. If the company is not holding safety meetings at the frequency as designated by the company, the auditor will note the findings on the audit report.

2.17.8 Are there written records available to demonstrate the company’s compliance with its established policy regarding the frequency of safety training sessions held for crewmembers employed onboard towing vessels? (RCP II) (RCP II-C-6b)

The company must comply with their established policy regarding the frequency of safety training sessions held for crewmembers employed onboard towing vessels. There must be completed safety training session records and/or documentation that the company is holding safety training sessions for crewmembers employed onboard its towing vessels in accordance with its written policy. If the company is not holding safety training sessions at the same frequency as designated by the company, the auditor will note the findings on the audit report.

2.17.9 Are there written records available to demonstrate the company’s compliance with its established policy regarding the frequency of safety drill sessions held for crewmembers onboard towing vessels? (RCP II) (RCP II-C-6b)

The company must comply with their established policy regarding the frequency of safety drill sessions held for crewmembers employed onboard towing vessels. There must be completed safety drill session records and/or documentation that the company is holding safety drill sessions for crewmembers employed onboard its towing vessels in accordance with its written policy. If the company is not holding safety drill sessions at the same frequency as designated by the company, the auditor will note the findings on the audit report.


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SECTION 3 – SECURITY POLICY AND/OR PROCEDURES TVIB – RCP MANAGEMENT AUDIT WORKSHEET


3.1 Does the company operate in compliance with a USCG Approved Vessel Security Plan, a USCG Approved Alternative Security Program, or a RCP-required written security policy and/or procedures created by the company to cover towing vessels that are not required to comply with USCG security regulations? (RCP II-D)

The company must have a RCP-required written security policy and/or procedures if it is not already operating in accordance with a USCG Approved Vessel Security Plan or a USCG Approved Alternative Security Program. For a written security policy program to be compliant in this regard, the written security policy program must satisfy the RCP definition for a written policy and must include one or more written policy statements that outline the company’s expectations regarding maritime security.

Note: Questions in Section 3 are applicable to all towing vessels which are included in the RCP, regardless of whether or not they are being operated in compliance with either a USCG Approved Vessel Security Plan, a USCG Approved Alternative Security Program, or the company has created a RCP-required written security policy and/or procedures to cover towing vessels that are not required to comply with USCG security regulations. Please see question 3.2 to determine which series of the following questions apply to the towing vessel being audited. In some cases, a company may have towing vessels or facilities that are required to be operated in compliance with USCG MTSA regulations. A company may also have towing vessels that are not required to comply with security regulations. It is possible that a combination could exist where some of the towing vessels operate under USCG security regulations and other towing vessels do not, and thus the company may need to comply with multiple security plans, policies or programs.


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3.2 The company is operating in compliance with: (check all that apply) � A USCG Approved Facility Security Plan (33 CFR 105) � A USCG Approved Vessel Security Plan (33 CFR 104) � A USCG Approved Alternative Security Program (33 CFR 105.140) � A RCP-required written security policy and/or procedures covering towing vessels that are not required to comply with USCG

security regulations (in addition to or in place of a USCG Security Plan or Program) The auditor must answer each of the question sets below that pertain to the type(s) of security policy/procedures and/or plan the company is operating in compliance with.

3.3 The following set of questions apply to those companies operating in compliance with a USCG Approved Security Plan:

3.3 (a) Does the company have a document from the USCG stating the plan is approved? (RCP II-D)

For a compliant answer, a company that is operating under a USCG Approved Security Plan must have a document from the Coast Guard stating the plan is approved.

The auditor should look for (1) a letter of approval from the Coast Guard that is less than 5 years old; and (2) a letter from the Coast Guard with a list of vessels operating under the approved security plan identified by the Coast Guard. The list of approvals, at this time, is received from the Coast Guard Marine Safety Center (MSC).

3.3 (b) Does the company have evidence to show that the Security Plan has been audited annually? (RCP II-D)

A company operating in compliance with a USCG Approved Security Plan must have evidence to show that the Security Plan has been audited annually.

The company’s security officer must provide evidence of the Security Plan audit, regardless of whether it was done internally or by a third party. The auditor should look for letter of audit, signed by the CSO or VSO, certifying that the audit was completed as documented.

3.4 The following set of questions apply to those companies operating in compliance with a USCG Approved Alternative Security Program:


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3.4 (a) Does the company have the letter to the Coast Guard signed by the vessel owner or operator that the towing vessel is using the approved ASP and that the vessel is in full compliance with the ASP? (RCP II-D)

For a compliant answer, a company that is operating under a USCG Approved Alternative Security Program must have sent a letter to the Coast Guard, signed by the vessel owner or operator, that the towing vessel is using the approved ASP and that the vessel is in full compliance with the ASP.

The auditor may request to see a document from the USCG acknowledging that the company is operating in compliance with an approved ASP, in response to the letter the company sent to the Coast Guard. If the letter is not available or not found, check any recent vessel security update acceptance letter from MSC, it will have a USCG case number which indicates the company has sent the required letter. Additionally, the company must have a letter from the USCG MSC showing the list of vessels covered under the security plan.

3.4 (b) Does the company have evidence to show that the ASP has been audited annually? (RCP II-D)

The company must provide evidence that the ASP has been audited annually.

The company’s security officer must provide evidence of the Security Plan audit, regardless of whether it was done internally or by a third party. The auditor should look for letter of audit, signed by the CSO or VSO, certifying that the audit was completed as documented.

3.5 The following set of questions apply to those companies operating in compliance with a RCP-required written security policy and/or procedures:

3.5 (a) Is the company’s RCP-required written security policy and/or procedures clearly stated and capable of being easily understood by employees? (RCP II-D)

The company’s RCP-required written security policy and/or procedures must be clearly stated and should be capable of being easily understood by employees.

3.5 (b) Is the company’s RCP-required written security policy and/or procedures well documented? (RCP II)

The company’s RCP-required written security policy and/or procedures must appear to the auditor to be well documented and be widely disseminated so as to be available to all employees.


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3.5 (c) Is the company’s RCP-required written security policy and/or procedures well known and understood by employees? (RCP II)

The company’s RCP-required written security policy and/or procedures must appear to the auditor to be well known by employees that are available during the management audit.

3.6 Does the RCP-required written security policy and/or procedures program include: (see the following items)

3.6.1 (a) Does the RCP-required written security policy and/or procedures program include periodic security training? (RCP II-D)

The company’s RCP-required written security policy and/or procedures program must include periodic security training., or the company could be using either a USCG Approved Security Plan or a USCG Approved Alternative Security Program to satisfy this requirement.

3.6.1 (b) Are there written records available to demonstrate compliance with the policy and or procedures program in 3.6.1 (a)? (RCP II)

There must be completed periodic security training records that demonstrate compliance with the company’s written security policy and/or procedures program.

3.6.2 (a) Does the RCP-required written security policy and/or procedures program include periodic security drills? (RCP II-D)

The company’s RCP-required written security policy and/or procedures program must include periodic security drills. or the company could be operating in compliance with either a USCG Approved Security Plan or a USCG Approved Alternative Security Program to satisfy this requirement.

3.6.2 (b) Are there written records available to demonstrate compliance with the policy and/or procedures program in 3.6.2 (a)? (RCP II)

There must be completed periodic security drills records that demonstrate compliance with the company’s written security policy and/or procedures program.

3.6.1

3.6.3

Does the RCP-required written security policy and/or procedures include emergency communications? (RCP II-D)

The company’s RCP-required written security policy and/or procedures must include emergency communications.


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3.6.2

3.6.4

Does the RCP-required written security policy and/or procedures include emergency notification? (RCP II-D)

The company’s RCP-required written security policy and/or procedures must include emergency notification.

3.6.3

3.6.5

Does the RCP-required written security policy and/or procedures include compliance with official instructions? (RCP II-D)

The company’s RCP-required written security policy and/or procedures must include compliance with official instructions.

In a security incident, the towing vessel crew members have to comply with instructions from law enforcement personnel.

3.6.4

3.6.6

Are employees familiar with MARSEC levels? (RCP II-D)

It must include the meaning of the MARSEC levels, and the company’s expectation for crew member response when MARSEC levels change.

3.6.5

3.6.7

Are employees familiar with specific activities that are required to be reported to the USCG? (RCP II-D)

Several resources are available to companies that are not required to comply with MTSA regulations, which can provide guidance for those companies to use. For more information regarding reporting suspicious activities to the USCG, please see COMDTINST 16618.8 dated 10 Feb 2005. See also http://americaswaterwaywatch.uscg.mil/home.html

3.6.6

3.6.8

Does the RCP-required written security policy and/or procedures include reporting of suspicious activities? (RCP II-D)

The company’s RCP-required written security policy and/or procedures must include reporting of suspicious activities. Several resources are available to companies that are not required to comply with MTSA regulations, which can provide guidance for those companies to use. For more information regarding reporting suspicious activities to the USCG, please see COMDTINST 16618.8 dated 10 Feb 2005. See also http://americaswaterwaywatch.uscg.mil/home.html.


4-1

SECTION 4 – ENVIRONMENTAL POLICY AND PROGRAM TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

4.1 Does a written company environmental policy or procedure exist? (RCP II-E-1)

The company must have a written company environmental policy or procedure which satisfies the RCP definition for a written policy or procedure

4.1.1

Is the written environmental policy or procedure well documented? (RCP II)

The company’s written environmental policy or procedure must appear to the auditor to be well documented and be widely disseminated so as to be available to all employees.

4.1.2 Is the written environmental policy or procedure well known and understood by employees? (ask several employees) (RCP II)

The company’s written environmental policy or procedure must appear to the auditor to be well known by employees that are available during the management audit.

4.2 The written environmental procedures must include the following elements:

4.2.1 Do these written environmental procedures include garbage disposal requirements and documentation? (RCP II-E-2)

The company’s written environmental procedures must include vessel garbage disposal requirements and documentation.

Garbage Management Plans are only required by the Coast Guard for manned oceangoing vessels of 40 feet or more in length, that are documented under the laws of the U.S. or numbered by a state, and that are either engaged in commerce or equipped with a galley and berthing. See 33 CFR 151.57 for applicability.

4.2.2 If applicable, do these written environmental procedures include maintaining a garbage log? (RCP II-E-2)

If the company has ocean-going vessels larger than 400 GT, the company’s written environmental procedures must include a Coast Guard requirement for the vessel to maintain a garbage log. Otherwise, the company may determine how they comply with this requirement.

See 33 CFR 151. 63 for requirements for shipboard control of garbage.


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4.2.3 Do these written environmental procedures include handling of waste oil, oily bilge slops, and used filters? (RCP II-E-3)

The company’s written environmental procedures must include specific procedures for handling of waste oil, oily bilge slops, and used filters.

4.2.4 Do these written environmental procedures include hazardous waste disposal and handling? (RCP II-E-4)

The company’s written environmental procedures must include hazardous waste disposal and handling.

4.2.5 Do these written environmental procedures include sanitary systems and handling of sewage? (RCP II-E-5)

The company’s written environmental procedures must include sanitary systems and handling of sewage.

4.2.6 Do these written environmental procedures include universal waste disposal? (40 CFR 273.13)

The company’s written environmental procedures must include universal waste disposal.

Universal waste means any of the following hazardous wastes that are subject to the universal waste requirements of 40 CFR part 273, including includes certain types of batteries, fluorescent lighting/lamps, mercury-containing equipment (eg. mercury switches and thermostats) and pesticides.

4.3 If applicable, does the company have written procedures and/or forms to assist in the efforts of the vessel to comply with the Vessel General Permit? (VGP Section 4.1 pg 64)

Applicable for vessels over 79 feet in length. The company must have written procedures and/or forms to assist in the efforts of the vessel to comply with the Vessel General Permit.

Refer to VGP Fact Sheet Section 6 pg 148 for additional information.

4.3.1 If applicable, does the company have written records to document the vessel’s compliance with their written VGP procedures and/or format? (VGP Section 4.1)

Applicable for vessels over 79 feet in length. The company must have written records to document the vessel’s compliance with their written VGP procedures and/or format.


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4.4 Where applicable, if the company operates vessels utilizing ballast water tanks, does the company have a written ballast water management policy for said vessel(s)? (33 CFR 151.2025; 33 CFR 151.2015)

A vessel utilizing ballast water tanks must employ one of the following ballast water management methods: (1) Install and operate a ballast water management system (BWMS) that has been approved by the Coast Guard under 46 CFR part 162; (2) use only water from a U.S. public water system as defined in 40 CFR 141.2, that meets the requirements of 40 CFR parts 141 and 143 as ballast water; (3) perform complete ballast water exchange in an area 200 nautical miles from any shore prior to discharging ballast water; (4) do not discharge ballast water into waters of the U.S., or (5) discharge to a facility onshore or to another vessel for purposes of treatment. See also additional information regarding exempt vessels.

Per 33 CFR 151.2015, the following vessels are exempt from the requirements of 33 CFR 151.2025: vessels that operate exclusively within one Captain of the Port (COTP) zone; seagoing vessels that operate in more than one COTP zone, do not operate outside of the Exclusive Economic Zone (EEZ), and are less than or equal to 1,600 gross register tons or less than or equal to 3,000 GT; non-seagoing vessels; and vessels that operate in more than one COTP zone and take on and discharge ballast water exclusively in one COTP zone.

4.4.1 Where applicable, does the company have written records that document a vessel’s compliance with the written ballast water management policy?

The company must have written records that document compliance with the written ballast water management policy.


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4.3

4.5

If the company has towing vessels that are burning residual fuel, are records (fuel receipts) available for review to verify compliance with the applicable requirements of MARPOL Annex VI (fuel must have less than 4.5% sulfur content)? (MARPOL Annex VI 49 CFR 94)

If the company has towing vessels that burn residual fuel, it must maintain records for review to verify compliance with the applicable requirements of MARPOL Annex VI (fuel must have less than 4.5% sulfur content).

Use checklist in App. A of Enc. 1 to CG-543 Policy Ltr 09-01 dtd 2/4/09 The EPA has published regulations in 49 CFR 94 to limit emissions from marine diesel engines manufactured on or after 1/1/2004 or vessels equipped with marine diesel engines constructed on or after that date, rated over 37 kilowatts (50 hp). The International Maritime Organization (IMO) adopted Annex VI on 9/27/1997 to limit air pollution from ships. It applies to UTV’s equipped with marine diesel engines rated over 130 kilowatts (175 hp). Annex VI establishes limits on Nitrogen Oxides (NOx) for new engines installed on a vessel constructed on or after 1/1/2000, and for existing engines that undergo a major conversion after that date. On 10/10/2008, IMO adopted Resolution MEPC. 176(58), which revised MARPOL Annex VI with an effective date of 7/1/2010.


5-1

SECTION 5 – COMPANY EMPLOYEES RESPONSIBILITIES AND AUTHORITIES TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

5.1 Are organizational levels well documented or defined in an organizational chart? (RCP II-I-1)

The company must have organizational levels in written form or defined in an organizational chart, and be widely disseminated so as to be readily available to employees in the workplace. At a minimum, the company must define position hierarchies of both shore-side and vessel positions.

5.1.1 Is the authority of all shoreside personnel well documented and defined? (RCP II-I-1)

The company must have the RCP-related authorities of all shoreside personnel in written form and be widely disseminated so as to be readily available to employees in the workplace.

5.1.2 Are the responsibilities of shoreside personnel well documented and defined? (RCP II-I-1)

The company must have the RCP-related responsibilities of all shoreside personnel in written form and be widely disseminated so as to be readily available to employees in the workplace. These may be defined in job descriptions, functional descriptions or any other format that achieves the requirement of “well documented and defined.”

5.2 Towing Vessel Master Authority and Responsibilities:

5.2.1 Does the company’s safety management system document the authority of the towing vessel master? (RCP II-I-1)

The company’s safety management system must document the master’s authority in written form and be widely disseminated so as to be readily available to employees in the workplace.

5.2.2 Does the company’s safety management system describe the general responsibilities of the towing vessel master? (RCP II-I-1)

The company’s safety management system must describe the master’s general responsibilities in written form and be widely disseminated so as to be readily available to employees in the workplace. These may be defined in job descriptions, functional descriptions or any other format that achieves the requirement of “well documented and defined.”


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5.2.3 Does the company’s safety management system clearly communicate that the master is responsible for the safety of the towing vessel? (RCP II-I-1a)

The company’s safety management system must clearly communicate that the master is responsible for the safety of the towing vessel.

5.2.4 Does the company’s safety management system clearly communicate that the master is responsible for adhering to the provisions of the Certificate of Inspection (COI), if issued? (RCP II-I-1a-1)

The company’s safety management system must clearly communicate that the master is responsible for ensuring the towing vessel is adhering to the provisions of the Certificate of Inspection.

This requirement will be implemented over the five year audit cycle and will not apply until the vessel has been issued a COI.

5.2.5 Does the company’s safety management system clearly communicate that the master is responsible for the vessel’s compliance with applicable regulations? (RCP II-I-1a-2)

The company’s safety management system must clearly communicate that the master is responsible for the vessel’s compliance with applicable regulations.

5.2.6 Does the company’s safety management system clearly communicate that the master is responsible for compliance with the safety management system applicable to the towing vessel? (RCP II-I-1a-3)

The company’s safety management system must clearly communicate that the master is responsible for compliance with the safety management system applicable to the towing vessel.


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5.2.7 Does the company’s safety management system clearly communicate that the master is responsible for reviewing the contents of the safety management system applicable to the towing vessel, and reporting non-conformities to shore based management? (RCP II-I-1a-4)

The company’s safety management system must clearly communicate that the master is responsible for both reviewing the contents of the safety management system applicable to the towing vessel and reporting non-conformities to shore based management. The company must outline the details of the reviews, including elements such as the frequency, scope and reporting requirements of non-conformities.

5.2.8 Does the company have written records to demonstrate that the master is reporting identified non-conformities to shore based management as required in 5.2.7? (RCP II)

The company must have written records to demonstrate that the master is reporting identified non-conformities to shore based management, if applicable.

There is not a requirement to have non-conformities, but rather a requirement to report identified non-conformities.

5.2.9 Does the company’s safety management system clearly communicate that the master is responsible for supervising all persons onboard in carrying out their assigned duties? (RCP II-I-1a-5)

The company’s safety management system must clearly communicate that the master is responsible for supervising all persons onboard in carrying out their assigned duties.


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5.2.10 Does the company’s safety management system clearly communicate that the master has the authority to determine if it is unsafe for the towing vessel to proceed? (RCP II-I-1b-1)

The company’s safety management system must clearly communicate that the master has the authority to determine if it is unsafe for the towing vessel to proceed.

5.2.11 If the master has determined it is unsafe to proceed, does the company’s safety management system clearly communicate that the master must ensure that adequate corrective action is taken, and must not proceed until it is safe to do so? (RCP II-I-1b-1)

The company’s safety management system must clearly communicate that if the master has determined it is unsafe to proceed, the master must ensure that adequate corrective action is taken, and must not proceed until it is safe to do so.

5.2.12 Does the company’s safety management system clearly communicate that the master has the authority to determine that an operation endangers the vessel or crew? (RCP II-I-1b-1)

The company’s safety management system must clearly communicate that the master has the authority to determine that an operation endangers the vessel or crew.


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5.2.13 If the master has determined that an operation endangers the vessel or crew; does the company’s safety management system clearly communicate that the master must ensure that adequate corrective action is taken and must not proceed until it is safe to do so? (RCP II-I-1b-1)

The company’s safety management system must clearly communicate that if the master has determined than an operation endangers the vessel or crew, the master must ensure that adequate corrective action is taken, and must not proceed until it is safe to do so.

5.2.14 Does the company’s safety management system clearly communicate that the master has the authority to determine that an unsafe condition exists? (RCP II-I-1b-1)

The company’s safety management system must clearly communicate that the master has the authority to determine than an unsafe condition exists.

5.2.15 If the master has determined that an unsafe condition exists, does the company’s safety management system clearly communicate that the master must ensure that adequate corrective action is taken and must not proceed until it is safe to do so? (RCP II-I-1b-1)

The company’s safety management system must clearly communicate that if the master has determined that an unsafe condition exists, the master must ensure that adequate corrective action is taken, and must not proceed until it is safe to do so.


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5.2.16 Does the company’s safety management system clearly communicate that nothing in the safety management system applicable to the towing vessel shall be misinterpreted in a manner that limits the master or mate (pilot) of their own responsibility taking such steps as he/she deems necessary and prudent to assist vessels in distress or for other emergency conditions? (RCP II-I-1b-2)

The company’s safety management system must clearly communicate that nothing in the safety management system applicable to the towing vessel shall be misinterpreted in a manner that limits the master or mate (pilot) of their own responsibility to take such steps as s/he deems necessary and prudent to assist vessels in distress, or for other emergency conditions.

5.2.17 Does the company’s safety management system clearly communicate that the master has the ability to request the company’s help when necessary? (RCP II-I-1b-3)

The company’s safety management system must clearly communicate that the master has the ability to request the company’s help when necessary.


