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.
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.
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.
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.
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))
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
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.
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.
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
SECTION 3 – DOCUMENTATION, NAVIGATION AND COMMUNICATION TVIB – RCP VESSEL AUDIT WORKSHEET ? # Question RCP Expectation Regulatory
Requirements Additional Information
3.1 Is a check-off report turned in or a log entry made at least quarterly verifying that documentation as required by RCP and regulation is present and current? (RCP III-D) (RCP IV-D) (RCP II-B-4)
For a compliant answer, the company must have a written procedure which implements a documented checklist or requires a log entry be made at least quarterly to verify required documentation (see 3.2 thru 3.22) is present and current.
3.2 For vessels 5 NT or greater, is the original Certificate of Documentation on board? (RCP II-A-3) (RCP III-D) (RCP IV-D)
For vessels 5 NT or greater, the vessel must have on board the original Certificate of Documentation currently in effect for the vessel, unless the document has been sent in to the National Vessel Documentation Center for exchange in accordance with 46 CFR 67.167(d) or (e). The Certificate of Documentation must have a proper/valid endorsement for the area(s) of operation. UTVs engaged in Western Rivers, Inland, or Coastal operations must have the Coastwise endorsement. UTVs engaged in Great Lakes operations must have the Great Lakes endorsement, and UTVs engaged in foreign trade must have the Registry endorsement.
Vessels less than 5 NT are required to have a state-issued Certificate of Number (33 CFR 173.21(a)(1)).
3.2.1 Certificate of Documentation expiration date.
The auditor should record the expiration date on the vessel’s Certificate of Documentation.
3.3 Is a valid load line certificate on board attesting to compliance with load line requirements? (where applicable)
For new vessels over 79 feet and existing vessels over 150 GT on Coastwise, Great Lakes & Oceans routes, the vessel must have on board a valid load line certificate issued by a classification society attesting to compliance with load line requirements.
3.4 Is the vessel marked with the name on both sides of the bow and at the stern, and hailing port on the stern?
For vessel 5 NT or greater, the name of the vessel must be marked on some clearly visible exterior part of the port and starboard bow and the stern of the vessel. The hailing port of the vessel must be marked on some clearly visible exterior part of the stern of the vessel. The markings must be made of any means and materials which result in durable markings, and must be made in clearly legible letters of the Latin alphabet or Arabic or Roman numerals not less than 4 inches in height.
46 CFR 67.123 Vessels less than 5 NT must comply with 33 CFR 173.27. The bow is defined as that portion of the vessel forward of amidships. The stern is defined as that portion of the vessel aft of amidships.
3.5 Is the official number permanently marked on an interior structural member?
For vessels 5 NT or greater, the official number of the vessel, preceded by the abbreviation “NO.” must be marked in block-type Arabic numerals no less than 3 inches in height on some clearly visible interior structural part of the hull. The number must be permanently affixed to the vessel so that alteration, removal or replacement would be obvious. If the number is on a separate plate, the plate must be fastened in such a manner that its removal would normally cause some scarring of or damage to the surrounding hull area.
46 CFR 67.121 Vessels less than 5 NT must comply with 33 CFR 173.27. The auditor should abide by the company’s confined space policy, if applicable. Depending on vessel configuration, photographic evidence may be accepted.
3.6 Is a copy of the Navigation Rules on board? (RCP III-D-1) (RCP IV-D-1)
For vessels 12 meters (39.4 feet) or greater, the vessel must have a current copy of the Inland Navigation Rules on board if operating inside the COLREGS demarcation line (i.e. Western Rivers, Inland Waters).
33 CFR 88.05
Navigation Rules should be maintained for ready reference. Electronic back-up copies of the Navigation Rules will be sufficient, if it complies with the Coast Guard policy letter.
3.7 Are current or corrected navigation charts or maps on board? (RCP III-D-11) (RCP IV-D-14)
For vessels 12 meters (39.4 feet) or greater, the vessel must have on board current edition(s) or currently corrected edition(s) of charts or maps of adequate scale and detail for areas of operation; extracts are acceptable.