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5.3 Is there a designated person(s) ashore having direct access to the highest level of management (Designated Person)? (RCP II-I-2)

The company must have one or more designated persons ashore having direct access to the highest level of management. The Designated Person position must be clearly identified in a written policy, written organizational levels or organizational chart (5.1). The name(s) of the person(s) in this position, along with their specific “Designated Person” responsibilities need(s) to be well documented, and widely disseminated so as to be readily available to employees in the workplace. These responsibilities must include both safety and environmental management.

5.4 Towing Vessel Crew Authority and Responsibilities:

5.4.1 Does the company’s safety management system document the authority of the towing vessel crew? (RCP II-I-1)

The company’s safety management system must document the crew’s authority in written form and be widely disseminated so as to be readily available to employees in the workplace.

5.4.2 Does the company’s safety management system document the general responsibilities of the towing vessel crew? (RCP II-I-1)

The company’s safety management system must document the crew’s general responsibilities in written form and be widely disseminated so as to be readily available to employees in the workplace. These may be defined in job descriptions, functional descriptions or any other format that achieves the requirement of “well documented and defined.”

5.4.3 Does the company’s safety management system clearly communicate that the crew is responsible for the safety of the towing vessel? (RCP II-I-1c-1)

The company’s safety management system must clearly communicate that the crew is responsible for the safety of the towing vessel.


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5.4.4 Does the company’s safety management system clearly communicate that the crew is responsible for compliance with the safety management system? (RCP II-I-1c-1)

The company’s safety management system must clearly communicate that the crew is responsible for compliance with the safety management system.

5.4.5 Does the company’s safety management system clearly communicate that the crew is responsible for compliance with applicable regulations? (RCP II-I-1c-2)

The company’s safety management system must clearly communicate that the crew is responsible for compliance with applicable regulations.

5.4.6 Does the company safety management system clearly communicate the crew’s requirement to report unsafe conditions to the master? (RCP II-I-1c-3)

The company’s safety management system must clearly communicate the crew’s requirement to report unsafe conditions to the master. The company is responsible for making a determination of what constitutes an unsafe condition or providing examples of which unsafe conditions require reporting.

5.4.7 Does the company safety management system clearly communicate that the crew is responsible for taking action to prevent accidents? (RCP II-I-1c-3)

The company’s safety management system must clearly communicate that the crew is responsible for taking action to prevent accidents.

7OPYRIGHT © TOWING VESSEL INSPECTION BUREAU (TVIB) – 2017 TVIB RCP MANAGEMENT AUDIT WORKSHEET - (6) –1.1.2017

6-1

SECTION 6 – RESOURCES AND PERSONNEL TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

Hiring

6.1 Does the company have a documented (written) hiring policy or procedure? (RCP II-J-1)

The company must have a written hiring policy and/or one or more written procedures to implement the policy. The hiring policy and/or written procedure(s) must satisfy the RCP definitions for a written policy or procedure. Regardless of the vehicle used, each company should provide a detailed description of their hiring practices for each item listed below, as appropriate.

Companies may want to consider ensuring their hiring policies and procedures address requirements of personnel initiatives such as EEO, ADA and any other federal or state requirements that may apply to the company’s employment practices.

6.2 Does the written hiring policy or procedures include physical exams or physical standards? (RCP II-J-2)

The company must have one or more written hiring policies or procedures that require physical exams by a medical professional, or a written physical standards policy or procedure that satisfies the RCP definition for a written policy or procedure. Written procedures addressing physical exams for pre-employment should require these exams to be conducted by a qualified medical professional and should take into consideration the specific type of work to be done by the employee and the duties contained in the job description. Physical standards policies and/or procedures intended to be used in lieu of a physical examination should contain a detailed outline of the physical standards employees will be expected to meet. Each prospective vessel employee should be assessed by a medical professional who is qualified to make the determination as to whether or not the prospective employee meets the written standards.

Maritime law, as well as federal and state requirements, is very specific regarding employment practices. EEOC and ADA are two sets of specific legal requirements that must be considered.

6.3 Does the written hiring policy or procedure include drug screening? (RCP II-J-3) (46 CFR 16.210)

The company must have a written hiring policy or procedure which requires pre-employment drug screening, and which satisfies the RCP definition for a written policy or procedure.

46 CFR 16.210 outlines pre-employment testing requirements for dangerous drugs as established by the USCG for employees who will be engaged in the marine employment. Currently, alcohol testing is not required at pre-employment. Other laws and regulations may apply to this process, such as EEOC and ADA.


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Orientation Program

6.4 Does the company have a documented (written) employee orientation program? (RCP II-J-5) (RCP V-C-1,-2,-3,-4 and -5)

The company must have a written employee orientation program which satisfies the RCP definition for a written program, and must include all elements required by the RCP.

The orientation program could be delivered via multiple methods, including electronic means, videos, shadowing, on-the-job training, conducted by a qualified individual, etc. Regardless of the method of training, the orientation program must include recordkeeping.

6.4.1 Is the written employee orientation program applicable to all new hires, including experienced personnel? (RCP II-J-5) (RCP V-C-1,-2,-3,-4 and -5)

The company’s written employee orientation program must be applicable to all new hires, including experienced personnel and new trip personnel as appropriate to their job position.

6.5 Employee orientation for entry-level towing vessel crewmembers components must include: (RCP V-C-5a)

6.5.1 Does the written employee orientation include drug and alcohol policy requirements? (RCP V-C-5a-1)

The company’s written employee orientation program must include drug and alcohol policy requirements.

See 33 CFR Part 95, 46 CFR Parts 4 and 16, and 49 CFR Part 40 for additional information.

6.5.2 Does the written employee orientation include exposure to and understanding of the company safety program and policy? (RCP V-C-5a-2)

The company’s written employee orientation program must include exposure to and understanding of the company safety program and policy (in Management Worksheet Section 2).


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6.5.3 Does the written employee orientation include safety as a condition of employment? (RCP V-C-5a-2)

The company’s written employee orientation program must include working safely as a condition of employment.

The company should define what “safety as a condition of employment” means, and the possible consequences for failure to comply.

6.5.4 Does the written employee orientation include safety equipment and PPE requirements? (RCP V-C-5a-4)

The company’s written employee orientation program must include safety equipment and PPE requirements, in accordance with the company’s written PPE policies or procedures (in Management Worksheet Section 2).

The company could include this requirement as part of shore side and onboard orientations.

6.5.5 Does the written employee orientation include fall overboard prevention? (RCP V-C-5d)

The company’s written employee orientation program must include fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures (in Management Worksheet Section 2).

Additional information regarding fall overboard prevention can be found in lesson plans published by the AWO Safety Committees.

6.5.6 (a)

Does the written employee orientation include injury prevention training? (RCP V-C-5e)

The company’s written employee orientation program must include injury prevention training. This includes training for prevention of all injuries, as determined by the company.

The training program could include methods such as job hazard analyses, risk assessments, lessons learned, safety briefings, team assessments while performing activities, etc.

6.5.6 (b)

Does the written employee orientation include back training? (RCP V-C-5e)

The company’s written employee orientation program must include back training. This includes training for proper lifting and body mechanics as appropriate for the employee’s job duties.

6.5.6 (c)

Does the written employee orientation include slip, trip and fall prevention training? (RCP V-C-5e)

The company’s written employee orientation program must include slip, trip and fall prevention training.

See 29 CFR 1910.20 thru 1910.30 for additional information. Additional information regarding slip, trip and fall prevention can be found in lessons plans published by the AWO Safety Committees.


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6.5.7 (a)

Does the written employee orientation include an onboard vessel orientation? (RCP V-C-5a-3)

The company’s written employee orientation program must include an onboard vessel orientation.

This could be done by the Master or his/her designate, and should include a company-specified list of items at a minimum.

6.5.7 (b)

Does the written employee orientation include vessel deck operations? (RCP V-C-5a-3)

The company’s written employee orientation program must include vessel deck operations.

This could be done by the Master or his/her designate, and should include a company-specified list of items at a minimum.

6.5.8 Does the written employee orientation include job responsibilities? (RCP V-C-5a-5)

The company’s written employee orientation program must include job responsibilities, in accordance with the well documented responsibilities of vessel personnel (in Management Worksheet Section 5).

6.6 Does the written employee orientation include exposure to emergency procedures? (RCP V-C-5b)

The company’s written employee orientation program must include exposure to the written emergency response procedures (in Management Worksheet Section 8) and the station bill requirements and directions.

6.6.1 Does the written employee orientation include exposure to emergency procedures for fire response? (RCP V-C-5b-1)

The company’s written employee orientation program must include exposure to emergency procedures for fire response and the station bill, as applicable to the employee’s job position.

See 46 CFR 27.209 and RCP Addendum C Item 14--16 for RCP requirements for firefighting training.

6.6.2 Does the written employee orientation include exposure to emergency procedures for collision and allision? (RCP V-C-5b-2)

The company’s written employee orientation program must include exposure to the written emergency response procedures for collision and allision (as applicable in Management Worksheet Section 8) and in accordance with the station bill.


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6.6.3 Does the written employee orientation include exposure to emergency procedures for sinking? (RCP V-C-5b-3)

The company’s written employee orientation program must include exposure to emergency procedures for vessel sinking (as applicable in Management Worksheet Section 8), and in accordance with the station bill.

6.6.4 Does the written employee orientation include exposure to emergency procedures for grounding? (RCP V-C-5b-4)

The company’s written employee orientation program must include exposure to emergency procedures for grounding (as applicable in Management Worksheet Section 8), and in accordance with the station bill.

6.6.5 Does the written employee orientation include exposure to emergency procedures for man overboard? (RCP V-C-5b-5)

The company’s written employee orientation program must include exposure to emergency procedures for man overboard (as applicable in Management Worksheet Section 8), and in accordance with the station bill.

6.6.6 Does the written employee orientation include exposure to emergency procedures for personal injury and illness? (RCP V-C-5b-6)

The company’s written employee orientation program must include exposure to the written emergency response procedures for personal injury and illness (as applicable in Management Worksheet Section 8) and in accordance with the station bill.


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6.7 Does the written employee orientation address confined space hazard awareness? (RCP V-C-5c)

The company’s written employee orientation program must address confined space hazard awareness, in accordance with the company’s written confined space procedures (in Management Worksheet Section 2). Companies that explicitly prohibit their employees from entering confined (or possibly enclosed) spaces must include their policy addressing this (in Management Worksheet Section 2).

Additional information regarding confined or enclosed space entry may be found in 29 CFR 1910.146 and 29 CFR 1915 Subpart B. See also the “AWO Approved Policy Regarding RCP Compliance” for the policy regarding compliance with OSHA Safety and Health Standards (see RCP Manual: Introduction to Section II, Management and Administration). Additional information regarding confined space hazard awareness can be found in lesson plans published by the AWO Safety Committees.

6.7.1 Where a company allows employees to enter confined or enclosed spaces, did the emergency procedures orientation include confined space entry hazard training for all involved personnel? (RCP V-C-5-c)

If a company allows employees to enter confined or enclosed spaces, the emergency procedures orientation must include confined space entry hazard training for all involved personnel. All crewmembers, not just those who are allowed access into confined or enclosed spaces, should receive training.

Training

6.8 Does the company have a written training program? (RCP V-C) (RCP II-J-5)

The company must have a written training program, or documented process, which satisfies the RCP definition for a written program or documented process. The written training program or documented process applies to all towing vessel personnel and shore-side personnel performing duties onboard towing vessels. This applies to questions 6.8 thru 6.28.

The written program could be in the form of a matrix, calendar of training, an electronic format, etc. and could include recordkeeping requirements.

6.9 (a) Does the written training program identify who is trained? (RCP II-J-5a)

The company’s written training program or documented process must identify who is trained. Topics required for each applicable employee may be identified by position, but records should be kept by individual name.


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6.9 (b) Does the written training program identify subjects in which training is given? (RCP II-J-5b)

The company’s written training program or documented process must identify subjects in which training is given. Topics required for each applicable employee may be identified by position, but records should be kept by individual name.

6.9 (c) Does the written training program identify frequency of training? (RCP II-J-5c)

The company’s written training program or documented process must identify frequency of training. The frequency of each topic required for each applicable employee may be identified by position.

6.9 (d) Does the written training program identify documented refresher training (at least every five years)? (RCP V-C)

The company’s written training program or documented process must identify documented refresher training (at least every five years). Documented refresher training for each topic required for each applicable employee may be identified by position, but records should be kept by individual name.

Training - Master (Captain), Relief Captain, Mate (Pilot), (herein called “wheelhouse personnel”)

6.10 Initial and Refresher Training Requirements (RCP V-C-1)

The company must define what initial training means, whether it is conducted at hire or within a specified time period. The company must define what refresher training means, and when it is to be conducted. The program could define initial training as training to be conducted within a specified time period (e.g., immediately upon hire, six months, one year, etc.) beginning at either the time of hire, or at the time of implementation of the Safety Management System. The program could define refresher training as training to be conducted on a specified periodic basis, at least every five years, and/or as dictated by federal regulations. The minimum five-year interval remains the standard, even if longer intervals are allowed under federal regulation. The written training program should clarify what training is required for temporary crewmembers. Training for temporary crewmembers may be different from training for permanent members of the crew.


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6.10.1 Does the company’s written training program include initial and refresher training for responsibility and authority of Master? (RCP V-C-1h)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in responsibility and authority of the Master, in accordance with the company’s well documented vessel personnel authorities and responsibilities (as identified in Management Worksheet Section 5).

6.10.2 Does the company’s written training program include initial and refresher training for supervisory skills training? (RCP V-C-1h)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in supervisory skills, as determined by the company.

6.10.3 Does the company’s written training program include initial and refresher radar training? (RCP V-C-1a)

The company’s written training program or documented process must include initial and refresher radar training for wheelhouse personnel. Training required as a condition of licensure may be used to satisfy the training specifications of the RCP, as long as the frequency of training is in accordance with the company’s specified periodic refresher training.

See 46 CFR 11.480 for additional information.

6.10.4 Does the company’s written training program include initial and refresher navigation and boat handling training or proficiency evaluations? (RCP V-C-1b)

The company’s written training program or documented process must include initial and refresher navigation and boat handling training for wheelhouse personnel, or must include proficiency evaluations for wheelhouse personnel in accordance with the company’s written proficiency evaluation program (in Management Worksheet Section 6).

The company may comply by conducting written proficiency evaluations, by having a formal training program to address navigation and boat handling skills, or both. The auditor should confirm there are records of proficiency training or a formal evaluation.


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6.10.5 Does the company’s written training program include initial and refresher Rules of the Road training? (RCP V-C-1b)

The company’s written training program or documented process must include initial and refresher Rules of the Road training for wheelhouse personnel. Training required as a condition of licensure may be used to satisfy the initial training specifications of the RCP for Rules of the Road training, but must be completed within a specified time period (e.g., immediately upon hire, six months, one year, etc.) beginning at either the time of hire, or at the time of implementation of the Safety Management System. The frequency of refresher training must be in accordance with the company’s specified periodic for refresher training.

6.10.6 Does the company’s written training program include initial orientation and refresher training for company policies and procedures? (RCP V-C-1c)

The company’s written training program or documented process must include initial orientation for wheelhouse personnel on company policies and procedures (as applicable to their position), and refresher training for wheelhouse personnel in company policies and procedures.

6.10.7 Does the company’s written training program include initial and refresher training for federal requirements and company conformance? (RCP V-C-1c)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in review of federal requirements applicable to their position and the company’s conformance with the federal requirements.

Federal regulations may include USCG, EPA, OSHA, DOT, etc., and company conformance may include the methods the company uses to comply with the regulations.

6.10.8 Does the company’s written training program include initial and refresher training for marine firefighting and fire prevention? (RCP V-C-1d)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in marine firefighting and fire prevention. See 46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training.


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6.11 Does the company’s written training program for wheelhouse personnel include initial and refresher training for personal safety, including: (RCP V-C-1e)

6.11.1 Does the company’s written training program include initial and refresher training for first aid and CPR awareness? (RCP V-C-1e-1)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in first aid and CPR awareness, in accordance with the company’s written procedures (Management Worksheet Section 2 – 2.17.6(a)).

The American Red Cross offers both first Aid and CPR courses that result in the employee receiving a wallet sized card certifying them as having completed the requirements for First Aid / CPR as appropriate. The American Heart Association also conducts similar courses through its HeartQuarters Training program designed specifically to address an individual company’s requirements for First Aid, CPR and AED training. See 29 CFR 1910.151 for additional information.

6.11.2 Does the company’s written training program include initial and refresher training for confined space hazard awareness? (RCP V-C-1e-2)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in confined space hazard awareness, in accordance with the company’s written confined space procedures (in Management Worksheet Section 2). Companies that explicitly prohibit their employees from entering confined (or possibly enclosed) spaces must include their policy addressing this (in Management Worksheet Section 2).


6.11.3 Does the company’s written training program include initial and refresher training for fall overboard prevention? (RCP V-C-1e-4)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures (in Management Worksheet Section 2).



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6.11.4 (a)

Does the company’s written training program include initial and refresher training for injury prevention? (RCP V-C-1e-3)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in injury prevention. This includes training for prevention of all injuries, as determined by the company.


6.11.4 (b)

Does the company’s written training program include initial and refresher back training? (RCP V-C-1e-3)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in back training. This includes training for proper lifting and body mechanics as applicable to the job responsibilities of the position.

6.11.4 (c)

Does the company’s written training program include initial and refresher slip, trip and fall prevention training? (RCP V-C-1e-3)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in slip, trip and fall prevention training.


6.12 Does the company’s written training program include initial and refresher training for wheelhouse personnel working with tank barges in tow:

6.12.1 Does the company’s written training program include initial and refresher training for first responder, spill mitigation training, and emergency response (may include HAZWOPER training) for wheelhouse personnel working with tank barges in tow? (RCP V-C-1f-1)

For wheelhouse personnel working with tank barges in tow, the company’s written training program or documented process must include initial and refresher training in first responder, spill mitigation training, and emergency response, in accordance with the company’s written procedures for spill response (in Management Worksheet Section 8) (may include Hazardous Waste Operations training).

While all towing vessels must have a spill response plan and/or contingency plan regardless of oil capacity, towing vessels over 400 GT must have a USCG-approved Non-Tank Vessel Response Plan. See 33 USC 1321(j)(5) and NVIC 01-05 CH-1. See 29 CFR 1910.120 for additional information regarding Hazardous Waste Operations.


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6.12.2 Does the company’s written training program include initial and refresher training for benzene awareness training and entry precautions (where applicable) for wheelhouse personnel working with tank barges in tow? (RCP V-C-1f-2)

For wheelhouse personnel working with tank barges in tow containing benzene, the company’s written training program or documented process must include initial and refresher training in benzene awareness and entry precautions, in accordance with the company’s written benzene handling policy/procedures (in Management Worksheet Section 2).

Additional information regarding benzene may be found in 46 CFR Part 197 Subpart C.

6.13 Does the company’s written training program include initial and refresher training for cargo knowledge and hazard awareness? (RCP V-C-1g) (29 CFR 1910.1200)

The company’s written training program or documented process must include initial and refresher training for wheelhouse personnel in cargo knowledge and hazard awareness, in accordance with the company’s written procedures for cargo knowledge and hazard communication (in Management Worksheet Section 2), and must comply with applicable requirements of 29 CFR 1910.1200.

Additional information regarding cargo knowledge may be found in 33 CFR Parts 154, 155, & 156; 46 CFR numerous parts; and 29 CFR 1910.1200. See also the “AWO Approved Policy Regarding RCP Compliance” for the policy regarding compliance with OSHA Safety and Health Standards.

Training – Engineer (If the vessel does not have an engineer, determine who the person in charge of fuel transfers would be and apply question number 6.14.2 to them; consider all of the questions in this section as applying to the crewmember who performs the duties normally assigned to an engineer, as appropriate.)

6.14 Does the company’s written training program for engineers include initial and refresher training for: (RCP V-C-2)



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6.14.1 Does the company’s written training program include initial and refresher training for marine diesel school or in-house training, including equipment and technical enhancements? (RCP V-C-2a)

The company’s written training program or documented process must include initial and refresher training for engineers in marine diesel school or in-house training, including equipment and technical enhancements.

6.14.2 Has the PIC received Coast Guard required initial and refresher training on procedures for fuel transfer? (RCP II-B-5 and III-F-7) (33 CFR 155.700-820) (33 CFR 155.715) (33 CFR 155.720)

The PIC must have received Coast Guard required training in procedures for fuel transfer, in accordance with the company’s written procedures for loading vessel fuel and transferring fuel to barges or other vessels (as applicable). Per 33 CFR 155.710(e)(2), the PIC must either have a valid license or carry a letter satisfying the requirements of 33 CFR 155.715, designating him or her as a PIC of the transfer of fuel and stating that he or she has received sufficient training to ensure his or her ability to safely and adequately carry out the duties and responsibilities of the PIC, for vessels with a 10,500 gallon capacity or more. If the capacity is less than 10,500 gallons, then 33 CFR 155.700 applies and the owner/agent of the vessel or the person arranging for and hiring the person to be in charge of the transfer, is responsible for designating the PIC of each transfer to or from the vessel, and there is no PIC training requirement.

Additional guidance can be found in 33 CFR Part 155 Subpart C – Transfer Personnel, Procedures, Equipment, and Records. See also Vessel Section 5.26 Auditors should look for the PIC letter on the vessel designating individuals by name who may serve as PIC, each individual’s PIC card or certification letter as documentation of who has been trained on PIC transfer responsibilities. For vessels with a capacity of less than 10,500 gallons, the PIC letter on the vessel may designate individuals who may serve as a PIC by name or by position in the crew.

6.15 Does the company’s written training program include initial orientation and refresher training for company policies and procedures? (RCP V-C-2b)

The company’s written training program or documented process must include initial orientation for engineers on company policies and procedures (as applicable to their position), and refresher training for engineers in company policies and procedures.


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6.15.1 Does the company’s written training program include initial and refresher training for review of federal requirements and company conformance? (RCP V-C-2b)

The company’s written training program or documented process must include initial and refresher training for engineers in review of federal requirements applicable to their position and the company’s conformance with the federal requirements.


6.16 Does the company’s written training program include initial and refresher training for marine firefighting and fire prevention? (RCP V-C-2c)

The company’s written training program or documented process must include initial and refresher training for engineers in marine firefighting and fire prevention. See 46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training.

6.17 Where applicable, does the company’s written training program include training for vessel staff on the operation and maintenance of the oily water separator? (33 CFR 155.380(e))

If the company has vessels with an oily water separator, the company’s written training program must include familiarization in the operation and maintenance of the oily water separator.

6.18

Does the company’s written training program for engineers include initial and refresher training for personal safety, including: (RCP V-C-2d)


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6.18.1

Does the company’s written training program include initial and refresher training for first aid and CPR awareness? (RCP V-C-2d-1)

The company’s written training program or documented process must include initial and refresher training for engineers in first aid and CPR awareness, in accordance with the company’s written procedures (Management Worksheet Section 2 – 2.17.6(a)).

The American Red Cross offers both First Aid and CPR courses that result in the employee receiving a wallet sized card certifying them as having completed the requirements for First Aid / CPR as appropriate. The American Heart Association also conducts similar courses through its HeartQuarters Training program designed specifically to address an individual company’s requirements for First Aid, CPR and AED training. See 29 CFR 1910.151 for additional information.

6.18.2

Does the company’s written training program include initial and refresher training for confined space hazard awareness? (RCP V-C-2d-2)

The company’s written training program or documented process must include initial and refresher training for engineers in confined space hazard awareness, in accordance with the company’s written confined space procedures (in Management Worksheet Section 2). Companies that explicitly prohibit their employees from entering confined (or possibly enclosed) spaces must include their policy addressing this (in Management Worksheet Section 2).


6.18.3

Does the company’s written training program include initial and refresher training for fall overboard prevention? (RCP V-C-2d-4)

The company’s written training program or documented process must include initial and refresher training for engineers in fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures (in Section 2).


6.18.4 (a)

Does the company’s written training program include initial and refresher training for injury prevention? (RCP V-C-2d-3)

The company’s written training program or documented process must include initial and refresher training for engineers in injury prevention.



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6.18.4 (b)

Does the company’s written training program include initial and refresher back training? (RCP V-C-2d-3)

The company’s written training program or documented process must include initial and refresher training for engineers in back training. This includes training for proper lifting and body mechanics as applicable to the job responsibilities of the position.

6.18.4 (c)

Does the company’s written training program include initial and refresher slip, trip and fall prevention training? (RCP V-C-2d-3)

The company’s written training program or documented process must include initial and refresher training for engineers in slip, trip and fall prevention training.


6.18.5

Does the company’s written training program include initial and refresher training for lock-out/tag-out procedures? (RCP V-C-2d-5)

The company’s written training program or documented process must include initial and refresher training for engineers in accordance with the company’s written lock-out/tag-out procedures.


6.19

Does the company’s written training program include initial and refresher training for first responder and spill mitigation training (for engineers working on tank barge tows)? (RCP V-C-2e-1)

For engineers working on tank barge tows, the company’s written training program or documented process must include initial and refresher training for engineers in first responder and spill mitigation training, in accordance with the company’s written procedures for spill response (in Management Worksheet Section 8).



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6.20

Do all newly hired engineers receive the above initial training? (RCP V-C-2)

The company’s written training program or documented process must require all newly hired engineers, both experienced and inexperienced, receive the initial training in 6.4 through 6.9.

Training – Tankerman

6.21

Does the company’s written training program for tankermen include initial and refresher training for: (RCP V-C-3)


6.21.1

Does the company’s written training program include initial and refresher training for tank barge safety training? (RCP V-C-3a)

The company’s written training program or documented process must include initial and refresher training for tankermen in tank barge safety training. Training required as a condition of licensure may be used to satisfy the training specifications of the RCP, as long as the frequency of training is in accordance with the company’s specified periodic refresher training and records of the completion of such training are maintained.

The program could define initial training as training to be conducted within a specified time period (e.g., immediately upon hire, six months, one year, etc.) beginning at either the time of hire, or at the time of implementation of the Safety Management System. The program could define refresher training as training to be conducted on a specified periodic basis, but not to exceed five years.


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6.21.2

Does the company’s written training program include initial and refresher training for loading and discharging operations? (RCP V-C-3a-1)

The company’s written training program or documented process must include initial and refresher training for tankermen in loading and discharging operations. Training required as a condition of licensure may be used to satisfy the training specifications of the RCP, as long as the frequency of training is in accordance with the company’s specified periodic refresher training and records of the completion of such training are maintained.

6.21.3

Does the company’s written training program include initial and refresher training for safety practices? (RCP V-C-3a-2)

The company’s written training program or documented process must include initial and refresher training for tankermen in safety practices, as determined by the company.

The training program could include following company procedures and safety practices for all phases of transfer operations, other operational duties, and maintenance performed on tank barges.

6.21.4

Does the company’s written training program include initial and refresher training for environmental protection and loading procedures? (RCP V-C-3a-3)

The company’s written training program or documented process must include initial and refresher training for tankermen in environmental protection and loading procedures, in accordance with the company’s written procedures for loading vessel fuel and written procedures for cargo transfer/handling (in Management Worksheet Section 7) and the company’s written environmental policy (in Management Worksheet Section 4).

6.21.5

Does the company’s written training program include initial and refresher training for federal regulation review and training? (RCP V-C-3a-4)

The company’s written training program or documented process must include initial and refresher training for tankermen in review of federal regulations applicable to their position.

Federal regulations may include USCG, EPA, OSHA, DOT, etc.


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6.21.6

Does the company’s written training program include initial and refresher training for first responder, spill mitigation, and emergency response (may include HAZWOPER training)? (RCP V-C-3a-5)

The company’s written training program or documented process must include initial and refresher training for tankermen in first responder, spill mitigation, and emergency response, in accordance with the company’s written procedures for spill response (in Section 8) (may include Hazardous Waste Operations training).


6.21.7

Does the company’s written training program include initial and refresher training for vapor recovery/control operations? (RCP V-C-3a-6)

The company’s written training program or documented process must include initial and refresher training for tankermen in vapor recovery/control operations, in accordance with the company’s written vapor recovery/control procedures (in Management Worksheet Section 7).

Additional guidance can be found in 46 CFR Part 39 and 40 CFR Part 61.

6.22

Does the company’s written training program include initial orientation and refresher training for company policies and procedures? (RCP V-C-3b)

The company’s written training program or documented process must include initial orientation for tankermen on company policies and procedures (as applicable to their position), and refresher training for tankermen in company policies and procedures.

6.22.1

Does the company’s written training program include initial and refresher training for review of federal requirements and company conformance? (RCP V-C-3b)

The company’s written training program or documented process must include initial and refresher training for tankermen in review of federal requirements applicable to their position and the company’s conformance with the federal requirements.



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6.23

Does the company’s written training program include initial and refresher training for marine firefighting and fire prevention? (RCP V-C-3c)

The company’s written training program or documented process must include initial and refresher training for tankermen in marine firefighting and fire prevention. See 46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training.

6.24

Does the company’s written training program for tankermen include initial and refresher training for personal safety, including: (RCP V-C-3d)

6.24.1


The company’s written training program or documented process must include initial and refresher training for tankermen in first aid and CPR awareness, in accordance with the company’s written procedures (Section 2 – 2.17.6(a)).


6.24.2


The company’s written training program or documented process must include initial and refresher training for tankermen in confined space hazard awareness, in accordance with the company’s written confined space procedures (in Management Worksheet Section 2). Companies that explicitly prohibit their employees from entering confined (or enclosed) spaces must include their policy addressing this (in Management Worksheet Section 2).



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6.24.3


The company’s written training program or documented process must include initial and refresher training for tankermen in fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures (in Management Worksheet Section 2).


6.24.4 (a)


The company’s written training program or documented process must include initial and refresher training for tankermen in injury prevention. This includes training for prevention of all injuries, as determined by the company.


6.24.4 (b)


The company’s written training program or documented process must include initial and refresher training for tankermen in back training. This includes training for proper lifting and body mechanics as applicable to the job responsibilities of the position.

6.24.4 (c)


The company’s written training program or documented process must include initial and refresher training for tankermen in slip, trip and fall prevention training.

See 29 CFR 1910.20 thru 1910.30 for additional information. Additional information regarding slip, trip and fall prevention can be found in lesson plans published by the AWO Safety Committees.

6.24.5

Does the company’s written training program include initial and refresher cargo-specific training? (RCP V-C-3d-5)

The company’s written training program or documented process must include initial and refresher cargo-specific training for tankermen, in accordance with the company’s written procedures for cargo handling (in Management Worksheet Section 7).


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6.25

Does the company’s written training program include initial and refresher training for vessel communications system and procedures for communication related to tankerman duties? (RCP V-C-3e)

The company’s written training program or documented process must include initial and refresher training for tankermen in vessel communications system and procedures for communication related to tankerman duties. Training required as a condition of licensure may be used to satisfy the training specifications of the RCP, as long as the frequency of training is in accordance with the company’s specified periodic refresher training, and records of the completion of such training are maintained.


Training – Deck Crew

6.26

Does the company’s written training program for deck crew include initial and refresher training for: (RCP V-C-4)



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6.26.1

Does the company’s written training program include initial and refresher training for deck operations and safety training? (RCP V-C-4a)

The company’s written training program or documented process must include initial and refresher training for deck crew in deck operations and safety training.

6.26.2

Does the company’s written training program include initial orientation and refresher training for company policies and procedures? (RCP V-C-4b)

The company’s written training program or documented process must include an initial orientation for deck crew on company policies and procedures (as applicable to their position), and refresher training for deck crew in company policies and procedures.

6.26.3

Does the company’s written training program include initial and refresher training for review of federal requirements and company conformance? (RCP V-C-4b)

The company’s written training program or documented process must include initial and refresher training for deck crew in review of federal requirements applicable to the position and the company’s conformance with those requirements.

Federal requirements may include USCG, EPA, OSHA, DOT, etc., and company conformance may include the methods the company uses to comply with the regulations.

6.26.4

Does the company’s written training program include initial and refresher training for vessel firefighting and fire prevention? (RCP V-C-4c)

The company’s written training program or documented process must include initial and refresher training for deck crew in vessel firefighting and fire prevention. See 46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training.

6.27

Does the company’s written training program for deck crew include initial and refresher training for personal safety, including: (RCP V-C-4d)


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6.27.1


The company’s written training program or documented process must include initial and refresher training for deck crew in first aid and CPR awareness, in accordance with the company’s written procedures (Section 2 – 2.17.6(a)).


6.27.2


The company’s written training program or documented process must include initial and refresher training for deck crew in confined space hazard awareness, in accordance with the company’s written confined space procedures (in Management Worksheet Section 2). Companies that explicitly prohibit their employees from entering confined (or possibly enclosed) spaces must include their policy addressing this (in Management Worksheet Section 2).


6.27.3


The company’s written training program or documented process must include initial and refresher training for deck crew in fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures (in Management Worksheet Section 2).


6.27.4 (a)


The company’s written training program or documented process must include initial and refresher training for deck crew in injury prevention. This includes training for prevention of all injuries, as determined by the company.



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6.27.4 (b)


The company’s written training program or documented process must include initial and refresher training for deck crew in back training. This includes training for proper lifting and body mechanics as applicable to the job duties of the position.

6.27.4 (c)


The company’s written training program or documented process must include initial and refresher training for deck crew in slip, trip and fall prevention training.

See 29 CFR 1910.20 thru 1910.30 for additional information. Additional information regarding slip, trip and fall prevention can be found in lesson plans published by the AWO Safety Committees.

6.27.5

Does the company’s written training program include initial and refresher training for lock-out/tag-out procedures? (RCP V-C-4d-5)

The company’s written training program or documented process must include initial and refresher training for deck crew in accordance with the company’s written lock-out/tag-out procedures (in Management Worksheet Section 10).


6.28

Does the company’s written training program include initial and refresher training for first responder and spill mitigation training (for crewmembers working on tank barge tows)? (RCP V-C-4e-1)

For crewmembers working on tank barge tows, the company’s written training program or documented process must include initial and refresher training for deck crew in spill mitigation training, in accordance with the company’s written procedures for spill response (in Management Worksheet Section 8).



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6.29

Do experienced deckhands, as well as new hires, receive the above initial training? (RCP V-C-4)

The company’s written training program or documented process must require newly-hired experienced deckhands, as well as newly-hired inexperienced deckhands, to receive the initial training in 6.4 through 6.9.

Employee Development

6.30

Does the company have written personnel development policies/procedures for vessel personnel? (RCP II-J-6)

The company must have written personnel development policies/procedures for vessel personnel which satisfy the RCP definition for a written policies/procedures.

The employee development policies/procedures requirements should coincide with the well documented vessel employee responsibilities and authorities (job descriptions), and the written employee proficiency evaluation policy/procedure.

6.30.1

Does the written personnel development policies/procedures target deckhands? (RCP II-J-6a)

The written personnel development policies/procedures must target deckhands.

6.30.2

Does the written personnel development policies/procedures target tankermen? (RCP II-J-6b)

The written personnel development policies/procedures must target tankermen.


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6.30.3

Does the written personnel development policies/procedures target engineers? (RCP II-J-6c)

The written personnel development policies/procedures must target engineers.

6.30.4

Does the written personnel development policies/procedures target wheelhouse personnel? (RCP II-J-6d)

The written personnel development policies/procedures must target wheelhouse personnel.

Proficiency Evaluations

6.31

Does the company have a documented (written) employee proficiency/ performance evaluation policy and/or procedures? (RCP II-J-4)

The company must have a written employee proficiency/performance evaluation policies/procedures which satisfies the RCP definition for a written policy or procedure.

The policy and/or procedures could include evaluations of an employee’s proficiency at some skill or knowledge level required by their well-documented vessel employee responsibilities and authorities (job description). The policy and/or procedures could include evaluations of an employee’s performance at daily tasks, personal hygiene, compliance with company policies and procedures, safety, etc.

6.31.1

Does the written employee proficiency/ performance evaluation policy and/or procedures require documented and individual employee evaluations? (RCP II-J-4)

The written employee proficiency/performance evaluation policy and/or procedures must require documented and individual employee evaluations.


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6.31.2

Does the written employee proficiency/ performance evaluation policy and/or procedures provide for feedback to the employees? (RCP II-J-4)

The written employee proficiency/performance evaluation policy and/or procedures must provide for feedback to the employees.

The policy and/or procedures could include training and personal development to improve proficiency and/or performance. Resources may be made available as necessary to assist the employee in their development, and feedback could be followed up with re-evaluation.

Other Personnel Policies

6.32

Does the company have a documented (written) drug and alcohol policy? (RCP II-J-3)

The company must have a written drug and alcohol policy which satisfies the RCP definition for a written policy.

See 33 CFR Part 95, 46 CFR Parts 4 and 16 and 49 CFR Part 40 for additional information.

6.32.1

Does the company have a documented training program for towing vessel crew regarding an employee assistance program? 46 CFR 16.401(b)

An EAP training program must be conducted for the employer's crewmembers and supervisory personnel. The training program must include at least the following elements: the effects and consequences of drug and alcohol use on personal health, safety, and work environment; the manifestations and behavioral cues that may indicate drug and alcohol use and abuse; and documentation of training given to crewmembers and the employer's supervisory personnel.

6.32.2

Does the company have a documented training program for supervisory personnel regarding an employee assistance program? 46 CFR 16.401(b)

An EAP training program must be conducted for the employer's crewmembers and supervisory personnel. The training program must include at least the following elements: the effects and consequences of drug and alcohol use on personal health, safety, and work environment; the manifestations and behavioral cues that may indicate drug and alcohol use and abuse; and documentation of training given to crewmembers and the employer's supervisory personnel. Supervisory personnel must receive at least 60 minutes of training.


6-29


6.33

Does the company have a documented (written) prescription medication notification policy/procedure? (RCP II-J-7)

The company must have a written prescription medication notification policy or one or more written procedures, which satisfies the RCP definition for a written policy or procedure.

The policy/procedure could include who should be notified and when they should be notified, and address other questions or issues as determined by the company. Companies may need to consider HIPPA rules and regulations.

6.34

Does the company have a documented (written) personal hygiene policy/procedure? (RCP II-J-8)

The company must have a written personal hygiene policy or one or more written procedures, which satisfies the RCP definition for a written policy or procedure.

The policy/procedure could be part of another document (e.g., employee handbook) or included as part of the Safety Management System. The policy/procedure could include training on personal hygiene as it pertains to overall health and wellness. Companies may follow up by addressing personal hygiene in the employee proficiency/performance evaluation program.

6.35

Does the company have a documented (written) sanitation and safe food handling policy/procedure? (RCP II-J-9)

The company must have a written sanitation and safe food handling policy or one or more written procedures, which satisfies the RCP definition for a written policy or procedure.

Additional information regarding safe food handling and galley safety can be found in lesson plans published by the AWO Safety Committees.

6.36

Does the company have a documented (written) disciplinary policy/procedure? (RCP II-J-10)

The company must have a written disciplinary policy or one or more written procedures, which satisfies the RCP definition for a written policy or procedures.

This policy/procedure could be part of another document (e.g., employee handbook) or included as part of the Safety Management System.

6.36.1

Does the written disciplinary policy/procedure identify behavior under which termination or suspension may occur? (RCP II-J-10)

The company’s written disciplinary policy/procedure must identify behavior under which termination or suspension may occur.


6-30


Watchstanding and Work Hours (Non-Emergency) Policies/Procedures

6.37

Are work hour restrictions well documented? (RCP V-B)

The company must have work hour restrictions in written form and be widely disseminated so as to be readily available to affected employees in the workplace.

Work hour restrictions could be part of another document (e.g., employee handbook) or included as part of the Safety Management System.

6.37.1

Does the company have a mechanism to track or confirm communication of work hour restrictions? (46 CFR 15.705)

The company must provide a mechanism to track or confirm that work hour restrictions have been communicated to each affected employee.

Work hour restrictions could be part of another document (e.g., employee handbook) or included as part of the Safety Management System.

6.37.2

Do the well documented work hour restrictions require, except as otherwise provided, such as 46 USC 8104(c), that licensed towing vessel operators work no more than 12 hours in a 24-hour period? (RCP V-B) (46 USC 8104(h))

The company must have well documented work hour restrictions which require, except as otherwise provided, such as 46 USC 8104(c), that licensed towing vessel operators work no more than 12 hours in a 24-hour period in accordance with 46 USC 8104(h).

See 46 CFR 15.705(d) and 46 USC 8104(c) and (h) for additional information.

6.37.3

Do the well documented work hour restrictions require that other vessel crewmembers work no more than 15 hours in a 24-hour period and no more than 42 hours in a 72-hour period? (RCP V-B)

The company must have well documented work hour restrictions which require that vessel crewmembers other than licensed towing vessel operators work no more than 15 hours in a 24-hour period and no more than 42 hours in a 72-hour period.


6-31


Vessel Manning Levels

6.38.1

Do written vessel manning policies/procedures reflect applicable laws and regulations? (RCP V-A-1a)

The company must have one or more written vessel manning policies or one or more written procedures, which satisfy the RCP definition of a written policy or procedure, and which reflect applicable laws and regulations, (e.g. if the vessel has a USCG Certificate of Inspection (COI), minimum manning must be consistent with the requirements of the COI).

6.38.2

Do written vessel manning policies/procedures take into account number, size, and type of barges to be towed? (RCP V-A-1b)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account the number, size and type of barges to be towed.

6.38.3

Do written vessel manning policies/procedures take into account geographical towing route? (RCP V-A-1c)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account the geographical towing route.

6.38.4

Do written vessel manning policies/procedures take into account safety of personnel, equipment, and the environment? (RCP V-A-1d)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account safety of personnel, equipment and the environment.

6.38.5

Do written vessel manning policies/procedures take into account the service in which tow is engaged? (RCP V-A-1e)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account the service in which the tow is engaged.


6-32


6.38.6

Do written vessel manning policies/procedures take into account duties of the crew in addition to navigation? (RCP V-A-1f)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account the duties of the crew in addition to navigation.

6.38.7

Do written vessel manning policies/procedures take into account the configuration of vessel-deck and engine room machinery? (RCP V-A-1g)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account the configuration of vessel-deck and engine room machinery.