Western Rivers: 33 CFR 164.72(b)(1)(A) Near Coastal/Ocean, Great Lakes/Inland: 33 CFR 164.72(b)(1)(B)
Old editions of charts that are not currently corrected should be removed from the vessel or marked as “out of date for reference only.” The most recently published version of an inland river chart book is considered to be currently corrected.
3.8 Are copies of tide and current tables on board? (not required for Western Rivers towing vessels) (RCP III-D-12) (RCP IV-D-15)
For vessels 12 meters (39.4 feet) or greater operating on other than Western Rivers, the vessel must have on board current copies of tidal-current or river-current tables and tide tables for areas of operation.
Near Coastal/Ocean, Great Lakes/Inland: 33 CFR 164.72(b)(2)(C) 33 CFR 164.72 (b)(3)
USCG District 8 has stated that electronic versions of certain required documents are acceptable if a secondary, backup means of accessing that documentation is available. NVIC 01-16 D8 Policy Letter 02-2010
3.9 Is there a copy of the Coast Pilot on board the vessel? (not required for Western Rivers towing vessels) (RCP III-D-13) (RCP IV-D-16)
For vessels 12 meters (39.4) feet or greater operating on other than Western Rivers, the vessel must have on board a current copy of the USCG Coast Pilot appropriate for the areas of operation.
Near Coastal/Ocean, Great Lakes/Inland: 33 CFR 164.72(b)(2)(ii)E) 33 CFR 164.72 (b)(3)
USCG District 8 has stated that electronic versions of certain required documents are acceptable if a secondary, backup means of accessing that documentation is available. NVIC 01-16 D8 Policy Letter 02-2010
3.10 Are there copies of the current ACOE Notices to Navigation, USCG Local Notice to Mariners, or NIMA Notices to Mariners, as applicable, on board? (RCP III-D-14) (RCP IV-D-18)
For vessels 12 meters (39.4 feet) or greater towing exclusively on the Western Rivers, the vessel must have on board a currently corrected edition of, or an applicable currently corrected extract from applicable ACOE Notices to Navigation, or USCG Local Notice to Mariners, for the area to be transited. For vessels 12 meters (39.4 feet) or greater towing other than exclusively on Western Rivers, the vessel must have on board a currently corrected edition of, or an applicable currently corrected extract from NIMA Notices to Mariners, or USCG Local Notice to Mariners, for the area to be transited.
USCG District 8 has stated that electronic versions of certain required documents are acceptable if a secondary, backup means of accessing that documentation is available. NVIC 01-16 D8 Policy Letter 02-2010
3.11 Is there a copy of the current USCG Light List, or current applicable extract for the vessel’s area of operations, on board? (RCP IV-D-17)
For vessels 12 meters (39.4 feet) or greater, the vessel must have on board a currently corrected edition of, or an applicable currently corrected extract from the USCG Light List for its area of operations.
Western Rivers: 33 CFR 164.72(b)(2)(i)(A) Near Coastal/Ocean, Great Lakes/Inland: 33 CFR 164.72(b)(2)(ii)(A)
USCG District 8 has stated that electronic versions of certain required documents are acceptable if a secondary, backup means of accessing that documentation is available. NVIC 01-16 D8 Policy Letter 02-2010
3.12 Are VTS manual(s) on board? (where applicable) (RCP III-D-17) (RCP IV-D-22)
For vessels 26 feet or greater operating in a VTS area, the vessel must have on board the current copies of VTS User Manual(s) appropriate to the vessel’s area of operation and up to date.
33 CFR 161.4 VTS User Manuals are also included in the Coast Pilot. USCG District 8 has stated that electronic versions of certain required documents are acceptable if a secondary, backup means of accessing that documentation is available. NVIC 01-16 D8 Policy Letter 02-2010
3.13 Is there a copy of the company’s drug and alcohol policy displayed and available to crewmembers, including Employee Assistance Program (EAP) information and hotline telephone number? (RCP II-J-3)
The vessel must have a copy of the company’s drug and alcohol policy, including EAP information and hotline telephone number displayed and available to crewmembers.
46 CFR 16.401 EAP information is often posted in the galley or crew’s lounge. A Zero Tolerance Policy Placard does not satisfy this requirement. The posted document must be the company’s policy regarding the use of drugs and alcohol in the workplace.
3.14 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?
The 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.
46 CFR 4.06-15 Drug testing must be accomplished within 32 hours of a serious marine incident (46 CFR 4.06-15). Alcohol testing equipment should be calibrated in accordance with manufacturer’s recommendations.
3.15 If subject to the Maritime Transportation Security Act (MTSA), is a U.S. Coast Guard-approved Vessel Security Plan or Alternative Security Program on board and secure?
For vessels subject to MTSA, a U.S. Coast Guard-approved Vessel Security Plan or Alternative Security Program must be on board, and located in a restricted area.
3.15.1 If subject to MTSA, do security measures for access control appear to be applied and enforced?
For vessels subject to MTSA, access control measures must be applied and enforced in accordance with 33 CFR 104.265 and/or the U.S. Coast Guard-approved VSP or ASP.
33 CFR 104.265 The security measures for access control requirements in 33 CFR 104.265 are subordinated to the company’s Coast Guard approved security plan or approved alternative security program. Examples may include identification checks, security briefings, signage, screening, use of escorts, etc.
3.16 Are Safety Data Sheets (SDSs) available on board the vessel, or readily available to crewmembers when needed? (RCP II-C-10)
The vessel must have on board, or have immediate access to, Safety Data Sheets (SDSs) in accordance with the company’s written hazard communication procedures.
29 CFR 1910.1200 Safety Data Sheets (SDSs) were formerly referred to as Material Safety Data Sheets (MSDSs). Electronic copies are an acceptable form and a backup electronic format would be encouraged.
3.17 Is cargo hazard information available on board the vessel, or readily available to crewmembers when needed? (RCP II-B-9)
The vessel must have on board, or have immediate access to, cargo hazard information for each cargo carried in barges towed by the vessel, or in barges stored in the barge fleets tended by the vessel, which may present hazards to crewmembers or the environment, or that may require special knowledge or special handling.
The requirement for cargo hazard information pertains to all types of cargoes, including liquid and dry cargoes that may be carried in barges. Cargo hazard information may be available from resources such as The Chemical Data Guide for Bulk Shipment by Water (Blue Book), CHRIS Manual, Safety Data Sheets (SDSs), etc. Electronic copies are an acceptable form and a backup electronic format would be encouraged.
3.18 Are tests and inspections required by 33 CFR 164.80 conducted, and the results entered in the log or other record carried on board?
The vessel must have on board a record of the most recently required tests and inspections of steering systems, navigational equipment, communications, lights, terminal gear and propulsion system. Vessels less than 1600 GT must conduct these tests and inspections before the vessel embarks on a voyage of more than 24 hours or when each new Master assumes command. For live aboard vessels, the tests and inspections must be completed each time a new Master assumes command, and should be completed as a part of the change-of-command process. For non live aboard vessels, the tests and inspections must be completed at the beginning of each shift by the new Master assuming command.
33 CFR 164.80 33 CFR 164.78
For crews working 12 hour shifts and not staying onboard the vessel, the master must complete the tests and inspections as required by 33 CFR 164.80 each time he or she assumes command, and maintain written records documenting the completion and the results of the tests on board.
3.19 Is the station bill conspicuously posted on board the vessel? (RCP II-C-6)
The vessel must have the station bill posted in one or more conspicuous locations on board the vessel, as necessary to ensure crew familiarity. The RCP does not specify a format for station bills; the company is expected to use its own discretion. The station bill should address both crewmembers and non-crewmembers.
The auditor should verify that the station bill does not conflict with the emergency response procedures.
3.20 Is a copy of the radiotelephone log maintained? (where applicable) (RCP III-D-2) (RCP IV-D-2)
For vessels 26 feet or greater subject to the Bridge-to-Bridge Act or the Great Lakes Radio Agreement, the vessel must have on board a radiotelephone log with: (1) entries at least every 30 days that batteries or other reserve power sources have been checked and are functioning properly; (2) daily statements about the condition of the required radiotelephone equipment, as determined by either normal test communication; (3) a summary of all distress and urgency communications; (4) the time of any inadvertent transmissions of distress, urgency and safety signals including the time and method of cancellation; (5) a weekly entry that digital selective calling equipment functions properly as determined by actual communication or a test call, the portable survival craft radio gear and radar transponders have been tested, and the EPIRBs have been inspected; (6) when the master is notified about improperly operating radiotelephone equipment; and (7) additional entries as required for GMDSS alerting devices (see 47 CFR 80.409(e)(11)). See “Additional Information” for additional requirements for vessels subject to the Great Lakes Radio Agreement.