6.38.8

Do written vessel manning policies/procedures take into account the extent of mechanical and/or electronic automation? (RCP V-A-1h)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account the extent of mechanical and/or electronic automation.

6.38.9

Do written vessel manning policies/procedures take into account vessel sizes and machinery operating requirements? (RCP V-A-1i)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account vessel sizes and machinery operating requirements.


6-33


6.38.10

Do written vessel manning policies/procedures take into account environmental, weather, and climatic conditions? (RCP V-A-1j)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account environmental, weather, and climatic conditions (e.g. icing, lightening, conditions of visibility, etc.).

6.38.11

Do written vessel manning policies/procedures take into account the overall experience of the crew? (RCP V-A-1k)

The company must have one or more written vessel manning policies or one or more written procedures which satisfy the RCP definition of a written policy or procedure, and which take into account the overall experience of the crew.

6.39

Is there a written policy/procedure requiring (except in an emergency) at least one wheelhouse person and one crewmember on duty at all times while underway? (RCP V-A-2)

The company must have one or more written vessel manning policies or procedures which satisfy the RCP definition of a written policy or procedure, and which require (except in an emergency) at least one qualified wheelhouse person and one additional crew member to be on duty at all times while the vessel is underway.


7-1

SECTION 7 – PLANS AND PROCEDURES FOR VESSEL OPERATIONS TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

7.1 Does the company have written vessel operating procedures that are well documented and distributed? (RCP II-B-1)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

7.1.1 Does the company have a written bridge transit procedure that is well documented and distributed? (RCP II-B-1a)

The company must have one or more written bridge transit procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees. This should include procedures specific to wheelhouse operations as well as to deck personnel.

The procedure(s) could include clear instructions regarding means and alternate means of communications (e.g., radio, hand signals, boat whistle, etc.). They should also include clear instructions regarding watch changes within a reasonable time period before transit, including allowing time for lining up the tow in preparation for transit. Additional information regarding bridge transit can be found in lesson plans published by the AWO Safety Committees.

7.1.2 For vessels operating on coastal routes, does the company have a written voyage planning procedure that is well documented and distributed? (RCP II-B-1b)

For vessels operating on coastal routes, the company must have one or more written voyage planning procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

Where applicable, the procedure(s) could include clear instructions regarding the completion of the voyage plan and review, discussion and acceptance with affected personnel before departure, that the voyage plan include all required or good practice information (including way points), and that the voyage plan be complete, covering from departure to arrival.

7.2 Does the company have a written change of watch procedure that is well documented and distributed? (RCP II)

The company must have one or more written change of watch procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

The procedure(s) could include guidance on situational awareness, vessel performance, and should also include a situation when a watch change occurs in conjunction with a crew change.


7-2


7.3 Does the company have a written guests and other visitors procedure that is well documented and distributed? (RCP II)

The company must have one or more written guests and other visitors procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

The procedure(s) could include, as applicable, security checks, safety, environmental and security briefings, and a review of the station bill.

7.4 Does the company have a written vessel communications with shore personnel procedure that is well documented and distributed? (RCP II)

The company must have one or more written vessel communications with shore personnel procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

The procedure(s) could cover regular communications (verbal, electronic and reports), as well as emergency communications (including points of contact and reporting requirements in the company) and other communications as specified by the company.

7.5 Does the company have a written bridge-to-bridge communications procedure that is well documented and distributed? (RCP II)

The company must have one or more written bridge-to-bridge communications procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

The procedure(s) could include standard communications terminology, as well as emergency communication guidance. Additional guidance may be found in 47 CFR 80.163 and 33 CFR 26.01.

7.6 Does the company have a written radio watch procedure that is well documented and distributed? (RCP II) (47 CFR 80.148) (33 CFR 26.01) (33 CFR 26.05)

The company must have one or more written radio watch procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

Additional guidance may be found in 33 CFR 160.472(a)(3) and 47 CFR 80.409(e)(3).

7.7 Does the company have a written Vessel Traffic Services (VTS) usage requirements procedure that is well documented and distributed? (RCP II) (33 CFR 161)

The company must have one or more written VTS usage requirements procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.


7-3


7.8 If applicable, does the company have written locking procedures that are well documented and distributed? (RCP II)

If the company has vessels that go through locks, then the company must have one or more written locking procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

Additional guidance may be found in the 33 CFR Part 207 (Blue Book).

7.9 If applicable, does the company have a written skiff/yawl use and operation procedure that is well documented and distributed? (RCP II)

If applicable, the company must have one or more written skiff/yawl use and operation procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

The procedure(s) could include launching and recovery operations, operation of outboard motor (if provided), limitations on capacity and use, navigation rules, maintenance, training and documentation, etc.

7.10

Does the company have a written navigation procedure that is well documented and distributed? (RCP II)

The company must have one or more written navigation procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

Examples of elements of a navigation procedure include the weather, tides, address the rules of the road, etc. Additional guidance regarding navigation may be found in 33 CFR Parts 83 – 88, and 33 CFR Part 207 (Blue Book).

7.11

Does the company have a written making up tow procedure that is well documented and distributed? (RCP II)

The company must have one or more written making up tow procedures, which satisfy the RCP definition for a written procedure, and which appear to the auditor to be well documented and widely disseminated so as to be available to all employees.

The procedure(s) could include tow configuration, placement of tank barges in tow, draft restrictions, etc. Additional guidance can be found in 33 CFR 164.74 and 164.76.

7.2

7.12

Do written procedures exist for making horsepower-to-tow size decisions? (RCP II-B-3)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for making horsepower-to-tow size decisions.

The procedure(s) could include considerations for crew size/experience, weather, river conditions, and the authority of the master, etc.

7.3

7.13

Do written procedures exist for dry cargo transfers, where applicable? (RCP II-B-9)

If the company is involved with cargo handling, the company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for cargo transfers.

The procedure(s) could include cargo knowledge and hazard awareness. Cargo handling in this context refers to dry cargo.


7-4


7.4

7.14

Do written procedures exist for the lightering of dry cargoes, where applicable? (RCP II-B-10)

If the company is involved with the lightering of dry cargoes, the company must have one or more written procedures which satisfy the RCP definition for a written procedure, for lightering of dry cargoes.

7.5

7.15

Do written procedures exist for liquid cargo transfers, where applicable? (RCP II-B-9)

If the company is involved in liquid cargo transfers, the company must have one or more written procedures which satisfy the RCP definition for a written procedure, for liquid cargo transfers.

This question pertains to written procedures vessel employees, such as tankermen, to follow when conducting transfers to or from tank barges.

7.6

7.16

Where applicable, do written procedures exist for vessel-to-vessel lightering of liquid cargo? (RCP II-B-10)

If the company conducts lightering operations, the company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for vessel-to-vessel lightering.

When lightering operations occur and towing vessel crews are actively involved, the procedure(s) could include guidelines for conducting lightering operations, safety equipment, minimum mooring requirements, safety briefing, etc., in accordance with the requirements issued by the COTP.

7.7

7.17

Where applicable, do written procedures exist for vapor control? (RCP II-B-9b)

Where applicable, the company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for vapor control.

Additional guidance can be found in 46 CFR Part 39 and 40 CFR Part 61.

7.8

7.18

If applicable, do written procedures exist for cargoes requiring special handling (e.g., anhydrous ammonia, hydrogen sulfide, etc.)? (RCP II-B-9c)

If applicable, the company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for cargoes requiring special handling (e.g., anhydrous ammonia, hydrogen sulfide, etc.).

The procedure(s) could include tow configuration requirements, special safety precautions, PPE requirements, special permitting, etc. Additional guidance can be found in 46 CFR 197.500, 46 CFR Part 151 and 29 CFR 1910.134.

7.9

7.19

If applicable, do written cargo handling procedures exist for benzene? (RCP II-B-9a) (46 CFR part 197)

If applicable, the company must have cargo handling procedures for benzene. The benzene procedures should be included in the company’s safety program, which the auditor should have examined in Management Worksheet Section 2.


7-5


7.10

7.20

Do written procedures exist to ensure that proper and valid documentation is carried aboard vessels? (RCP II-B-4)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, ensuring that proper and valid documentation is carried aboard vessels.

The procedure(s) could include a process where the company office distributes “proper and valid” documentation as necessary to each vessel, as well as regular (e.g. at least annual) onboard inspections of documentation to ensure that all “proper and valid” documentation is onboard, and that it is current. This could include MSDS, USCG special permits, Cargo Information Cards, etc.

7.10.1

7.20.1

Does the written procedure include a list of documentation to be carried? (RCP II-B-4) (46 CFR 67.161(a))

The company’s written procedure for ensuring that proper and valid documentation is carried aboard the vessels must include a list of documentation to be carried.

The procedure(s) could include a list of all documents appropriate to the vessel and its type of service and route.

7.11

7.21

Does the company have either written procedures for identifying critical stores and supplies or a list of critical stores and supplies? (RCP II-B-11)

The company can either have a list of critical stores and supplies, or one or more written procedures, which satisfy the RCP definition for a written procedure, for identifying critical stores and supplies.

The procedure(s) could include a definition of “critical” stores and supplies (e.g. rigging, filters, lock lines, fuel, and other supplies, stores and equipment which may be critical to the operation of the vessel), as well as a process to identify which stores and supplies are considered critical.

7.12

7.22

Do written procedures exist for loading vessel fuel? (RCP II-B-5)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for loading vessel fuel. For RCP compliance, every towing vessel regardless of oil capacity must have transfer procedures for loading vessel fuel and must comply with 33 CFR 155.700. Towing vessels with a capacity of oils over 10,500 gallons must have transfer procedures which meet U.S. Coast Guard requirements. The procedures should be vessel specific.

Additional guidance can be found in 33 CFR Part 155 Subpart C – Transfer Personnel, Procedures, Equipment, and Records.


7-6


7.12.1

7.22.1

Do written procedures exist that require the vessel operator to keep written records available for inspection by the COTP or OCMI of the name of each person currently designated as a person in charge (PIC) of transfer operations? (33 CFR 155.820) (33 CFR 155.700)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, regarding maintaining written records of the name of each person currently designated as a person in charge (PIC) of transfer operations. This is required regardless of total capacity of fuel and/or oils.

See 33 CFR 155.710 for the qualifications for the person in charge of transfer operations. See also 33 CFR 155.715 for the requirements of the contents of the letter referred to in 33 CFR 155.710(e)(2).

7.12.2

7.22.2

If applicable, do written procedures exist for transferring fuel to barges or other vessels? (RCP II-B-5) (33 CFR 155) (33 CFR 156)

If applicable, the company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for transferring fuel to barges or other vessels.

If either vessel contains over 10,500 gallons of oils the transfer would be regulated by the USCG and should be addressed in the vessel’s USCG required fuel transfer procedures. If neither vessel contains over 10,500 gallons of oils the transfer is not regulated by the USCG, but should still be addressed in the RCP required fuel transfer procedures.

7.12.3

7.22.3

If applicable, do written procedures exist for cargo transfer/cargo handling? (RCP II-B-9)

If the company transfers or handles cargoes, the company must have one or more written procedures, which satisfy the RCP definition for a written procedure, for cargo transfer/cargo handling.

In instances where cargo transfers are conducted by towing vessel employees, they should be conducted in accordance with either the towing vessel’s USCG required fuel transfer procedures or the barge’s USCG required oil transfer procedures. Additional information can be found in 33 CFR Part 154 Subparts A-F.

7.13

7.23

Do written procedures address the safe use and handling of rigging and towing gear? (RCP III-E-1)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, addressing the safe use and handling of rigging and towing gear.

The procedure(s) could include safety precautions when working with rigging, lines and other towing gear.


7-7


7.14

7.24

Is there a documented (written) inspection and replacement program for rigging and towing gear? (RCP III-E-3) (RCP IV-E-6)

The company must have a written program, which satisfies the RCP definition for a written program, for inspecting and replacing rigging and towing gear. The program must include a documented process to address periodic and frequent inspections of rigging and towing gear for suitability for continued use. Rigging and towing gear determined to be defective should be disposed of in accordance with the company’s documented process.

Additional information can be found in 33 CFR 164.74 and 164.76. The procedure(s) could identify the frequency with which inspections should be conducted.

7.14.1

7.24.1

Are procedures for identifying specifications for wires, lines, and associated towing gear well documented? (RCP III-E-4) (RCP IV-E-1, -2, -3)

The company must have written procedures which identify the specifications for ratchets, wires, lines, and associated towing gear. Procedures must be widely disseminated so as to be readily available to employees in the workplace.

The procedure(s) could identify the minimum size and length of lines, ratchets, wires and shackles, and associated towing gear (e.g. chain links, straps, shackles, pins, etc.). The procedure(s) could also specify acceptable manufacturers and suppliers.

7.14.2

7.24.2

Are there written procedures identifying minimum rigging and towing gear requirements for each vessel according to service? (RCP III-E-2) (RCP IV-E-1a)

The company must have written procedures that satisfies the RCP definition for a written procedure, which identify minimum rigging requirements for each item of rigging and towing gear that is to be carried onboard each vessel according to its service. Minimum rigging requirements are company and vessel specific.

7.14.3

7.24.3

Are the minimum requirements well documented? (RCP II)

The company’s written procedures which identify minimum rigging requirements for each item of rigging and towing gear that is to be carried onboard each vessel according to its service must be widely disseminated so as to be readily available to employees in the workplace.


7-8


7.15

7.25

Is there a policy regarding smoking onboard the vessel? (33 CFR 156.120 (cc))

If the company has a smoking policy, it must be adhered to onboard the vessel.

OSHA29 CFR 1910.106(d)(7)(iii) 33 CFR 156.120 (cc) provides guidance regarding no smoking areas around fuel transfer locations. It is advised that “no smoking” /designated smoking areas be marked throughout the vessel.

7.16

7.26

Does the company’s SMS contain either written procedures or a list identifying critical equipment and systems, the sudden failure of which may place the towing vessel, towing vessel crew or environment into a hazardous situation? (RCP II-B-6)

The company must have either a documented procedure which satisfies the RCP definition of a procedure, or a list identifying critical equipment and systems, the sudden failure of which may place the towing vessel, crew or environment into a hazardous situation.

The actual critical equipment will be based on the company’s risk assessment. Risk assessment considerations may, but are not required to, include: worst case scenarios, personnel and environmental impact, failure response measures, replacement and testing, back-up equipment and spares, operational impact, and added safety requirements. Critical equipment examples include: main propulsion, generator, steering, navigation equipment, firefighting equipment, PPE. If the company uses a list, it should be in a format that is easy to understand and use. Listing additional information, for example system type, location of spare parts, any special requirements for the piece of equipment, etc. may be beneficial.

7.16.1

7.26.1

If applicable, are there written records to demonstrate compliance with the procedures listed in 7.16? (RCP II-B-6)

If the company’s SMS contains written procedures to identify critical equipment and systems, the company must provide written records to demonstrate compliance with their procedure(s).


8-1

SECTION 8 – EMERGENCY RESPONSE PROCEDURES TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

8.1 Do written company emergency response procedures exist? (RCP II-F)

The company must have one or more written emergency response procedures which satisfy the RCP definition for a written procedure.

The procedures could be included with other operational procedures, or in a separate binder/manual/ electronic file. In any case, they should be readily available and easily found in an emergency situation.

8.1.1

Are these written company emergency response procedures well documented? (RCP II)

The company’s written emergency response procedures must appear to the auditor to be well documented and be widely disseminated so as to be available to all employees.

8.1.2 Are these written company emergency response procedures well known and understood by affected employees? (RCP II)

The company’s written emergency response procedures must appear to the auditor to be well known by employees that are available during the management audit.

8.2 Do written emergency response procedures include injuries and illness onboard? (RCP II-F-1)

The company must have one or more written emergency response procedures which address injuries and illness onboard vessels and which satisfy the RCP definition for a written procedure.

The procedures could include expectations of crewmembers in the event of personal injury or illness onboard the vessel (e.g. onboard reporting, reporting to office, reporting to USCG (if applicable), contacting emergency response personnel, providing first aid, etc.).

8.2.1 Do written emergency response procedures include addressing injuries and illness that require professional medical treatment beyond first aid? (46 CFR 4.05-1(a)(6)) (RCP II-F-1)

The company must have one or more written emergency response procedures which address injuries and illness requiring professional medical treatment beyond first aid, and which satisfy the RCP definition for a written procedure.

The procedures could include expectations of crewmembers in the event of personal injury or illness onboard the vessel which requires more than onboard first aid (e.g. onboard reporting, reporting to office, reporting to USCG (if applicable), contacting emergency response personnel, providing CPR and/or first aid, etc.), as well as contact information for remote (e.g., by phone or internet) medical advice, medical transportation and medical emergency facilities available along the tow routes. Alcohol and drug tests are required by 46 CFR 16.240; 46 CFR 4.06-5.


8-2


8.3 Do written emergency response procedures include a spill response plan and/or contingency plan? (RCP II-F-2)

The company must have one or more written emergency response procedures which include spill response and/or its contingency plan, and which satisfy the RCP definition for a written procedure. All towing vessels must have a spill response plan and/or contingency plan regardless of oil capacity.

While all towing vessels must have a spill response plan and/or contingency plan regardless of oil capacity, towing vessels over 400 GT must have a USCG-approved Non-Tank Vessel Response Plan. See 33 USC 1321(j)(5) and NVIC 01-05 CH-1.

8.3.1 Do written emergency response procedures include spill response emergency numbers? (RCP II-F-2)

The company must have one or more written emergency response procedures for spills which include emergency response numbers, and should satisfy the RCP definition for a written procedure.

The procedures could include contact information for company reporting, and local, state and federal authorities (as applicable).

8.3.2 Do written emergency response procedures include spills on deck during transfer operations? (RCP II-F-2)

The company must have one or more written emergency response procedures which include spills on deck during transfer operations, and which satisfy the RCP definition for a written procedure.

The procedures could include training of vessel personnel for emergency response procedures, materials to be used, and instructions for disposal for clean up of spills on deck during cargo transfer (as applicable).

8.3.3 Do written emergency response procedures include spills in the water during cargo transfer operations? (RCP II-F-2)

The company must have one or more written emergency response procedures which include spills in the water during cargo transfer operations, and which satisfy the RCP definition for a written procedure.

The procedures could include training of vessel personnel for emergency response procedures, materials to be used, and instructions for disposal for cleanup of spills in the water during cargo transfer (as applicable). See 29 CFR 1910.120 for additional information.

8.3.4 Do written emergency response procedures include spills due to grounding? (RCP II-F-3)

The company must have one or more written emergency response procedures which include spills due to grounding, and which satisfy the RCP definition for a written procedure.

The procedures could include training of vessel personnel for emergency response procedures, materials to be used, and instructions for disposal for cleanup of spills due to grounding (as applicable). See 29 CFR 1910.120 for additional information.

8.4 Do written emergency response procedures include vessel accident response? (RCP II-F-3)

The company must have one or more written emergency response procedures which include vessel accident response, and which satisfy the RCP definition for a written procedure.

The procedures could address falls overboard, severe weather, and other vessel accidents/incidents not covered elsewhere in this section. Procedures could expand on the station bill, but not be in conflict with it.


8-3


8.4.1 Do written emergency response procedures include collision with another vessel? (RCP II-F-3)

The company must have one or more written emergency response procedures which include collision with another vessel, and which satisfy the RCP definition for a written procedure.

8.4.2 (a)

Do written emergency response procedures include reporting an allision with an aid-to-navigation? (RCP II-F-3) (46 CFR 4.05-20)

The company must have one or more written emergency response procedures which include allision with an aid-to-navigation (e.g. buoys, dayboards, lights, etc.), and which satisfy the RCP definition for a written procedure.

The procedures could include expectations of crewmembers in the event of an allision with an aid-to-navigation (e.g., reporting to office, reporting to USCG (if applicable).

8.4.2 (b)

Do written emergency response procedures include allision with a fixed object? (RCP II-F-3) (46 CFR 4.05-10)

The company must have one or more written emergency response procedures which include allision with a fixed object (e.g. bridge, dock, etc.), and which satisfy the RCP definition for a written procedure.

The procedures could include expectations of crewmembers in the event of an allision with a fixed object (e.g., reporting to office, reporting to USCG (if applicable).

8.5 Do written procedures specify frequency, documentation, and subject matter of onboard emergency response training and drills? (RCP II-F-4)

The company must have one or more written emergency response procedures, or a documented process, which specifies frequency, documentation, and subject matter of onboard emergency response training and drills, and which satisfy the RCP definition for a written procedure or a documented process.

The written procedures or documented process could be in the form of a matrix, calendar of training and drills, an electronic format, etc. and could include recordkeeping requirements.

8.5.1 Do written procedures specify frequency, documentation, and subject matter of grounding drills? (RCP II-F-4) (RCP V-C-5b-4)

The company must have one or more written emergency response procedures, or a documented process, which specifies frequency, documentation, and subject matter of grounding drills, and which satisfy the RCP definition for a written procedure or a documented process.



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8.5.2 Do written procedures specify frequency, documentation, and subject matter of fire drills? (RCP II-F-4) (RCP V-C-5b-1)

The company must have one or more written emergency response procedures, or a documented process, which specifies frequency, documentation, and subject matter of fire drills, and which satisfy the RCP definition for a written procedure or a documented process.

The written procedures or documented process could be in the form of a matrix, calendar of training and drills, an electronic format, etc. and could include recordkeeping requirements. See 46 CFR 27.209 for additional information regarding fire drills and training.

8.5.3 Do written procedures specify frequency, documentation, and subject matter of sinking drills? (RCP II-F-4) (RCP V-C-5b-3)

The company must have one or more written emergency response procedures, or a documented process, which specifies frequency, documentation, and subject matter of sinking drills, and which satisfy the RCP definition for a written procedure or a documented process.


8.5.4 Do written procedures specify frequency, documentation, and subject matter of man overboard drills? (RCP II-F-4) (RCP V-C-5b-5)

The company must have one or more written emergency response procedures, or a documented process, which specifies frequency, documentation, and subject matter of man overboard drills, and which satisfy the RCP definition for a written procedure or a documented process.


8.6 Do written emergency response procedures include:

8.6.1 Do written emergency response procedures include operator incapacitation? (RCP II-F-5)

The company must have one or more written emergency response procedures which include operator incapacitation, and which satisfy the RCP definition for a written procedure.

The procedures could include means to monitor the ongoing capability of the operator (such as the use of area or personal motion sensors or “dead man switches”), and/or practices related to periodic two-way communication between wheelhouse and deck personnel. Procedures could also include the means to communicate an operator incapacitation situation quickly, provide expectations for crewmembers’ response and a means to control the vessel.


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8.6.2 Are appropriate crewmembers trained in vessel control procedures for incidents of operator incapacitation? (RCP II-F-5)

The company must have one or more written emergency response procedures which include training for crewmembers in vessel control procedures for incidents of operator incapacitation, and which satisfy the RCP definition for a written procedure.

The procedures could include vessel control training for employees designated to respond to operator incapacitation, including documentation of training.

8.7 Is the company able to demonstrate compliance with 46 CFR 4.06-1 in regards to alcohol testing within 2 hours after a serious marine incident? Are there written procedures to ensure that there are devices to accomplish alcohol testing on board, or are arrangements in place to accomplish alcohol testing within 2 hours after a serious marine incident? (46 CFR 4.06-1; 46 CFR 4.06-15)

The company must be able to demonstrate compliance with the requirements of 46 CFR 4.06-1, have one or more written procedures that include including the requirement that a vessel must have on board unexpired and/or currently calibrated devices to accomplish alcohol testing, or the company must have arrangements in place to accomplish alcohol testing within 2 hours after a serious marine incident. The procedure must satisfy the RCP definition for a written procedure.

Drug testing must be accomplished within 32 hours of a serious marine incident (46 CFR 4.06-15). If applicable, alcohol testing equipment should be calibrated in accordance with manufacturer’s recommendations.


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SECTION 9 – INCIDENT INVESTIGATION/REVIEW TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

9.1 Does the company have written procedures addressing Personal Injury Reporting? (RCP II-A-4a)

The company must have one or more written procedures which address the company’s expectations for personal injury reporting. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. As concerns vessel casualty reporting, vessel accident reporting, reporting requirements for any other types of incidents, the following guidance is offered: • USCG regulations listed in the “Additional Information” column in section 9 contain references to those types of incidents that may be required to be reported to the USCG and in this regard, are required to be complied with for RCP compliance as per AWO RCP policy. The company’s written procedures must address all USCG reporting requirements. • Furthermore, companies may have requirements issued by their Insurance Underwriters, OSHA, or other entities that may have some connection with their business and that may stipulate certain types of incidents that are to be reported to the company by these entities. • In addition, there may be other types of incidents that the company expects employees to report to the company. For example, falls overboard are soon to be included in statistics required to be submitted to AWO as a condition of membership. In order to track these statistics, companies will likely require employees to report all occurrences of falls overboard.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12 & 46 CFR 16.240 for USCG regulations addressing personal injury reporting requirements. See also 33 CFR 160.204 & 160.215 for requirements addressing reporting of hazardous conditions. In some cases, OSHA requirements for recording and reporting occupational injuries and illnesses may be applicable in the marine environment. These recording and reporting requirements are listed in 29 CFR 1904 which applies to all employers who are covered by the OSH ACT. Also see the AWO Safety Statistics Instruction Manual.

9.1.1 Are there written procedures for reporting personal injuries as required by the USCG? (RCP II-A-4a)

The company’s written procedures for reporting personal injuries must include instruction for reporting to the USCG when applicable and should include a definition of what is reportable. In some cases the company may expect vessel employees to report directly to the USCG. In other cases, the company may expect vessel employees to report all incidents to the office and have office personnel assigned to make the reports to the USCG. Either way, the written procedures should clearly define the responsibilities for reporting.

See 46 CFR 4.03-2, 4.05-1, 4.05-5, 4.05-10, & 4.05-12 for USCG regulations addressing personal injury reporting requirements. See also 33 CFR 160.204 & 160.215 for requirements addressing reporting of hazardous conditions.


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9.1.2 Is a routing list or communication flow chart present? (RCP II-A-4a)

The company’s written procedures for reporting personal injuries must include a routing list or communications flow chart or matrix which identifies persons making required reports. The routing list or flow chart should also include the types of injuries and/or illnesses required to be reported and should outline the timeframe specified by the regulatory agencies for making these reports.

9.1.3 Are the responsibilities for reporting personal injury clearly defined for vessel crew as well as shore-side personnel? (RCP II-A-4a)

The company’s written procedures for reporting personal injuries must clearly define reporting responsibilities for vessel crew as well as shore-side personnel. Shore-side personnel includes both office and dockside personnel.

9.1.4 If applicable, are there written records to demonstrate compliance with the procedure(s) listed in 9.1-9.1.3? (II-A-4a)

If the company has had a reportable personal injury, the company must show written records or other documentation to verify compliance with its personal injury reporting procedure.

9.1.5 Is the personal injury reporting procedures consistent with emergency response procedures? (RCP II-A-4a) (RCP II-F-1)

The company’s written procedures for reporting personal injuries must be consistent with emergency response procedures. Some companies combine the reporting requirements with their response procedures, while others provide separate procedures to address reporting requirements. In either case, it is important that the response procedures contain sufficient detail to ensure that reports are made in accordance with regulatory requirements.

9.2 Does the company have written procedures addressing Oil and/or Hazardous Substance Spill Reporting? (RCP II-A-4b)

The company must have one or more written procedures which address the company’s expectations for oil and/or hazardous spill reporting. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. See RCP Expectation comments and guidance regarding reporting in 9.1, above.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12 & 46 CFR 16.240 for USCG regulations addressing oil or hazardous substance spill reporting requirements. See also 33 CFR 160.204 & 160.215 for requirements addressing reporting of hazardous conditions.


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9.2.1 Are there written procedures for reporting oil/hazardous substance spills? (RCP II-A-4b)

The company’s written procedures for reporting oil and/or hazardous substance spills must include instruction for reporting, such as what is reportable, who is responsible for making the report, to whom the report is to be made, and the required timeframe allowed after the incident for the report to be made. In most cases, both verbal and written reports are required to be submitted to the USCG and in some cases, to state and federal agencies.


9.2.2 Are the responsibilities for reporting oil or hazardous substance spills clearly defined for vessel crew as well as shore-side personnel? (RCP II-A-4b)

The company’s written procedures for reporting oil and/or hazardous substance spills must clearly define reporting responsibilities for vessel crew as well as shore-side personnel. Shore-side personnel includes both office and dockside personnel. In some cases the company may expect vessel employees to report directly to the USCG. In other cases, the company may expect vessel and shore-side employees to report all incidents to the office and has office personnel assigned to make the reports to the USCG. Either way, the written procedures must should clearly define the responsibilities for reporting.


9.2.3 Is an explanation of procedures for reporting oil or hazardous substance spills available to the vessel crew? (RCP II-A-4b)

The company’s written procedures for reporting oil and/or hazardous substances spills must be readily available to vessel crew and easily understood.

9.2.4 Is a routing list or communications flow chart available? (RCP II-A-4b)

The company’s written procedures for reporting oil and/or hazardous substance spills must include a routing list or communications flow chart. The routing list or flow chart should also include the types of incidents required to be reported and should outline the timeframe specified by the regulatory agencies for making these reports.

9.2.5 Are oil and/or hazardous substance spill reporting criteria easily accessible? (RCP II-A-4b)

The company’s written procedures for reporting oil and/or hazardous substance spills must be easily accessible to vessel crew as well as shore-side personnel who are expected to make these reports. Shore-side personnel includes both office and dockside personnel.


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9.2.6 If applicable, are there written records to demonstrate compliance with the procedure(s) listed in 9.2-9.2.5? (II-A-4b)

If the company has had an oil or hazardous substance spill, the company must show written records or other documentation to verify compliance with its oil and hazardous substance spills reporting procedure.

9.2.7 Are spill reporting procedures consistent with spill emergency response procedures? (RCP II-A-4b) (RCP II-F-2)

The company’s written procedures for reporting oil and/or hazardous substance spills must be consistent with emergency response procedures. Some companies combine the reporting requirements with their response procedures, while others provide separate procedures to address reporting requirements. In either case, it is important that the response procedures contain sufficient detail to ensure that reports are made in accordance with regulatory requirements.

9.3 Does the company have written procedures addressing Vessel Accident Reporting? (RCP II-A-4c)

The company must have one or more written procedures which address the company’s expectations for reporting vessel accidents. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. See RCP Expectation comments and guidance regarding reporting in 9.1, above.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12 & 46 CFR 16.240 for USCG regulations addressing vessel casualties reporting requirements. See also 33 CFR 160.204 & 160.215 for requirements addressing reporting of hazardous conditions.

9.3.1 Are there written procedures for reporting vessel casualties as required by the USCG? (RCP II-A-4c)

The company’s written procedures for reporting vessel casualties must include instruction for reporting to the USCG when applicable, and should include a definition of what is reportable. In some cases the company may expect vessel employees to report directly to the USCG. In other cases, the company may expect vessel and shore-side employees to report all incidents to the office and has office personnel assigned to make the reports to the USCG. Shore-side personnel includes both office and dockside personnel. Either way, the written procedures should clearly define the responsibilities for reporting.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12, 4.05-20 & 46 CFR 16.240 for USCG regulations addressing vessel casualties reporting requirements. See also 33 CFR 160.204 & 160.215 for requirements addressing reporting of hazardous conditions.


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9.3.2 Are the responsibilities for vessel accident reporting clearly defined for vessel crew as well as shore-side personnel? (RCP II-A-4c)

The company’s written procedures for reporting vessel casualties must clearly define reporting responsibilities for vessel crew as well as shore-side personnel. In some cases the company may expect vessel employees to report directly to the USCG. In other cases, the company may expect vessel employees to report all incidents to the office and has office personnel assigned to make the reports to the USCG. Shore-side personnel includes both office and dockside personnel. Either way, the written procedures should clearly define the responsibilities for reporting.

9.3.3 Is a listing of all reportable vessel accidents available? (RCP II-A-4c)

The company’s written procedures for reporting vessel casualties must include a listing of all reportable vessel accidents. Some companies choose to display their reporting requirements in the form of written text that is provided within their reporting procedure(s). Other companies may choose to use a flow chart for this purpose (See 9.3.4).

9.3.4 Is a routing list or communication flow chart available? (RCP II-A-4c)

The company’s written procedure for reporting vessel casualties must include a routing list or communications flow chart. Some companies choose to display their reporting requirements in the form of a flow chart. Other companies may choose to use text that is written in to their reporting procedure(s) (See 9.3.3).

9.3.5 Are vessel accident reporting criteria easily accessible? (RCP II-A-4c)

The company’s written procedures for reporting vessel casualties must be easily accessible to vessel crew and office personnel who are expected to make the required reports.

9.3.6 If applicable, are there written records to demonstrate compliance with the procedure(s) listed in 9.3-9.3.5? (II-A-4c)

If the company has had a vessel accident, the company must show written records or other documentation to verify compliance with its vessel accident reporting procedure.


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9.3.7 Are vessel accident reporting procedures consistent with vessel accident emergency response procedures? (RCP II-A-4c) (RCP II-F-3)

The company’s written procedures for reporting vessel casualties must be consistent with emergency response procedures. Some companies combine the reporting requirements with their response procedures, while others provide separate procedures to address reporting requirements. In either case, it is important that the response procedures contain sufficient detail to ensure that reports are made in accordance with regulatory requirements.

9.4 Does the company have written procedures addressing Bridge, Lock or Dock Allision Reporting? (RCP II-A-4d)

The company must have one or more written procedures which address the company’s expectations for reporting bridge, lock or dock allisions. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. See RCP Expectation comments and guidance regarding reporting in 9.1, above.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12 & 46 CFR 16.240 for USCG regulations addressing bridge, lock or dock allision reporting requirements. See also 33 CFR 160.204 & 160.215 for requirements addressing reporting of hazardous conditions.

9.4.1 Are there written procedures for reporting bridge, lock, or dock allisions as required by the USCG? (RCP II-A-4d)

The company’s written procedures for reporting bridge, lock or dock allisions must include instruction for reporting to the USCG when applicable, and should include a definition of what is reportable.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12 & 46 CFR 16.240 for USCG regulations addressing bridge, lock or dock allision reporting requirements. See also 33 CFR 160.204 & 160.215 for requirements addressing reporting of hazardous conditions.

9.4.2 Are the responsibilities for reporting bridge, lock, or dock allisions clearly defined for vessel crew as well as shore-side and office personnel? (RCP II-A-4d)

The company’s written procedures for reporting bridge, lock or dock allisions must clearly define reporting responsibilities for vessel crew as well as shore-side and office personnel who are expected to make these reports.


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9.4.3 Is a routing list or communication flow chart available? (RCP II-A-4d)

The company’s written procedure for reporting bridge, lock or dock allisions must include a routing list or communications flow chart. Some companies choose to display their reporting requirements in the form of a flow chart. Other companies may choose to use written text that is provided within their reporting procedure(s).

9.4.4 Are reporting criteria for bridge, lock or dock allisions easily accessible? (RCP II-A-4d)

The company’s written procedures for reporting bridge, lock or dock allisions must be easily accessible to vessel crew and office personnel who are expected to make these reports.

9.4.5 If applicable, are there written records to demonstrate compliance with the procedure(s) listed in 9.4-9.4.4? (II-A-4d)

If the company has had a bridge, lock or dock allision, the company must show written records or other documentation to verify compliance with its bridge, lock or dock allision reporting procedure.

9.4.6 Are reporting procedures for bridge, lock or dock allisions consistent with vessel emergency response procedures? (RCP II-A-4d) (RCP II-F-3)

The company’s written procedures for reporting bridge, lock or dock allisions must be consistent with emergency response procedures. Some companies combine the reporting requirements with their response procedures, while others provide separate procedures to address reporting requirements. In either case, it is important that the response procedures contain sufficient detail to ensure that reports are made in accordance with regulatory requirements.

9.5 Does the company have written procedures addressing Reporting of Groundings? (RCP II-A-4e)

The company must have one or more written procedures which address the company’s expectations for reporting groundings. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. See RCP Expectation comments and guidance regarding reporting in 9.1, above.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12 & 46 CFR 16.240 for USCG regulations addressing reporting requirements for groundings. See also 33 CFR 160.204 & 160.215 and USCG NVIC 1-15 for requirements addressing reporting of hazardous conditions.


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9.5.1 Are there written procedures for reporting groundings as required by the USCG? (RCP II-A-4e)

The company’s written procedures for reporting groundings must include instruction for reporting to the USCG when applicable, and should include a definition of what is reportable.

See 46 CFR 4.03-2, 4.03-65, 4.05-1, 4.05-5, 4.05-10, 4.05-12 & 46 CFR 16.240 for USCG regulations addressing reporting requirements for groundings. See also 33 CFR 160.204 & 160.215 and USCG NVIC 1-15 for requirements addressing reporting of hazardous conditions.

9.5.1

9.5.2

Are the responsibilities for reporting groundings clearly defined for vessel crew and office personnel? (RCP II-A-4e)

The company’s written procedures for reporting groundings must clearly define reporting responsibilities for vessel crew and office personnel who are expected to make these reports.

9.5.2

9.5.3

Is a routing list or communication flow chart available? (RCP II-A-4e)

The company’s written procedure for reporting groundings must include a routing list or communications flow chart. Some companies choose to display their reporting requirements in the form of a flow chart. Other companies may choose to use text that is written in to their reporting procedure(s).

A flow chart or the text document should include both shoreside and vessel personnel.

9.5.3

9.5.4

Are reporting criteria for groundings easily accessible? (RCP II-A-4e)

The company’s written procedures for reporting groundings must be easily accessible to vessel crew and office personnel.

9.5.4

9.5.5

If applicable, are there written records to demonstrate compliance with the procedure(s) listed in 9.5-9.5.4? (II-A-4e)

If the company has had a reportable grounding, the company must show written records or other documentation to verify compliance with its grounding reporting procedure.


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9.5.5

9.5.6

Are reporting procedures for groundings consistent with vessel emergency response procedures? (RCP II-F-3) (RCP II-A-4e)

The company’s written procedures for reporting groundings must be consistent with emergency response procedures. Some companies combine the reporting requirements with their response procedures, while others provide separate procedures to address reporting requirements. In either case, it is important that the response procedures contain sufficient detail to ensure that reports are made in accordance with regulatory requirements.

9.6 Does the company have written procedures addressing other company-specific incident reporting policies and procedures? (RCP II-A-4f)

If the company has one or more additional written procedures for reporting of specified incidents that are not required to be reported by RCP or federal regulations, the procedures must satisfy the RCP definition for a written procedure. See RCP Expectation comments and guidance regarding reporting in 9.1, above.

9.6.1 Are the responsibilities for company-specific incident reporting clearly defined for vessel crew and office personnel? (RCP II-A-4f)

The company’s written procedures for company-specific incident reporting must clearly define reporting responsibilities for vessel crew and office personnel.

9.6.2 Is a list of these types of company-specific reportable incidents available? (RCP II-A-4f)

The company’s written procedures for company-specific incident reporting must include the types of incidents required to be reported.

9.6.3 Is a routing list or communication flow chart available? (RCP II-A-4f)

The company’s written procedure for company-specific incident reporting must include a routing list or communications flow chart. Some companies choose to display their reporting requirements in the form of a flow chart. Other companies may choose to use written text that is provided within their reporting procedure(s).


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9.6.4 If applicable, are there written records to demonstrate compliance with the procedure(s) listed in 9.6-9.6.3? (II-A-4f)

If the company has had other incidents defined in their company-specific incidents reporting policies and procedures, the company must show written records or other documentation to verify compliance with its policies or procedure.

9.7 Are the responsibilities for incident investigation clearly assigned? (RCP II-A-4)

The company’s written procedures must clearly assign responsibilities for incident investigation for vessel crew as well as shore-side and office personnel. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure.

9.8 Are written procedures for incident investigation and review clearly defined? (RCP II-A-4)

The company’s written procedures for incident investigation and review must be clearly defined. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. In some cases, the company may choose to delegate the investigation to a third-party. If that is the case, the written procedure must clearly describe the process for making the determination as to which incidents would be delegated and what type of third-party would be selected for a particular incident.

9.8.1 Does the incident investigation take place in accordance with the company’s written procedure(s)? (RCP II-A-4)

The company’s written procedures must require the incident investigation to take place in a timely fashion. The company’s written procedures must specify the amount of time that is to be allowed for initiating the investigation.

9.8.2 Is a detailed investigation report prepared after the investigation is conducted? (RCP II-A-4)

The company’s written procedures must require a written report of the investigation be prepared after the investigation is conducted.

9.8.3 Do written investigation procedures address:


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9.8.3.1 Do written investigation procedures address personal injury? (RCP II-A-4a)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company’s written investigation procedures must clearly describe the company’s expectations for the conduct of personal injury investigations.

9.8.3.2 Do written investigation procedures address spills? (RCP II-A-4b)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company’s written investigation procedures must clearly describe the company’s expectations for the conduct of oil or hazardous substance spill investigations.

9.8.3.3 Do written investigation procedures address all other identified types of vessel accidents? (RCP II-A-4c)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company’s written investigation procedures must clearly describe the company’s expectations for the conduct of all other identified types of vessel accident investigations.

9.8.3.4 Do written investigation procedures address bridge, lock or dock allision? (RCP II-A-4d)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company’s written investigation procedures must clearly describe the company’s expectations for the conduct of bridge, lock or dock allision investigations.

9.8.3.5 Do written investigation procedures address grounding? (RCP II-A-4e)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company’s written investigation procedures must clearly describe the company’s expectations for the conduct of grounding investigations.

9.8.3.6 Does the company have any other company specific incident investigation procedures? (RCP II-A-4f)

If the company identifies any other investigation procedures, there must be written records to demonstrate compliance.

Examples of “other company-specific procedures” include equipment failures, suspicious activity, unidentified cargoes, dry cargo spillage, personnel issues, and loss of steering.


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9.8.3.7 If applicable, are there written records to demonstrate compliance with the procedure(s) listed in 9.8.3? (RCP II-A-4a, -4b, -4c, -4d, -4e, -4f)

If applicable, the company must show written records to verify compliance with its investigation requirement.