In addition, vessels 26 feet or greater subject to the Great Lakes Radio Agreement must include entries in the radiotelephone log for: (1) results of required equipment tests, including specific gravity of lead-acid storage batteries and voltage reading of other types of batteries provided as a part of the compulsory installation; (2) GMDSS radio log entries made whenever GMDSS equipment is exchanged or replaced, when major repairs to GMDSS equipment are accomplished, and when annual GMDSS inspections are conducted; and (3) an easily identifiable, separate section relating to the required inspection of the ship’s radio station (see 47 CFR 80.409(f)(2).
3.20.1 Has the vessel had its communications equipment inspected and certified within the last 13 months, if subject to the Great Lakes Radio Agreement?
For vessels subject to the Great Lakes Radio Agreement, the vessel must have an inspection and certification of its communications equipment at least once every 13 months. The results of the inspection must be recorded in the ship’s radiotelephone log (see 3.20).
47 CFR 80.953 47 CFR 80.409(f)(2)(v)
This inspection must be made by a technician holding one of the following: a General Radiotelephone Operator License, a GMDSS Radio Maintainer’s License, a Second Class Radiotelegraph Operator’s Certificate, or a First Class Radiotelegraph Operator’s Certificate; and cannot be the vessel’s owner, operator, master, or an employee of any of them.
3.21 Is a valid FCC radio station license posted? (RCP III-D-4) (RCP IV-D-4)
The vessel must have an original, current FCC Ships Station License posted on board; or a copy of the current FCC Ships Station License, with the location of the original noted, posted on board.
47 CFR 80.13 As vessels are required to have AIS equipment, the old PLURALITY type licenses will be discontinued and each vessel will again have its own call sign.
3.22 Where applicable, do all radio operators (i.e. Masters, Mates/Pilots, and Steersmen) have appropriate permits or licenses?
For vessels 26 feet or greater subject to the Bridge-to-Bridge Act, all radio operators (i.e. Masters, Mates/Pilots, Steersmen) must have a Restricted Radiotelephone Operator permit or higher class license. For vessels 26 feet or greater subject to the Great Lakes Radio Agreement, all radio operators (i.e. Masters, Mates/Pilots, Steersmen) must have a Marine Radio Operator permit or higher class license.
For Bridge-to-Bridge Act: 33 CFR 164.72(a)(3) 47 CFR 80.163 33 CFR 26.05 For Great Lakes Radio Agreement: 33 CFR 164.72(a)(3) 47 CFR 80.161 33 CFR 26.05
This permit/license is required for each person who makes arrangements using VHF radiotelephones for crossing, passing, meeting, or overtaking situations with other vessels.
3.23 Is a check-off report turned in or a log entry made at least quarterly verifying that navigation and communication equipment as required by RCP and regulation is present and in good working order? (RCP III-D) (RCP IV-D)
For a compliant answer, the company must have a written procedure which implements a documented checklist or requires a log entry be made at least quarterly to verify required navigation and communication equipment (see 3.24 through 3.41 ) is present and in good working order.
3.24 Is the vessel equipped with VHF radio(s) in good working order? (RCP III-D-3) (RCP IV-D-3)
For vessels greater than 26 feet NOT subject to the Great Lakes Radio Agreement, the vessel must have on board two radios (including portable radios, i.e. handhelds) or one radio with two receivers. If subject to the Great Lakes Radio Agreement: vessels > 26 feet to 123 feet must have one radio on board; vessel > 124 feet must have two radios on board.
33 CFR 164.72(a)(3) 33 CFR 26.03 Great Lakes Radio Agreement: 47 CFR 80.308 47 CFR 80.955
3.24.1 Is the vessel equipped with one or more VHF radios connected to a battery backup? (RCP III-D-8) (RCP IV-D-9)
The vessel must have at least one operable VHF radio connected to a battery backup.