9.9 Are investigation results used to formulate lessons learned? (RCP II-A-6d)

The company’s written investigation procedures must clearly describe the company’s expectations for how the investigation results should be used to formulate lessons learned.

9.9.1 Are lessons learned communicated throughout the organization? (RCP II-A-6d)

The company’s written investigation procedures must clearly describe the company’s expectations for how lessons learned are to be communicated throughout the organization.

9.10 Near-Miss Procedures:

9.10 (a) Does the company have near-miss procedures which address near-miss reporting? (RCP II-A-5)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company must have written procedures which address the company’s expectations for reporting of near miss incidents.

Additional components of a Near Miss Program might include: responsibilities for near miss investigations, root cause analysis, preventive and corrective actions, lessons learned reports and communications, timelines established for actions and completion, timely notifications, training for employees and investigations, breaches of policy violations identified, and/or inspections following near miss incidents.


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9.10 (b) Are there written records to demonstrate compliance with the procedure(s) listed in 9.10 (a)? (RCP II-A-5)

The company must show written records to verify compliance with the requirement.

9.11 (a) Does the company have procedures describing how near-miss report information is incorporated into future risk management assessments, as appropriate? (RCP II-A-1b) (RCP II-A-5)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company must have written procedures that must include an explanation of the company’s expectation for how near miss information is incorporated into future risk assessments.

9.11 (b) Are there written records to demonstrate compliance with the procedures listed in 9.11 (a)? (RCP II-A-1b) (RCP II-A-5)


9.12 (a) Does the company have near-miss procedures which address near-miss investigation? (RCP II-A-5)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company’s written procedures must include all other company expectations for investigations of near miss reports.

9.12 (b) Are there written records to demonstrate compliance with the procedure listed in 9.12 (a)? (RCP II-A-5)


9.13 (a) Does the company have near-miss procedures which address near-miss corrective action? (RCP II-A-5)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company must have written procedures that include how corrective actions are generated and addressed from near miss investigation information.


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9.13 (b) Does the company have near-miss procedures which address near-miss preventive action? (RCP II-A-5)

For a compliant answer, the procedures must satisfy the RCP definition for a written procedure. The company must have written procedures that include how preventive actions are generated and addressed from near-miss investigation information.

9.13 (c) Are there written records to demonstrate compliance with the procedure(s) in 9.13 (a) and (b)? (RCP II-A-5)



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SECTION 10 – VESSEL MAINTENANCE TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

10.1 Does a written vessel maintenance program exist within the company? (RCP II-B-7)

The written vessel maintenance program must satisfy the RCP definition for a written program and must address all the required components contained in this section.

Vessel Maintenance Program Components

10.2.1 (a) Does the written vessel maintenance program identify a designated person responsible for overall vessel maintenance? (RCP II-B-7a)

The written vessel maintenance program must contain one or more written procedures which identify, by name or position, a designated management person responsible for overseeing vessel maintenance.

10.2.1 (b) Does the written vessel maintenance program identify a designated person responsible for onboard vessel maintenance? (RCP II-B-7a)

The written vessel maintenance program must contain one or more written procedures which identify, by position, designated personnel who are responsible for conducting onboard vessel maintenance.


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10.2.2 Does the written vessel maintenance program include written procedures for the performance of scheduled maintenance? (RCP II-B-7b)

The written vessel maintenance program must include written procedures, which satisfy the RCP definition for a written procedure, for the performance of scheduled vessel maintenance. Written procedures which address scheduled maintenance should include both periodic preventive maintenance and maintenance work that is scheduled for a later date, such as at the next drydocking or repair yard visit. This should address maintenance conducted by company personnel as well as third party vendors, if used. For the company to be in compliance, procedures must satisfy the definition for Scheduled Maintenance: A system of periodic maintenance of or service to equipment intended to preserve or restore reliability of operation and prevent equipment failure. Scheduled maintenance activities are generally applied based on some interval of time: hours of operation, daily, weekly monthly, etc. Scheduled maintenance could include but is not limited to: tests, measurements, adjustments, lubrication or parts replacement. Scheduled maintenance could occur as reactive maintenance rather than planned maintenance should indicators develop requiring unplanned maintenance to correct the defect identified by the indicator factor; e.g., add water as a result of a low day/expansion tank level alarm.


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10.2.3 Does the written vessel maintenance program specify requirements for the qualifications and training of the persons in charge of onboard vessel maintenance? (RCP II-B-7c)

The written vessel maintenance program must specify requirements for the qualifications and training of the persons in charge of onboard vessel maintenance. Examples of qualifiers that companies often utilize are formal education and/or training, employee job descriptions, employee development program criteria, initial and refresher training appropriate to the employee’s job position, years of experience in a specific position, etc. as a means of establishing these qualifications for both management and vessel maintenance personnel. In the case of vessel maintenance employees, training requirements should address specific job related tasks that are to be conducted during regularly scheduled maintenance and emergency repairs typically conducted onboard vessels.

10.2.4 Does the written vessel maintenance program include written procedures for correcting deficiencies identified during maintenance? (RCP II-B-7d)

The written vessel maintenance program must include one or more written procedures, which satisfy the RCP definition for a written procedure, for correcting deficiencies identified during vessel maintenance. Some companies treat this as a part of their formal corrective action program and utilize that format for identifying deficiencies, accomplishing corrective action and maintenance of written records. Other companies provide written instructions for making specific repairs that are typically encountered during maintenance, while other companies utilize maintenance manuals provided by equipment manufacturers as guidelines for making these types of repairs. Regardless of the method used, the company should provide sufficient detail so that employees can be successful at meeting the company’s expectations.

10.2.5 Does the written vessel maintenance program include a written policy or procedure regarding the retention of maintenance records? (RCP II-B-7e)

The written vessel maintenance program must include a written policy or procedure regarding the retention of vessel maintenance records which also satisfies the RCP definition for a policy or procedure. The policy/procedure provided must contain sufficient details as necessary to describe the company’s expectations.

The company’s expectations could include information such as the condition of the equipment or machinery at the time of maintenance, what adjustments and/or repairs were conducted, what parts were replaced, etc.


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10.2.6 (a) Do the company’s written vessel maintenance procedures include conducting a risk assessment and obtaining required approvals before critical equipment or systems identified by RCP II-B-6 are shut down for maintenance? (RCP II-B-7f) (RCP II-A-1)

The written vessel maintenance program must include a written procedure identifying the risk assessment undertaken and required approvals needed before critical equipment or systems are shut down for maintenance, which also satisfies the RCP definition for a procedure.

The procedure should recognize the time sensitive nature for making these decisions in the field, and whether it is a ship-board decision or long term maintenance decision. See also question 7.21 regarding the identification of critical equipment or systems, and for suggested examples.

10.2.6 (b) Are there written records to demonstrate compliance with the procedures listed in 10.2.6(a)? (RCP II-B-7f) (RCP II-A-1)

The company must provide written records to demonstrate compliance with the requirement.

10.2.7 (a) Do the company’s written procedures include conducting a risk assessment and obtaining required approvals before critical equipment or systems identified by RCP II-B-6 are bypassed for maintenance? (RCP II-B-7f) (RCP II-A-1)

The written vessel maintenance program must include a written procedure identifying the risk assessment undertaken and required approvals needed before critical equipment or system are bypassed for maintenance, which also satisfies the RCP definition for a procedure.

The procedure should recognize the time sensitive nature for making these decisions in the field, and whether it is a ship-board decision or long term maintenance decision. Redundant systems could be used when a main system needs to be taken down for maintenance.

10.2.7 (b) Are there written records to demonstrate compliance with the procedures listed in 10.2.7 (a)? (RCP II-B-7f) (RCP II-A-1)



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10.2.8 (a) Do the company’s written procedures include conducting a risk assessment and obtaining required approvals before critical equipment or systems identified by RCP II-B-6 are taken out of service for maintenance? (RCP II-B-7f) (RCP II-A-1)

The written vessel maintenance program must include a written procedure identifying the risk assessment undertaken and required approvals needed before critical equipment or systems are taken out of service for maintenance, which also satisfies the RCP definition for a procedure.

The procedure should recognize the time sensitive nature for making these decisions in the field, and whether it is a ship-board decision or long term maintenance decision.

10.2.8 (b) Are there written records to demonstrate compliance with the procedures listed in 10.2.8 (a)? (RCP II-B-7f) (RCP II-A-1)


10.3 Is there a policy and/or procedure concerning drydocking or routine hull inspections? (RCP III-A-1) (RCP IV-A-1)

The written vessel maintenance program must include a written policy or one or more procedures which satisfy the RCP definition for a policy or procedure, and which specifies the minimum requirements for drydocking and/or routine hull inspections, and recordkeeping requirements.

As a guideline, written inspection programs which utilize written checklists should be implemented by a written inspection procedure that satisfies the RCP definition for a procedure, and at a minimum should outline the company’s expectation for how the inspection is to be conducted, identify the person or persons responsible for conducting the inspection, list the areas of the vessel to be inspected, describe the corrective action process that is to be used to correct deficiencies, and specify the record keeping process that is to be used to maintain evidence of the results of the inspection and of the inspection having been accomplished. Written checklists should contain a list of items and/or areas to be inspected and should provide sufficient detail for each item as necessary to ensure the inspector is able to identify issues and/or conditions which indicate a deficiency in accordance with the company’s expectations.


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10.3.1 Does the policy and/or procedure concerning drydocking or routine hull inspections provide for a maximum 36-month drydock period? (RCP III-A-1) (RCP IV-A-1a)

Except for vessels which are specifically engaged in the coastal harbor services trade and/or the coastal/ocean towing services trade, written vessel maintenance program’s policies and/or procedure(s) which specify the minimum requirements for drydocking and/or routine hull inspections must include a written requirement which provides for a maximum 36-month interval between drydockings. (For vessels engaged in the coastal harbor services trade, see question 10.3.2, below.)

10.3.2 (a)

For coastal harbor services, does the policy provide for a minimum drydock period once every 5 years with a mid-term underwater inspection between the 24th and 36th months? (RCP IV-A-1b)

For vessels in coastal harbor services (i.e. not beyond the boundary line), the written vessel maintenance program’s policy and/or procedure(s) which specify the minimum requirements for drydocking and/or routine hull inspections must include a written requirement which provides for a maximum five-year interval between drydockings and a mid-term underwater inspection between the 24th and 36th months.

10.3.2 (b)

For coastal/ocean towing vessels, does the policy provide for a minimum drydock period once every 5 years with a mid-term underwater inspection between the 24th and 36th months? (RCP IV-A-1b)

For vessels in coastal/ocean towing services (i.e. beyond the boundary line), the written vessel maintenance program’s policy and/or procedure(s) which specify the minimum requirements for drydocking and/or routine hull inspections must include a written requirement which provides for a maximum five-year interval between drydockings and a mid-term underwater inspection between the 24th and 36th months.

For information regarding towing vessels that are required to be inspected by the USCG, see 46 CFR 91.40. Also see Volume II of the USCG Marine Safety Manual for additional information concerning inspected towing vessels.

10.3.3 For coastal/ocean towing vessels, does the policy provide for hull gaugings and ballast tank inspections? (RCP IV-A-2)

For vessels in coastal/ocean towing services (i.e. beyond the boundary line), the written vessel maintenance program’s policy and/or procedure(s) which specify the minimum requirements for drydocking and/or routine hull inspections must include a written requirement which provides for a maximum five-year interval between hull gaugings and a maximum 36-month interval between inspections for ballast tanks and void compartments.

See Additional Information comments regarding written inspection programs in 10.3, above.


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10.4 Is there a written policy and/or procedure concerning inspection of watertight closures (doors, hatches, airports, windows, etc.)? (RCP III-A-2) (RCP IV-A-3)

The written vessel maintenance program must include a written policy and/or one or more procedures which satisfy the RCP definition for a policy or procedure, and which specifically addresses inspection of watertight closures including doors, hatches, airports, windows, etc. Inspection checklists should contain detailed instructions as necessary to ensure the results of the inspection will meet the company’s expectations regarding how the vessel is to be maintained. Each item on a checklist should describe the company’s expectation for that item (i.e., what to look at, what to look for, etc.).


10.4.1 If vessels have watertight closures, is there a written policy requiring annual inspection, with particular attention to deck or freeboard closures? (RCP III-A-2) (RCP IV-A-3)

The written policy and/or procedure(s) which address inspection of watertight closures must require at least annual inspections, with particular attention to deck or freeboard closures. Inspection checklists should contain detailed instructions as necessary to ensure the results of the inspection will meet the company’s expectations regarding how the vessel is to be maintained. Each item on a checklist should describe the company’s expectation for that item (i.e., what to look at, what to look for, etc.).


10.4.2 Is there a written policy requiring annual inspections of other openings (ventilators, air pipes, tank vents, etc.) for water or weather tightness and structural integrity? (RCP III-A-3) (RCP IV-A-4)

The written policy and/or procedure(s) which address inspection of watertight closures must require at least annual inspections of other openings including ventilators, air pipes, tank vents, etc. for weather tightness and structural integrity. Inspection checklists should contain detailed instructions as necessary to ensure the results of the inspection will meet the company’s expectations regarding how the vessel is to be maintained. Each item on a checklist should describe the company’s expectation for that item (i.e., what to look at, what to look for, etc.).



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10.4.3 Are these inspections documented? (RCP II)

The written policy and/or procedure(s) which address inspection of all watertight closures in 10.3 through 10.3.2 must provide for written documentation of all formal inspections. Documentation could include information such as the condition found at the time of inspection, what adjustments and/or repairs were conducted, what parts were replaced, etc.


10.5 Is there a policy requiring annual inspection of:

10.5.1 Is there a written policy requiring annual inspection of rails, ladders, bulwarks, lighting, walking surfaces, guard chains, safety chains and handrails for wastage, weakness and personnel safety considerations? (RCP III-A-4a) (RCP IV-A-5)

The written vessel maintenance program must include a written policy and/or one or more procedures which satisfy the RCP definition for a policy or procedure, and which specifically addresses inspection of rails, ladders, bulwarks, lighting, walking surfaces, guard chains, safety chains and handrails for wastage, weakness and personal safety considerations at least annually. Inspection checklists should contain detailed instructions as necessary to ensure the results of the inspection will meet the company’s expectations regarding how the vessel is to be maintained. Each item on a checklist should describe the company’s expectation for that item (i.e., what to look at, what to look for, etc.).



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10.5.2 Is there a written policy requiring annual inspection of guard chains or safety chains (if equipped) along the outboard sides of the main deck? (RCP III-A-4b)

For vessels equipped with safety/guard chains, the written vessel maintenance program must include a written policy and/or one or more procedures which satisfy the RCP definition for a policy or procedure, and which specifically address inspection of guard chains or safety chains along the outboard sides of the main deck at least annually. Inspection checklists should contain detailed instructions as necessary to ensure the results of the inspection will meet the company’s expectations regarding how the vessel is to be maintained. Each item on a checklist should describe the company’s expectation for that item (i.e., what to look at, what to look for, etc.).

See Additional Information comments regarding written inspection programs in 10.3, above. The kind of fall overboard protection used may vary between vessels; guard chains, safety chains, ropes or cables may all be used for this purpose.


The written policy and/or procedure(s) which address inspection of rails, ladders, bulwarks, lighting, walking surfaces, guard chains, safety chains and handrails must provide for written documentation of all these inspections. Documentation could include information such as the condition found at the time of inspection, what adjustments and/or repairs were conducted, what parts were replaced, etc.


10.6 Is there a written policy requiring annual inspection of emergency walkways and hatchways? (RCP III-A-5) (RCP IV-A-6)

For vessels equipped with emergency walkways and hatchways, the written vessel maintenance program must include a written policy and/or one or more procedures which satisfy the RCP definition for a policy or procedure, and which specifically address inspection of emergency walkways and hatchways at least annually. Inspection checklists should contain detailed instructions as necessary to ensure the results of the inspection will meet the company’s expectations regarding how the vessel is to be maintained. Each item on a checklist should describe the company’s expectation for that item (i.e., what to look at, what to look for, etc.).



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The written policy and/or procedure(s) which address inspection of emergency walkways and hatchways must provide for written documentation of inspections which provides evidence that the inspections were completed in accordance with the company’s written requirements. Documentation could include information such as the condition found at the time of inspection, what adjustments and/or repairs were conducted, what parts were replaced, etc.


10.7 Is there a written policy regarding the use of piping diagrams and the marking of piping systems (color coding, numbering, lettering, etc.)? (RCP III-A-6a) (RCP IV-A-8a)

The written vessel maintenance program must include a written policy and/or one or more procedures which satisfy the RCP definition for a policy or procedure, and which address the use of piping diagrams and the marking of piping systems (by color coding, numbering, lettering, etc.), and defining what piping systems are to be included. The RCP states that “piping diagrams should be kept aboard the vessel” and for all towing vessels that have a capacity for more than 250 barrels or 10,500 gallons of oils onboard, the USCG also requires diagrams for all piping used in oil transfer operations to be provided onboard the vessel. For vessels that are less than 250 barrels or 10,500 gallons of capacity of oils onboard, there is no USCG requirement that addresses piping diagrams, but the RCP has a requirement for vessels to use piping diagrams. The auditor should check if the company has a process to ensure that piping diagrams and markings are modified and kept up to date whenever any changes are made to the piping systems onboard a vessel.

See 33 CFR 155.750(a)(2). While some companies state that the presence of piping diagrams required by 33 CFR 155.750(a)(2) fulfills this requirement, other companies may provide piping diagrams for all piping that is found onboard the vessel. Most newer vessels were equipped with piping diagrams, but many older vessels, especially those constructed in smaller shipyards, did not have original drawings or diagrams, or in some cases, previously provided diagrams were not updated or have been lost or misplaced.


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10.7.1 Are piping diagrams kept aboard the vessel? (RCP III-A-6a) (RCP IV-A-8a)

The written policy and/or procedure(s) which address the use of piping diagrams and the marking of piping systems must provide for keeping piping diagrams aboard the vessel. For more information regarding the use of piping diagrams, refer to information concerning RCP expectation in question 10.7, above and 33 CFR 155.750(a)(2). The auditor should check if the company has a process to ensure that the piping diagrams onboard each vessel are updated whenever any changes are made to the vessel’s piping systems.

See 33 CFR 155.750(a)(2).

10.7.2 Is there a written policy requiring annual inspection of piping systems and tanks? (RCP III-A-6b) (RCP IV-A-8b)

The written vessel maintenance program must include a written policy and/or one or more procedures which satisfy the RCP definition for a policy or procedure, and which specifically addresses inspection of piping systems and tanks at least annually. Inspection checklists should contain detailed instructions as necessary to ensure the results of the inspection will meet the company’s expectations regarding how the vessel is to be maintained. Each item on a checklist should describe the company’s expectation for that item (i.e., what to look at, what to look for, etc.). This should include a check that the onboard piping diagrams are accurate to the actual piping systems and tanks. The written policy and/or procedure(s) which address annual inspection of piping systems and tanks should provide for written documentation of inspections having been conducted, should provide evidence of the results of these inspections and should document that the inspections were completed in accordance with company requirements.

See Additional Information comments regarding written inspection programs in 10.3, above. While there are currently no requirements for what is to be inspected, examples may include:

• Availability of a piping system diagram

• Accuracy of the piping system diagram

• Correct application of piping color coding per the posted piping color code chart

• System leaks or wastage (apply special attention to piping with thru hull fittings below the waterline)

• Application of chafing gear where needed

• Valve operation, missing or broken valve operating handles

• MSD system overboard bypass secured

• Proper application of any required lock out/tag out devices


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10.7.3 Are these inspections of piping systems and tanks documented? (RCP II)

The written policy and/or procedure(s) which address inspection of piping systems and tanks must provide for written documentation of inspections which provides evidence that the inspections were completed in accordance with the company’s written requirements. Documentation could include information such as the condition found at the time of inspection, what adjustments and/or repairs were conducted, what parts were replaced, what markings or diagram updates were made, etc.


10.8 Is there a policy requiring annual inspection of freeing ports and scuppers (if applicable) while underway to note satisfactory drainage of the main deck for seaworthiness? (RCP III-A-7) (RCP IV-A-7)

For vessels equipped with freeing ports and/or scuppers, the written vessel maintenance program must include a written policy and/or one or more procedures which satisfy the RCP definition for a policy or procedure, and which specifically addresses the inspection of freeing ports and scuppers while underway to note satisfactory drainage of the main deck for seaworthiness at least annually. The written policy and/or procedure(s) which address inspection of freeing ports and scuppers should provide written documentation of inspections having been conducted, should provide evidence of the results of these inspections and should document that the inspections were completed in accordance with company requirements.


10.8.1 Are these inspections of freeing ports and scuppers (if applicable) documented? (RCP II)

The written policy and/or procedure(s) which address inspection of freeing ports and scuppers must provide for written documentation of inspections having been conducted and should provide evidence that the inspections were completed in accordance with the company’s written requirements. Documentation could include information such as the condition found at the time of inspection, what adjustments and/or repairs were conducted, what parts were replaced, etc.