3.25 Is a backup marine radio or telephone communication available? (RCP III-D-18) (RCP IV-D-23)
The vessel must have at least one other emergency communication capability in addition to the VHF radio(s) required in 3.24 and 3.24.1 (e.g. cellular telephone, satellite phone, company radio, etc.).
3.26 Is a public address system and/or internal communication system available and functional? (RCP III-D-21) (RCP IV-D-24)
The vessel must be equipped with an operable public address system and/or internal communication system, if required by regulation. If equipped, the public address system and/or internal communication system must be operable.
For vessels 11 meters or greater, operating more than 3 nautical miles from shore, is the vessel equipped with an emergency position indicating radio beacon (EPIRB)? (RCP IV-D-8)
For vessels 11 meters (36 feet) or greater operating greater than 3 NM from shore, the vessel must have on board a float-free automatically activated Category I 406 MHz Emergency Position Indicating Radio Beacon (EPIRB) stowed in a manner so that it will float free if the vessel sinks. The EPIRB’s NOAA Registration and the EPIRB’s battery must not be expired.
46 CFR 25.26-20(a) 46 CFR 25.26-50
Vessels less than 11 meters (36 feet) must comply with 46 CFR 25.26-20(b).
3.27.1
If equipped, is the EPIRB tested monthly?
For vessels equipped with an EPIRB, it must be tested monthly, and the results of the tests entered in a log or other record carried on board.
Are all required navigation lights in good working order: (33 CFR Subchapter E) (RCP III-D-5) (RCP IV-D-5)
Auditors are expected to verify the navigational lights and day shapes, if applicable, are compliant with the Coast Guard regulations applicable to the vessel through company-provided documentation, tags on the bulbs, records from the Coast Guard, etc. as per the questions in 3.28.1-3.29.
3.28.1
Is the vessel equipped with an operational white masthead light?
The vessel must be equipped with an operational white masthead light placed over the fore and aft centerline of the vessel, except on a vessel of less than 12 meters in length the masthead light may be placed as near as practicable to the fore and aft centerline of the vessel. The masthead light must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 225 degrees and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on either side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 6 miles Vessels 20-50 meters = 5 miles Vessels 12-20 meters = 3 miles Vessels < 12 meters = 2 miles; (3) Be placed so as not to be obstructed; (4) Be located at least one meter higher than the vessel’s sidelights, and must not be so low as to be interfered with by deck lights; applies regardless of length; and (5) For power driven vessels 65.6 feet in length or greater built after 12/24/1981, the vessel’s forward masthead light must be located forward of the sidelights.
If applicable, is the vessel equipped with a second operational white masthead light?
For vessels 50 meters or greater, the vessel must be equipped with a second operational white masthead light placed abaft of and higher than the first (see 3.28.1). Vessels less than 50 meters may exhibit such light, but are not required to do so. The second masthead light must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 225 degrees and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on either side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 6 miles Vessels 20-50 meters = 5 miles Vessels 12-20 meters = 3 miles Vessels < 12 meters = 2 miles; and (3) Be placed so as not to be obstructed. See 33 CFR 84.03 regarding horizontal positioning of masthead lights.
Is the vessel equipped with two operational white masthead lights if pushing ahead or towing alongside below the Huey P. Long Bridge and/or on waters specified by the Secretary in 33 CFR 89.27?
For vessels pushing ahead or towing alongside below the Huey P. Long Bridge and/or on waters specified by the Secretary in 33 CFR 89.27, the vessel must be equipped with two operational white masthead lights in a vertical line placed over the fore and aft centerline of the vessel, except on a vessel of less than 12 meters the masthead lights may be placed as near as practicable to the fore and aft centerline of the vessel. The two masthead lights must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 225 degrees and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on either side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 6 miles Vessels 20-50 meters = 5 miles Vessels 12-20 meters = 3 miles Vessels < 12 meters = 2 miles; (3) Be placed so as not to be obstructed; and (4) Be placed at least one meter vertically apart.
The masthead lights referred to in the question are separate and distinct from the masthead lights required for power driven vessels underway (without a tow) (see 3.15.1 and 3.15.2). Navigation light fixtures must be fitted with a bulb that meets the standard the fixture was approved with.
Is the vessel equipped with an operational green sidelight on the starboard side and an operational red sidelight on the port side?
The vessel must be equipped with an operational green sidelight on the starboard side and an operational red sidelight on the port side. On a vessel of less than 20 meters the sidelights may be combined in one lantern carried on the fore and aft centerline of the vessel, except that on a vessel of less than 12 meters the sidelights when combined in one lantern must be placed as nearly as practicable to the fore and aft centerline of the vessel. Each sidelight must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 112.5 degrees, and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on its respective side; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 3 miles Vessels 12-50 meters = 2 miles Vessels < 12 meters = 1 miles; (3) Be placed so as not to be obstructed; and (4) On vessels 20 meters or more, be fitted with mat black inboard screens that meet the requirements of 33 CFR 84.17; or (5) On vessels less than 20 meters, be fitted with mat black inboard screens if necessary to meet the requirements of 33 CFR 84.17, or with a combined lantern, using a single vertical filament and a very narrow division between the green and red sections, external screens need not be fitted.
Is the vessel equipped with an operational white stern light?
The vessel must be equipped with an operational white stern light placed as nearly as practicable at the stern. The stern light must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 135 degrees, and so fixed as to show the light 67.5 degrees from right aft on each side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 3 miles Vessels 12-50 meters = 2 miles Vessels < 12 meters = 2 miles; and (3) Be placed so as not to be obstructed.
33 CFR 83.23(a)(4) 33 CFR 83.21(c) 33 CFR 83.22
Navigation light fixtures must be fitted with a bulb that meets the standard the fixture was approved with.
3.28.6
Is the vessel equipped with two operational yellow towing lights?
For vessels subject to the Inland Navigation Rules, the vessel must be equipped with two operational yellow towing lights. The two towing lights must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 135 degrees, and so fixed to show the light 67.5 degrees from right aft on each side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 3 miles Vessels 12-50 meters = 2 miles Vessels < 12 meters = 2 miles; and (3) Be placed so as not be obstructed; and (4) Be placed at least one meter vertically apart.
Navigation light fixtures must be fitted with a bulb that meets the standard the fixture was approved with. Notice there is no requirement for these lights to be at a specific any location.
Is the vessel equipped with two operational white masthead lights to be displayed if towing astern on Near Coastal/Ocean or Great Lakes/Inland routes?
For vessels towing astern on Near Coastal/Ocean or Great Lakes/Inland routes, the vessel must be equipped with two operational white masthead lights in a vertical line placed over the fore and aft centerline of the vessel, except on a vessel of less than 12 meters the masthead lights may be placed as near as practicable to the fore and aft centerline of the vessel. The two masthead lights must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 225 degrees and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on either side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 6 miles Vessels 20-50 meters = 5 miles Vessels 12-20 meters = 3 miles Vessels < 12 meters = 2 miles; (3) Be placed so as not to be obstructed; and (4) Be placed at least one meter vertically apart.
The masthead lights referred to in the question are separate and distinct from the masthead lights required for power driven vessels underway (without a tow) (see 3.15.1 and 3.15.2). Navigation light fixtures must be fitted with a bulb that meets the standard the fixture was approved with.
Is the vessel equipped with a third operational masthead light above the others, if towing astern on Near Coastal/Ocean or Great Lakes/Inland routes, and the length of the tow exceeds 656 feet?
For vessels towing astern on Near Coastal/Ocean or Great Lakes/Inland routes, when the length of the tow is greater than 200 meters measuring from the stern of the towing vessel to the after end of the tow, the vessel must be equipped with a third operational white masthead light above the others (see 3.11.7) placed over the fore and aft centerline of the vessel. The third masthead light must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 225 degrees and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on either side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 6 miles Vessels 20-50 meters = 5 miles Vessels 12-20 meters = 3 miles Vessels < 12 meters = 2 miles; (3) Be placed so as not to be obstructed; and (4) Be placed at least one meter vertically apart.
Is the vessel equipped with an operational yellow towing light placed in a vertical line above the white stern light, if towing astern on Near Coastal/Ocean or Great Lakes/Inland routes?