10.9 Does the company vessel maintenance program cover the following components: (RCP III-B-1) (RCP IV-B-1)


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10.9.1 Does the company vessel maintenance program cover all major propulsion machinery, including main engines, reduction gears, clutches, controls, shafting, bearings, and other items prone to wear? (RCP III-B-1a) (RCP IV-B-1a)

The company’s vessel maintenance program must satisfy the RCP definition for a program, which incorporates written procedures satisfying the RCP definition for written procedures, and must include all major propulsion machinery, including at a minimum main engines, reduction gears, clutches, controls, shafting, bearings, and other items prone to wear.

The vessel maintenance program may include, a) work instructions for each piece of major propulsion machinery/equipment, for inspections and maintenance, b) what type of inspection program should be followed for each piece of equipment (regular schedule based on date and/or hours of operation, or performance based, or predictive, etc.); c) whether reference manuals should be available; d) what inspection/maintenance records are to be maintained, etc.

10.9.2 Does the company vessel maintenance program cover all steering system components? (RCP III-B-1b) (RCP IV-B-1b)

The company’s vessel maintenance program must satisfy the RCP definition for a program, which incorporates written procedures satisfying the RCP definition for written procedures, and must include all steering system components.

10.9.3 Does the company vessel maintenance program cover miscellaneous auxiliary systems? (RCP III-B-1c) (RCP IV-B-1c)

The company’s vessel maintenance program must satisfy the RCP definition for a program, which incorporates written procedures satisfying the RCP definition for written procedures, and must include miscellaneous auxiliary systems (i.e., air compressors, packing glands, deck machinery, oily water separator (if applicable), marine sanitation device, fuel systems including shutoff valves, hydraulic systems, HVAC equipment etc.).

10.9.4 Does the company vessel maintenance program cover electrical systems, including labeling? (RCP III-B-1d) (RCP IV-B-1d)

The company’s vessel maintenance program must satisfy the RCP definition for a program, which incorporates written procedures satisfying the RCP definition for written procedures, and must include electrical systems, including generators, labeling of switches and breakers and/or the use of schematics.


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10.10 Are maintenance records kept on all systems identified above? (RCP III-B-2) (RCP IV-B-2)

The written procedure(s) which address maintenance of each of these systems must provide for written documentation of maintenance activities which provides evidence that the maintenance was completed in accordance with the company’s written requirements.

10.10.1 Is sufficient information kept to develop a program for overhauls, repairs, and preventative maintenance? (RCP III-B-2) (RCP IV-B-2)

Records must contain sufficient information to develop a program for overhauls, repairs, and preventative maintenance, and indicate critical part replacement dates and test dates. Logs must be kept indicating any maintenance or inspections performed.

The company’s written procedures could include information to be kept and may include information such as the date of maintenance, the condition found at the time of maintenance, what adjustments and/or repairs were conducted, what parts were replaced, what markings or diagram updates were made, etc.

10.10.2 Are logs kept which indicate any maintenance or inspections performed? (RCP III-B-2) (RCP IV-B-2)

Records must contain sufficient information to develop a program for overhauls, repairs, and preventative maintenance, and indicate critical part replacement dates and test dates. Logs must be kept indicating any maintenance or inspections performed.

10.11 Do company maintenance procedures include a lock-out/tag-out program? (RCP III-B-3) (RCP IV-B-3)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, which includes a lock-out/tag-out program applicable to all types of energy sources.

Additional guidance regarding lock-out/tag-out may be found in 29 CFR 1910.147.

10.12 Does the maintenance program require that guards be placed around any exposed moving parts (e.g., shafts, belts, pulleys, etc.)? (RCP III-B-4) (RCP IV-B-4)

The company must have one or more written procedures, which satisfy the RCP definition for a written procedure, requiring that guards be placed around any exposed moving parts (e.g. shafts, belts, pulleys, gears, couplings, etc.).

Additional guidance regarding machinery and machine guarding may be found in 29 CFR 1910.212.

10.13 Does the company's policy/procedure(s) require that vessels be equipped with the following alarms or require that individuals be assigned the responsibility of monitoring and documenting the following: (RCP III-B-5a) (RCP IV-B-5a)


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10.13.1 Main engine water temperature? (RCP III-B-5a-1) (RCP IV-B-5a-1)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring main engine water high-temperature alarm(s), OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each main engine water temperature. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.13.2 Main engine lube oil pressure? (RCP III-B-5a-2) (RCP IV-B-5a-2)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring main engine lube oil low-pressure alarm(s), OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each main engine lube oil pressure. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.13.3 Bilge alarm? (RCP III-B-5a-3) (RCP IV-B-5a-3)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring a bilge high-level alarm, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting the bilge level. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.


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10.13.4 Generator water temperature? (RCP III-B-5a-4) (RCP IV-B-5a-4)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring generator water high-temperature alarm(s), OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each generator water temperature. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.13.5 Generator lube oil pressure? (RCP III-B-5a-5) (RCP IV-B-5a-5)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring generator low-pressure alarm(s), OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each generator lube oil pressure. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.13.6 Hydraulic steering fluid level? (RCP III-B-5a-6) (RCP IV-B-5a-6)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring a hydraulic steering fluid low-level alarm, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting the hydraulic steering fluid level. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.13.7 General alarm audible in all compartments? (RCP III-B-5a-7) (RCP IV-B-5a-7)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring a general alarm in accordance with 46 CFR 27.201.


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10.13.8 Is the general alarm tested weekly? (RCP III-B-5a-8) (RCP IV-B-5a-8)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring weekly testing of the general alarm in accordance with 46 CFR 27.201. The results of the test must be recorded.

10.13.9 Are other alarms tested at least quarterly? (RCP III-B-5a-8) (RCP IV-B-5a-8)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring other installed alarms to be tested at least quarterly.

Additional guidance regarding fire-detection system testing may be found in 46 CFR 27.203.

10.14 Does the company's policy/procedures require that vessels be equipped with the following gauges or require that individuals be assigned the responsibility of monitoring and documenting the following: (RCP III-B-5-b) (RCP IV-B-5-b)

10.14.1 Main engine water temperature? (RCP III-B-5b-1) (RCP IV-B-5b-1)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring main engine water temperature gauge(s) at the engineer’s station or in the wheelhouse, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each main engine water temperature gauge. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.14.2 Main engine lube oil pressure? (RCP III-B-5b-2) (RCP IV-B-5b-2)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring main engine lube oil pressure gauge(s) at the engineer’s station or in the wheelhouse, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each main engine lube oil pressure gauge. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.


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10.14.3 Generator water temperature? (RCP III-B-5b-3) (RCP IV-B-5b-3)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring generator water temperature gauge(s) in the wheelhouse, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each generator water temperature gauge. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.14.4 Generator lube oil pressure? (RCP III-B-5b-4) (RCP IV-B-5b-4)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring generator lube oil pressure gauge(s) in the wheelhouse, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each generator lube oil pressure gauge. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.

10.14.5 Main engine tachometer? (RCP III-B-5b-5) (RCP IV-B-5b-5)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring main engine tachometer gauge(s) in the wheelhouse, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting each main engine tachometer gauge. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.


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10.14.6 Hydraulic steering fluid level (sight glass)? (RCP III-B-5b-6) (RCP IV-B-5b-6)

The company must have one or more written procedures or a documented process, which satisfies the RCP definition for a written procedure or a documented process, requiring a hydraulic steering fluid level sight glass, OR requiring that an individual be assigned the responsibility of regularly monitoring and documenting the hydraulic steering fluid level. If an individual is assigned, the procedure must define the individual responsible (by position) as well as the frequency of monitoring and documentation.


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SECTION 11 – AUDITING & REVIEW PROCEDURES TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

Internal Auditing

11.1 Does the company have a written internal auditing program? (RCP II-G-1)

The written internal auditing program must satisfy the RCP definition for a written program.

11.1.1 Does the internal auditing program periodically evaluate the effectiveness of the safety management system? (RCP II-G-1a-1)

The annual internal audit of the management system must include an evaluation of the effectiveness of the management system, either as a component of the internal audit or as a separate activity.

For this question, periodically means the entire system must be evaluated at least once annually, but more frequently if specified by the company.

11.1.2 Does the internal auditing program review the safety management system when needed in accordance with the established procedures of the company? (RCP II-G-1a- 2)

In addition to the RCP required annual internal audit requirement for management systems and towing vessels, the company may specify additional items or areas of the company to be audited during the internal audit process. The auditor may also audit the company’s compliance with these additions as specified in its management system.

11.1.3 (a)

Is there a method for identifying non-conformities? (RCP II-G-1a-3)

The written internal auditing program must include one or more written procedures which provide a method for identifying non-conformities that require corrective action. In other words, once non-conformities are identified, then corrective action is required. The written procedure(s) should include clear definitions of non-conformity and corrective action. It is recommended that ISO 9001, ISM or any other recognized management system standard be used as guidance.

11.1.3 (b)

Does the internal auditing program require reporting of identified non-conformities? (RCP II-G-1a- 3)

The internal auditing program must require reporting of identified non-conformities.


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11.1.4 Are deficiencies identified while conducting internal audits included in the corrective action program (see section of questions below, beginning with 11.10)? (RCP II-G-1a- 4) (RCP II-A-6)

Deficiencies identified while conducting internal audits must be included in the company’s corrective action program.

The completed corrective actions from internal audits should be included in the company’s continuous improvement program.

11.1.5 Does the internal auditing program include a management review of the internal management and vessel audit findings at least annually? (RCP II-G-1a- 5)

There must be some record of a management review meeting that covers the results of the internal audit program and the corrective actions from the identified non-conformities. This management review should be in addition to the implementation verification of each corrective action The management review should confirm the non-conformities have been appropriately closed out in a timely manner. The purpose and expected output of the management review process should be clearly defined in the written procedure(s).

Include P-D-C-A model/reference and where management review fits in as appropriate.

11.2 Are internal audits carried out annually and initiated by the anniversary date of the last internal audit for each of the company’s managing offices (all offices with management oversight of towing vessels)? (RCP II-G-1b-1)

Internal audits must be carried out annually. Each internal audit must be initiated by the anniversary date of the previous internal audit for each of the company’s managing offices.

Note: Audits may be conducted up to three months before the anniversary date of the original or previous audit and will maintain the original anniversary date.

11.3.1 Does the internal audit process specify factors for determining selection of personnel responsible for conducting internal audits, to include: qualifications for those personnel? (RCP II-G-1b-2i)

The company’s process must describe the factors to be used to determine which personnel are responsible for conducting internal audits and include qualifications for those persons conducting internal audits.


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11.3.2 Does the internal audit process specify factors for determining selection of personnel responsible for conducting internal audits, including training requirements for the internal auditing personnel? (RCP II-G-1b-2i)

The company’s process must describe the factors to be used to determine which personnel are responsible for conducting internal audits and include the training requirements for those persons conducting internal audits.

11.3.3 Does the internal audit process specify factors for determining selection of personnel responsible for conducting internal audits, to include: a requirement that personnel are independent of the area being audited, as practicable? (RCP II-G-1b-2ii)

The internal audit process must specify the factors for determining which personnel will be responsible for conducting internal audits. The person/s conducting the audit must be independent of the area being audited, as practical for the size of the company.

Companies should avoid a situation that would place an internal auditor in a conflict of interest; for example, an internal auditor should not be doing the audit of his or her own work or the areas that are under his/her responsibility.

11.3.4 Are internal audits carried out annually and initiated by the anniversary date of the last internal audit for each towing vessel operated by the company? (RCP II-G-1b-1)

Internal audits of each towing vessel operated by the company must be carried out annually. These audits must be initiated by the anniversary date of the previous internal audit.

Note: Audits may be conducted up to three months before the anniversary date of the original or previous audit and will maintain the original anniversary date.


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11.4 Internal Vessel Inspection Procedures

11.4.1 Does the audit program verify vessel inspection procedures? (RCP II-G-1) Notice that the line of questioning has shifted from questions that deal with the management internal audit to questions that deal with the vessel internal audit. Also notice that the question here addresses the company verifying or validating the vessel inspection procedures and not just the company inspecting the vessel itself.

The written internal auditing program must verify vessel inspection procedures. For example, if the company has a written vessel inspection procedure and a vessel inspection checklist that is completed by vessel personnel, the written internal audit procedures might require an internal audit of the vessel using that same checklist or a different checklist that is designed specifically for that purpose to be used to assure management that crewmembers are complying with the company’s expectations when conducting vessel inspections.

11.4.2 Do these written vessel inspection procedures include frequency of inspections? (RCP II-B-8b) (RCP II-G-1b-1)

The written vessel inspection procedures and/or the checklist used for the inspection must include the frequency of inspections (e.g. monthly, quarterly, annually, etc.). Internal vessel audits must be conducted at least annually.

11.4.3 Do these written vessel inspection procedures include what is to be inspected and/or audited? (RCP II-B-8)

The written vessel inspection procedures and/or the checklist used for the inspection must provide sufficient detail so that persons responsible for conducting vessel inspections clearly understand the company’s expectations for what is to be inspected and be able to identify conditions which are unacceptable (i.e., the company should provide definitions for terms such as deficiency and nonconformity).

11.4.4 Do these written vessel inspection procedures include persons responsible for conducting in-house inspections? (RCP II-B-8a)

The written vessel inspection procedures and/or the checklist used for the inspection must identify persons, by name or position, who are responsible for conducting in-house vessel inspections.


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11.4.5 Do these written vessel inspection procedures include qualifications and training requirements for persons responsible for conducting in-house inspections? (RCP II-B-8c)

The written vessel inspection procedures must include qualifications and training requirements for persons responsible for conducting in-house vessel inspections. The company should be able to provide evidence to document that persons who conduct in-house vessel inspections have met the company’s written qualification requirements and provide evidence of appropriate training having been completed for persons who are engaged in conducting in-house vessel inspections.

11.4.6 Do these written vessel inspection procedures include correcting deficiencies identified during inspections? (RCP II-B-8d)

The written vessel inspection procedures must include procedures for correcting deficiencies identified during vessel inspections. The company should be able to provide evidence to document that the procedures which describe the process for identifying deficiencies, tracking corrective action, assigning responsibility, management review, and follow-up time frame have been met for written vessel inspections conducted during the audit period.

11.4.7 Do these written vessel inspection procedures include requirements for record retention? (RCP II-B-8e)

The written vessel inspection procedures must include requirements for record retention. The company should be able to provide evidence to document compliance with the company’s record retention requirements. These requirements should include what inspection records are to be retained, for how long, and how they are to be maintained to ensure they are reasonably secured from loss or damage.

11.5 External Audits

11.5.1 Does the company have a method to ensure that external audits are to be carried out for each towing vessel, during a period not to exceed five years after the initial audit and no more than three months prior to the fifth anniversary of the initial or previous audit? (RCP II-G-2a-1)

The company must have a method to ensure that external audits will be carried out for each towing vessel no more than five years after the initial vessel audit, and no more than three months prior to the fifth anniversary of the initial or previous audit. The company can determine whether to use a policy, procedure, process, etc. to comply with this requirement.

For a listing of current TVIB-certified RCP auditors, please visit www.thetvib.org.

http://www.thetvib.org/


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11.5.2 Does the company have a method to ensure that external compliance audits are to be carried out for each managing office, once every five years and no more than three months prior to the fifth anniversary date of the initial audit (or previous audit)? (RCP II-G-2a-1)

The company must have a method to ensure that external compliance audits will be carried out for each managing office once every five years and no more than three months prior to the fifth anniversary date of the initial or previous audit. The company can determine whether to use a policy, procedure, process, etc. to comply with this requirement.

11.5.3 Does the company have a method to ensure that external mid-period compliance audits are to be carried out for each managing office during a period not to exceed five years, and between the 27th and 33rd month after the previous external compliance audit, but no more than three months prior to the anniversary date of the previous mid period audit? (RCP II-G-2a-1)

The company must have a method to ensure that external mid-period compliance audits will be carried out for each managing office. The mid-period audit is a “check-in” review of the effectiveness of the safety management system. Auditors will look at the last external audit findings, internal audit documentation, completion of corrective actions and such. This audit should be a verification of compliance and implementation, taking a deeper dive into specific areas if needed. It should be focused on documented compliance, “results and records” and not just be a repeat of the 5 year certification audit.

The expectation of compliance or non-compliance is the same as the recertification audit, however, and the deadline is the end of the 180 day window for the mid-period audit. The company can determine whether to use a policy, procedure, process, etc. to comply with this requirement.

11.6 Performance Measurement Procedures (RCP II-A-7)

11.6.1 Does the company have written performance measurement procedures? (RCP II-A-7)

The company must have one or more written procedures which address performance measurement. For a compliant answer, the procedures must satisfy the RCP definition for a written procedure.


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11.6.2 Does the company record and measure performance statistics including manhours? (RCP II-A-7a)

The company must have one or more written procedures, which address recording and measuring manhours, and the procedures must satisfy the RCP definition for a written procedure. The company must be able to provide evidence to document compliance with the company’s performance measurement procedures.

For more information on how to calculate manhours, see 2012 AWO Safety Statistics Instruction Manual.

11.6.3 Does the company record and measure performance statistics including number and rate of fatalities? (RCP II-A-7b)

The company must have one or more written procedures, which address recording and measuring the number and incident rate of fatalities, and the procedures must satisfy the RCP definition for a written procedure. The company must be able to provide evidence to document compliance with the company’s performance measurement procedures.

For more information on how to calculate the incident rate of fatalities, see 2012 AWO Safety Statistics Instruction Manual.

11.6.4 Does the company record and measure performance statistics including number and rate of recordable injuries? (RCP II-A-7c)

The company must have one or more written procedures, which address recording and measuring the number and incident rate of recordable injuries, and the procedures must satisfy the RCP definition for a written procedure. The company must be able to provide evidence to document compliance with the company’s performance measurement procedures.

For more information on how to calculate the incident rate of recordable injuries, see 2012 AWO Safety Statistics Instruction Manual.

11.6.5 Does the company record and measure performance statistics including number and rate of lost time injuries? (RCP II-A-7d)

The company must have one or more written procedures, which address recording and measuring the number and incident rate of lost time injuries, and the procedures must satisfy the RCP definition for a written procedure. The company must be able to provide evidence to document compliance with the company’s performance measurement procedures.

For more information on how to calculate the incident rate of lost time injuries, see 2012 AWO Safety Statistics Instruction Manual.

11.6.6 Does the company record and measure performance statistics including number and rate of falls overboard? (RCP II-A-7e)

The company must have one or more written procedures, which address recording and measuring the number and incident rate of falls overboard, and the procedures must satisfy the RCP definition for a written procedure. The company must be able to provide evidence to document compliance with the company’s performance measurement procedures.

For more information on how to calculate the incident rate of falls overboard, see 2012 AWO Safety Statistics Instruction Manual.


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11.6.7 Does the company record and measure performance statistics including number and volume of spills to water? (RCP II-A-7f)

The company must have one or more written procedures, which address recording and measuring the number and volume of spills to water, and the procedures must satisfy the RCP definition for a written procedure. The company must be able to provide evidence to document compliance with the company’s performance measurement procedures.

11.6.8 Does the company have a process for identifying areas for improvement? (RCP II-A-7)

The company must have one or more written procedures, which specifies the process for identifying areas for improvement, and the procedures must satisfy the RCP definition for a written procedure. The company should be able to provide evidence how it uses the company’s performance measurements to identify areas for improvement.

11.7 Does the company track the following indicators to assess its effectiveness in applying a performance improvement process?

11.7.1

Does the company track mechanical breakdowns and maintenance records to assess its effectiveness in applying a performance improvement process? (RCP II-A-7)

The company must have one or more written procedures, which provides for tracking and assessing mechanical breakdowns and maintenance records. Companies that have procedures for tracking mechanical breakdowns and maintenance records as a means to assess the company’s effectiveness must be able to provide evidence to document compliance with their performance measurement procedures. Effectiveness can also be measured by evaluating the company’s response in terms of implementing corrective actions.

11.7.2 (a)

Does the company track regulatory nonconformities to assess its effectiveness in applying a performance improvement process? (RCP II-A-7)

The company must have one or more written procedures, which provides for tracking and assessing regulatory nonconformities. Companies that have procedures for tracking regulatory nonconformities as a means to assess the company’s effectiveness must be able to provide evidence to document compliance with their performance measurement procedures. Effectiveness can also be measured by evaluating the company’s response in terms of implementing corrective actions.


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11.7.2 (b)

Does the company track customer complaints to assess its effectiveness in applying a performance improvement process? (RCP II-A-7)

The company must have one or more written procedures, which provides for tracking and assessing customer complaints. Companies that have procedures for tracking customer complaints as a means to assess the company’s effectiveness must be able to provide evidence to document compliance with their performance measurement procedures. Effectiveness can also be measured by evaluating the company’s response in terms of implementing corrective actions.

11.8 Vendor Safety: (RCP II-H) (Applicable for subcontractors and vendors that provide towing and vessel assist services)

11.8.1 If applicable, does the company have a written vendor safety evaluation procedures? (RCP II-H)

If applicable, the company must have one or more written procedures which satisfy the RCP definition of a procedure, to outline its vendor safety evaluation procedures. Companies must be able to provide evidence to document compliance with their vendor safety evaluation policy/procedures.