For vessels towing astern on Near Coastal/Ocean or Great Lakes/Inland routes, the vessel must be equipped with an operational yellow towing light placed in a vertical line above the white stern light. The towing light must: (1) Be so equipped to show an unbroken light over an arc of the horizon of 135 degrees and so fixed as to show the light 67.5 degrees from right aft on each side of the vessel; (2) Have an intensity so as to be visible at the minimum range relative to the vessel’s length, as follows: Vessels > 50 meters = 3 miles Vessels 12-50 meters = 2 miles Vessels < 12 meters = 2 miles; and (3) Be placed so as not to be obstructed.
33 CFR 83.24(a)(4) 33 CFR 83.21(d) 33 CFR 83.22
Navigation light fixtures must be fitted with a bulb that meets the standard the fixture was approved with.
3.28.10
Is the vessel equipped with a black diamond shape, if towing astern on Near Coastal/Ocean or Great Lakes/Inland routes and the length of the tow exceeds 656 feet?
For vessels towing astern on Near Coastal/Ocean or Great Lakes/Inland routes, when the length of the tow is greater than 200 meters measuring from the stern of the towing vessel to the after end of the tow, the vessel must be equipped with a black diamond shape where it can best be seen. The diamond shape must consist of two cones, each having a base diameter of not less than 0.6 meter and a height equal to its diameter, having a common base. In a vessel of less than 20 meters, shapes of lesser dimensions but commensurate with the size of the vessel may be used.
3.29 Is a whistle available and in good working order? (RCP III-D-6) (RCP IV-D-6)
For vessels 12-20 meters, the vessel must be equipped with a whistle which has an audible range of 0.5 NM. For vessels 20-100 meters, the vessel must be equipped with a whistle which has an audible range of 1.0 NM.
33 CFR 83.33(a) 33 CFR 86.01(c)
Vessels over 100 meters are required to be equipped with a gong.
3.29.1 If applicable, does the vessel carry a maneuvering light to supplement its whistle signals?
If the vessel carries a maneuvering light to supplement its whistle signals, the maneuvering light must meet the requirements of and be displayed in accordance with the requirements outlined in Inland Navigation Rule 34(b).
33 CFR 83.34(b)
3.30 If applicable, is a bell available and in good working order? (RCP III-D-6) (RCP IV-D-6)
For vessels over 20 meters, the vessel must be equipped with a bell with a diameter at the mouth of the bell that is not less than 300 millimeters.
33 CFR 83.33(a) 33 CFR 86.02(b) 33 CFR 86.23
Vessels over 100 meters are required to be equipped with a gong.
3.31 Is the vessel equipped with a sound signal device? (COLREGS Rule 33) (RCP III-D-7) (RCP IV-D-7)
For vessels less than 12 meters, the vessel must be equipped with a means of making an efficient sound signal (e.g. portable air horn, emergency whistle, or other sound-producing device).
33 CFR 83.33(b)
3.32 Is a swing meter or magnetic compass on board? (RCP III-D-9) (RCP IV-D-10)
For vessels 12 meters or greater, the vessel must be equipped with an operable, illuminated card-type magnetic steering compass readable from the vessel’s main steering station; or if towing exclusively on Western Rivers an operable, illuminated swing-meter or an operable, illuminated card-type magnetic steering compass readable from the vessel’s main steering station.
33 CFR 164.72(a)(4)
3.33 For vessels operating on Oceans/Near Coastal routes, is there a backup means of determining course and direction? (RCP IV-D-10)
For vessels operating on Oceans/Near Coastal routes, in addition to the magnetic compass required by 3.32, the vessel must have a backup means of determining course and direction.
3.34 For vessels operating on Oceans/Near Coastal routes, is the vessel equipped with a rudder angle indicator? (RCP IV-D-20)
For vessels operating on Oceans/Near Coastal routes, the vessel must be equipped with an operable rudder angle indicator.
3.35 For oceangoing vessels, is the vessel equipped with a gyrocompass? (RCP IV-D-10)
For vessels over 1600 gross tons operating on ocean routes, the vessel must be equipped with an operable gyrocompass as required by regulation.
46 CFR 96.17
3.36
Where applicable, is the vessel equipped with two radars, or one radar plus documentation of procedures to address radar failure? (RCP III-D-10) (RCP IV-D-11)
For vessels 12 meters (39.4 feet) or greater, the vessel must be equipped with two operable marine radars which meet the RTCM Standard; or one such radar and one or more written procedures addressing radar failure.