11.8.2 If applicable, are there written procedures for evaluation of subcontractors and vendors providing towing and vessel assist services on their ability to provide an acceptable level of safety? (RCP II-H)

The company must have one or more written procedures which satisfy the RCP definition of a procedure to outline its process for evaluating subcontractors and vendors who are providing towing and vessel assist and/or fleeting services. These procedures must also allow the company to make an assessment as to whether or not the vendor is capable of providing the company with an acceptable level of safety in the conduct of its services. Companies that have one or more written procedures for conducting vendor safety evaluations of its vendors must be able to provide evidence to document compliance with their vendor safety evaluation procedures.


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11.8.3 If applicable, is preference given to towing, vessel assist and/or fleeting vendors that have a documented and third-party audited, safety management system? (RCP II-H-1)

The company must have one or more written procedures which satisfy the RCP definition of a procedure to outline its process for giving preference to towing, vessel assist and/or fleeting vendors that have a documented, and third-party audited safety management system. Companies that have one or more written procedures addressing preferences for vendors that have a documented and third-party audited safety management system must be able to provide evidence to document compliance with their vendor safety evaluation procedures.

The RCP and ISM are examples of audited safety management systems.

11.8.4 For vendors providing towing, vessel assist and/or fleeting services that maintain a routine and reoccurring business relationship with the company, but do not participate in an audited safety management system, are there procedures for at least one of the following? (RCP II-H-2)

For those vendors who do not have a third-party audited safety management system, some factors to consider include safety performance, safety management systems, environmental compliance, crew training standards, emergency response plan, equipment maintenance standards.

11.8.4 (a)

On-site inspection of vessels and facilities (RCP II-H-2a)

When vendors do not participate in a third-party audited safety management system, the company must have one or more written procedures which satisfy the RCP definition of a procedure to outline its process for assessing the safety performance of its vendors by (11.8.4 (a)) conducting on-site inspections of their vessels and facilities, OR (11.8.4 (b)) the company must have one or more written procedures which satisfy the RCP definition of a procedure to outline its process for assessing the safety performance of its vendors by conducting pre-qualification interviews and completion of a safety assessment checklist with vendor safety/operations personnel.

Since the original statement in 11.8.4 requires RCP companies to have written procedures for one of the following, RCP companies may comply by addressing either 11.8.4 (a) or 11.8.4 (b).


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11.8.4 (b)

Pre-qualification through interview and completion of a safety assessment checklist with vendor safety/operations personnel (RCP II-H-2b)

See RCP Expectation for 11.8.4 (a). Since the original statement in 11.8.4 requires RCP companies to have written procedures for one of the following, RCP companies may comply by addressing either 11.8.4.(a) or 11.8.4 (b).

11.9 Does the company have a written policy and/or procedures to ensure compliance with applicable federal laws and regulations concerning marine safety and environmental protection? (RCP II-A-2) (RCP II-A-3)

The company must have a written policy and/or procedures which satisfy the RCP definition of a procedure to ensure its compliance with applicable federal laws and regulations concerning marine safety and environmental protection.

11.9.1 Do the written procedures include person(s) responsible for compliance? (RCP II-A-2)

The company’s written procedures for ensuring its compliance with applicable federal laws and regulations must identify, by name and/or position, the person(s) responsible for compliance. Companies usually address this issue in their management system by formally appointing a member of management to be responsible for the company’s compliance program. In most cases this appointment will be included in the job description for that particular employee or job position. Companies that have one or more written procedures addressing designation of a person responsible for regulatory compliance must be able to provide evidence to document compliance with its written procedures.

11.9.2 Do the written procedures include frequency and method(s) of review? (RCP II-A-2)

The company’s written procedures for ensuring its compliance with applicable federal laws and regulations must include the frequency and method(s) of review. Companies that have one or more written procedures addressing frequency and method of review of the effectiveness of the company’s compliance program must be able to provide evidence to document compliance with its written procedures.


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11.9.3 Do the written procedures adequately identify sources of information? (RCP II-A-2)

The company’s written procedures for ensuring its compliance with applicable federal laws and regulations must identify the sources of information. Companies that have one or more written procedures which identify the sources of information that is to be reviewed to ensure the effectiveness of the company’s compliance program must be able to provide evidence to document compliance with its written procedures. The company should have a review process to evaluate (at least annually) the adequacy of its sources of information related to ensuring ongoing compliance.

11.9.4 Are there written procedures to verify that necessary changes have been made? (RCP II-A-2) (RCP II-A-3)

The company must have one or more written procedures which satisfy the RCP definition for a procedure to verify that necessary changes have been made to company policies, procedures and/or practices to ensure ongoing legal/regulatory compliance, based on a) a review of the compliance-related information acquired b) an evaluation of its applicability to the company, c) development of appropriate responses, and d) effective communication and implementation of the changes to all impacted personnel and parts of the company. Companies that have one or more written procedures which verify that necessary changes have been made to ensure the effectiveness of the company’s compliance program must be able to provide evidence to document compliance with its written procedures.


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Corrective and Preventive Action Program

11.10 (a) Does the company have written corrective action procedures that apply to findings from deficiencies identified during maintenance? (RCP II-A-6) (RCP II-B-7d)

The company must have one or more written procedures which satisfy the RCP definition for a procedure that include how corrective actions are generated and addressed from findings of deficiencies identified during routine and non-routine maintenance.

11.10 (b) Does the company have written preventive action procedures that apply to findings from deficiencies identified during maintenance? (RCP II-A-6) (RCP II-B-7d)

The company must have one or more written procedures which satisfy the RCP definition for a procedure that include how preventive actions are generated and addressed from findings of deficiencies identified during routine and non-routine maintenance.

11.10 (c) Are there written records to demonstrate compliance with the procedure(s) in 11.10 (a) & (b)? (RCP II-A-6) (RCP II-B-7d)


11.11 (a) Does the company have written corrective action procedures that apply to findings from deficiencies identified during internal and external incident investigations and audits? (RCP II-A-6)

The company must have one or more written procedures which satisfy the RCP definition for a procedure that include how corrective actions are generated and addressed from findings of deficiencies identified during internal and external investigations and audits.

11.11(b) Does the company have written preventive action procedures that apply to findings from deficiencies identified during internal and external incident investigations and audits? (RCP II-A-6)

The company must have one or more written preventive action procedures which satisfy the RCP definition for a procedure that include how preventive actions are generated and addressed from findings of deficiencies identified during internal and external investigations and audits.


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11.11 (c) Are there written records to demonstrate compliance with the procedure(s) in 1.11(a) & (b)? (RCP II-A-6)


11.12 (a) Does the company have written corrective action procedures that apply to findings from deficiencies identified during employee and customer suggestions? (RCP II-A-6)

The company must have one or more written procedures which satisfy the RCP definition for a procedure that include how corrective actions are generated and addressed from findings of deficiencies identified during employee and customer suggestions.

11.12 (b) Does the company have written preventive action procedures that apply to findings from deficiencies identified during employee and customer suggestions? (RCP II-A-6)

The company must have one or more written preventive actio procedures which satisfy the RCP definition for a procedure that include how preventive actions are generated and addressed from findings of deficiencies identified during employee and customer suggestions.

11.12 (c) Are there written records to demonstrate compliance with the procedure(s) in 11.12 (a) & (b)? (RCP II-A-6)


11.13 (a) Does the company have written corrective action procedures that apply to findings from deficiencies identified during management review? (RCP II-A-6)

The company must have one or more written procedures which satisfy the RCP definition for a procedure that include how corrective actions are generated and addressed from findings of deficiencies and deficiencies identified during management reviews.

See also RCP II-G-1-a-5.


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11.13 (b) Does the company have written preventive action procedures that apply to findings from deficiencies identified during management review? (RCP II-A-6)

The company must have one or more written preventive action procedures which satisfy the RCP definition for a procedure that include how preventive actions are generated and addressed from findings of deficiencies identified during management review.

11.13 (c) Are there written records to demonstrate compliance with the procedure(s) in 11.13 (a) & (b)? (RCP II-A-6)


11.14 (a) Do the procedures address the method for identifying non-conformities? (RCP II-A-6a)

The company’s written corrective actions procedures must address the method of identifying non-conformities and deficiencies that require corrective action. In other words, once non-conformities are identified, then corrective action is required. The written procedure(s) should include clear definitions of non-conformity and corrective action. It is recommended that ISO 9001, ISM or any other recognized management system standard be used as guidance.

11.14 (b) Are there written records to demonstrate compliance with the procedure(s) listed in 11.14 (a)? (RCP II-A-6a)


11.15 (a) Do the procedures address the follow-up time frame for initiating corrective action? (RCP II-A-6b)

The company’s written corrective actions procedures must address management’s expectations of the follow-up time frame for initiating the corrective actions. Some companies specify a fixed timeframe for completion of the required corrective actions, while other companies allow a variable timeframe depending on certain circumstances which are outlined in their programs.

Follow-up timeframes should include a check prior to the implementation target date (to determine if the target date will be met, if more resources may be required to implement the corrective action, and/or the target date needs to be adjusted). Follow-up should also be scheduled some time after implementation of the corrective action, to verify effectiveness and ongoing application of the corrective action.


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11.15 (b) Are there written records to demonstrate compliance with the procedure(s) listed in 11.15 (a)? (RCP II-A-6b)


11.16 (a) Do the procedures address the method for tracking initiation and completion of corrective action? (RCP II-A-6c)

The company’s written corrective actions procedures must address the method of tracking initiation and the follow through to completion of corrective actions.

11.16 (b) Are there written records to demonstrate compliance with the procedure(s) listed in 11.16 (a)? (RCP II-A-6c)


11.17 (a) Do the procedures address assigning responsibility for tracking the initiation and completion of corrective action? (RCP II-A-6c)

The company’s written corrective actions procedures must address the method for assigning responsibility for tracking the initiation and completion of corrective actions.

The method of tracking corrective actions should also include target dates for implementation, and a requirement for verification of effective implementation of the corrective action.

11.17 (b) Are there written records to demonstrate compliance with the procedure(s) listed in 11.17 (a)? (RCP II-A-6c)


11.18 (a) Do the procedures address lessons learned? (RCP II-A-6d)

The company’s written corrective actions procedures must address the development of lessons learned from the necessary corrective actions that were initiated.

11.18 (b) Are there written records to demonstrate compliance with the procedure(s) listed in 11.18 (a)? (RCP II-A-6d)



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11.19 (a) Do the procedures include communication procedures for disseminating lessons learned? (RCP II-A-6d)

The company’s written corrective actions procedures must include communication procedures for disseminating lessons learned to the rest of the company to help prevent future occurrences.

11.19 (b) Are there written records to demonstrate compliance with the procedure(s) listed in 11.19 (a)? (RCP II-A-6d)



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SECTION 12 – DOCUMENT CONTROL TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

12.1 Does the company have a written document control program? (RCP II-A-3)

The written document control program must satisfy the RCP definition for a written program and must include document control, updating and distribution. Companies should be able to provide evidence to document that all components of their document control program with regard to the RCP or other acceptable Safety Management System (ISM), are in place throughout the company and that it is being followed by all persons who are involved in the management of controlled documents throughout the company. For the company to be in compliance, the program must satisfy the RCP definition for Document Control Program: A documented procedure that applies to the control of all documents used in the company’s RCP or ISM Safety Management System. This would include all operating policies, procedures, forms and records used within the RCP or ISM. The document control program would include a process for approval, identification, distribution, review, revision and control of obsolete documentation, and also include records retention. Documents used within the system could be in paper, electronic or similar format. For the company to be in compliance, the program must satisfy the RCP definition for Controlled Document: Any document identified by the document control program as being included in the program.

Consideration should be given to document control requirements of ISO 9001, ISM or other recognized management system standards.

12.2 Does the company have documentation to show current compliance with their document control process? (RCP II-A-3)

See 12.1

12.3 Does the documentation reflect that the system is maintained and current as of the date of the audit? (RCP II-A-3)

See 12.1


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12.4 Does the written document control program include identification of critical operating policies and procedures? (RCP II-A-3)

The written document control program must include written procedures which satisfy the RCP definition for a written procedure and which identify all of the critical operating policies and procedures the company considers to be controlled documents (see the definition for controlled documents). For example, these controlled documents may be identified in the form of a list contained within a written procedure or they may be included within a procedure in the form of a matrix, or a diagram, etc. Critical operating policies and procedures are defined as those procedures that are included in the company’s document control program.

The company should have a process to determine what operating policies and procedures would be considered critical. This designation of “critical” may be based on risk factors such as the impact of regulatory compliance, personnel safety, vessel safety, operational impact or other considerations

12.5 Does the written document control program include identification of who receives the documented policies and procedures? (RCP II-A-3)

The written document control program must include written procedures which should satisfy the RCP definition for a written procedure and should identify who receives the documented policies and procedures, or if electronic, how and where to access them. Each company’s document control program should identify recipients either by name or by their job positions, for all employees who are authorized to receive controlled documents (see the definition for controlled documents). This may be presented in the form of a distribution list.


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12.6 Does the written document control program include a control system for policies and procedures? (RCP II-A-3)

The written document control program must include written procedures which satisfy the RCP definition for a written procedure and should include a control system for policies and procedures. Each company’s document control program must contain written instructions which outline the elements of the control system for these controlled documents (see the definition for controlled documents) and must provide sufficient detail as to how to manage controlled documents that are to be maintained within their custody, care and control. For example, the document control system may include a process for:

• designating one or more persons or positions as document controllers;

• determining what documents need to be controlled; • approving documents prior to use; • reviewing, updating and re-approving documents; • ensuring that changes and current revisions to

documents are identified; • maintaining revision history logs for each document; • having a document receipt, review and

implementation confirmation process for all designated recipients;

• ensuring that relevant versions of applicable documents are available at points of use;

• differentiating between controlled and uncontrolled copies of controlled documents;

• ensuring that documents remain legible and readily identifiable; and

• preventing the unintended use of obsolete documents, etc.


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12.7 Does the written document control program include cyclic accuracy review of critical operating policies and procedures? (RCP II-A-3)

The written document control program must include written procedures which should satisfy the RCP definition for a written procedure and should include cyclic accuracy review of critical operating policies and procedures. Each company’s document control program must describe the specific review process for each controlled document (see the definition for controlled documents) identified as a critical operating policy or procedure. Each company’s document control program must also define the frequency of a periodic review such as quarterly, annually, etc. Each document review must at a minimum determine that the document remains current and that it adequately meets the needs it was designed to accomplish. This review process must also include a verification that up-to-date versions of controlled documents are in place where they should be, and that no out-of-date/obsolete versions are found.

COPYRIGHT © TOWING VESSEL INSPECTION BUREAU (TVIB) – 2017 TVIB RCP MANAGEMENT AUDIT WORKSHEET (13) – 1.1.2017

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SECTION 13 – RISK MANAGEMENT TVIB – RCP MANAGEMENT AUDIT WORKSHEET ? # Question RCP Expectation Additional Information

13.1 Does the company have a written procedure that integrates the concept of risk management? (RCP II-A-1)

The company must have a comprehensive written procedure on risk management and assessment. This is different than a Job Safety Analysis, Toolbox Talk, or other risk-related procedure. (While the questions below separate out the different elements of the risk assessment procedure, one procedure can easily satisfy the requirements.)

13.2 (a) Does the company have written procedures to systematically assess identified risks to onboard personnel? (RCP II-A-1)

The risk assessment procedure must specifically address how risks to onboard personnel are identified or discovered.

Risks may be intentionally identified during a risk analysis procedure or accidentally discovered during daily activities.

13.2 (b) Does the company have written procedures to manage identified risks to onboard personnel? (RCP II-A-1)

The risk assessment procedure must specifically address how risks to onboard personnel are managed.

13.2 (c) Are there written records available to demonstrate compliance with the procedures in 13.2 (a) and (b)? (RCP II-A-1)

There must be completed risk assessment records and/or other documentation showing that the risk assessment procedure was used to identify (discover), assess, and manage risks to onboard personnel. (Documentation of risk assessments completed may cover multiple categories of risk.)

Forms are always blank. Completed “forms” become records after they are filled out. Auditors will be looking for completed records during their audits.

13.3 (a) Does the company have written procedures to systematically assess identified risks to vessels? (RCP II-A-1)

The risk assessment procedure must specifically address how risks to vessels are identified or discovered.

13.3 (b) Does the company have written procedures to manage identified risks to vessels? (RCP II-A-1)

The risk assessment procedure must specifically address how risks to vessels are managed.


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13.3 (c) Are there written records available to demonstrate compliance with the procedures in 13.3(a) and (b)? (RCP II-A-1)

There must be completed risk assessment records and/or other documentation showing that the risk assessment procedure was used to identify (discover), assess, and manage risks to vessels. (Documentation of risk assessments completed may cover multiple categories of risk.)

13.4 (a) Does the company have written procedures to systematically assess identified risks to the environment? (RCP II-A-1)

The risk assessment procedure must specifically address how risks to the environment are identified or discovered.

13.4 (b) Does the company have written procedures to manage identified risks to the environment? (RCP II-A-1)

The risk assessment procedure must specifically address how risks to the environment are managed.

13.4 (c) Are there written records available to demonstrate compliance with the procedures in 13.4(a) and (b)? (RCP II-A-1)

There must be completed risk assessment records and/or other documentation showing that the risk assessment procedure was used to identify or discover, assess, and manage risks to the environment. (Documentation of risk assessments completed may cover multiple categories of risk.)

13.5 Do the risk management procedures contain a process for identifying risks---risk discovery? (RCP II-A-1-a)

The risk assessment procedure must specifically address how risks are identified or discovered. This can include through incident reports, results from internal or external audits, new regulations, the management of change process, or any other source.

This question addresses the overall system and goes beyond the items specifically identified in 13.2-13.4. FMEA (Failure Mode Effects and Analysis) and the Risk Priority Number concept is one method of assessing risk to an organization’s SMS. Risk Priority Number equals: Severity X Occurrence X Detection


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SEVERITY: seriousness of an effect (ranked 1 to 5) OCCURRENCE: likelihood a cause will create the failure associated with an effect (ranked 1 to 5) DETECTION: ability to detect the failure before it affects external stakeholders (ranked 5 to 1) Additional risk assessment examples can be found on the AWO website: http://www.americanwaterways.com/sites/default/files/Risk%20Assessment%20Webinar_0.pdf

13.6 Do the risk management procedures establish the risk evaluation criteria for the purpose of accepting or rejecting risks that are identified? (RCP II-A-1b)

The method used by the company to evaluate and manage potential risks must cause the company to make objective judgments that result in a high quality risk management process.

Refer to FMEA above, or AWO webinar for risk assessment tools.

13.7 Do risk control measures (procedures) establish appropriate safeguards to ensure identified risks are reduced to an appropriate level, satisfactory to the company? (RCP II-A-1c)

During risk assessments, measures must be identified or developed to reduce or mitigate the risk to a level that is satisfactory to the company. The procedure must explain how this is done.

“Measures” used in this context is to be interpreted as the same as procedures.

http://http/www.americanwaterways.com/sites/default/files/Risk%20Assessment%20Webinar_0.pdf


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13.8 (a) Does the company have written procedures to identify, assess, and manage the risk of hazards introduced by new or non-routine changes to equipment? (RCP II-A-1d)

The risk assessment procedure must specifically address how risks that may be introduced by new or non-routine changes to equipment are identified or discovered, assessed, and managed. Because new or non-routine changes to equipment can pose unanticipated risks, the company must ensure that they are addressed through the risk assessment procedure and process.

13.8 (b) Are there written records available to demonstrate compliance with the procedures in 13.8 (a)? (RCP II-A-1d)

There must be completed risk assessment records and/or other documentation showing that the risk assessment procedure was used to identify or discover, assess, and manage risks that may be introduced by new or non-routine changes to equipment. (Documentation of risk assessments completed may cover multiple categories of risk.)

13.9 (a) Does the company have written procedures to identify, assess and manage the risk of hazards introduced by new or non-routine changes to staffing (ashore or afloat)? (RCP II-A-1d)

The risk assessment procedure must specifically address how risks that may be introduced by new or non-routine changes to staffing (both ashore and afloat) are identified or discovered, assessed, and managed. Because new or non-routine changes to staffing can pose unanticipated risks, the company must ensure that they are addressed through the risk assessment procedure and process.


There must be completed risk assessment records and/or other documentation showing that the risk assessment procedure was used to identify (discover), assess, and manage risks that may be introduced by new or non-routine changes to staffing (both ashore and afloat). (Documentation of risk assessments completed may cover multiple categories of risk.)


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13.10 (a) Does the company have written procedures to identify, assess and manage the risk of hazards introduced by new or non-routine changes to procedures? (RCP II-A-1d)

The risk assessment procedure must specifically address how risks that may be introduced by new or non-routine changes to procedures are identified or discovered, assessed, and managed. Because new or non-routine changes to procedures can pose unanticipated risks, the company must ensure that they are addressed through the risk assessment procedure and process.


There must be completed risk assessment records and/or other documentation showing that the risk assessment procedure was used to identify or discover, assess, and manage risks that may be introduced by new or non-routine changes to procedures. (Documentation of risk assessments completed may cover multiple categories of risk.)

Date post:	31-Oct-2020
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