One radar is required by regulation: 33 CFR 164.72(a)(1)
The RTCM (Radio Technical Commission for Maritime Services) has published standards to specify marine radar systems. RTCM Paper71-95/SC112-STD applies to vessels less than 300 GT. RTCM Paper191-93/SC112-X applies to vessels of 300 GT or larger.
3.37
Is a searchlight installed and functional? (RCP III-D-15) (RCP IV-D-19)
For vessels 12 meters (39.4 feet) or greater, the vessel must be equipped with an operable searchlight directable from the main steering station, and it must have a range two times the length of the longest tow.
33 CFR 164.72(a)(2)
3.38
Is the vessel equipped with a defroster or deicer on wheelhouse windows? (where applicable as determined by the company) (RCP III-D-16) (RCP IV-D-21)
The vessel must be equipped with an operable defroster or deicer on wheelhouse windows, where applicable as determined by the company. If a defroster and/or deicer is fitted, it must be operable.
For vessels operating in a VTS area other than Louisville, KY and Los Angeles/Long Beach, CA, is the vessel equipped with a properly installed, operational automatic identification system (AIS)?
Vessels 26 feet or greater and greater than 600 HP operating in a VTS area other than Louisville, KY and Los Angeles/Long Beach, CA, must be equipped with a properly installed, operational AIS that is capable of making an accurate broadcast of the towing vessel’s MMSI, and is maintained with accurate input, upkeep and updating. The towing vessel must be equipped with an AIS to operate within a VTS today and by March 1, 2016 the towing vessel must have the AIS when operating anywhere on the navigable waters of the U.S..
33 CFR 164.46(a)(3)(ii)
Per 33 CFR 164.46(c)(2)(ii), AIS must be maintained in effective operating condition, which includes: the ability to access AIS information from the primary conning position of the vessel; and 33 CFR 164.46(c)(4)(e): Watchkeeping: AIS is primarily intended for use by the Master or person in charge of the vessel, or by the person designated by the Master or person in charge to pilot or direct the movement of the vessel, who must maintain a periodic watch for AIS information.
3.39.1
Is the AIS equipment located at the vessel’s operating station, so as to be available to the person who is controlling the vessel?
The AIS must be located at the vessel’s operating station, so as to be available to the person who is controlling the vessel while underway.
33 CFR 164.46
3.40
Is the vessel equipped with an operable electronic position-fixing device (GPS)? (where applicable) (RCP III-D-19) (RCP IV-D-13)
For vessels 12 meters (39.4 feet) or greater towing seaward of navigable waters of the U.S., and/or greater than 3 NM from shore on the Great Lakes, the vessel must be equipped with an operable electronic position-fixing device (GPS).
33 CFR 164.72(a)(6) 33 CFR 164.41
The USCG discontinued all LORAN C signals effective February 8, 2010.
3.41
Is the vessel equipped with an operable echo depth-sounding device (fathometer)? (not required for towing vessels on Western Rivers or Inland Waters exclusively in USCG District 8) (RCP IV-D-12)
For vessels 12 meters (39.4 feet) or greater operating on other than Western Rivers or Inland Waters exclusively in USCG District 8, the vessel must have on board an operable echo depth-sounding device.
4.1 Is a check-off report turned in or a log entry made at least quarterly verifying that required firefighting and lifesaving equipment is present and in good working order? (RCP III-C) (RCP IV-C)
A check-off report or log entry must be made at least quarterly to verify that required firefighting and lifesaving equipment listed in 4.2-4.28 is present and in good working order.
Refer to Section 11.4 of the Management Audit Worksheet for details regarding the vessel internal auditing procedure. The list should include all of the firefighting and lifesaving equipment listed in Section 4.
4.2
Are a sufficient number of Coast Guard-approved life preservers available and in good working condition? (RCP III-C-1) (RCP IV-C-1)
Vessels less than 40 feet must have Type I, II, or III serviceable Coast Guard approved life preservers of a suitable size for each person. Vessels greater than or equal to 40 feet must have a Type I serviceable Coast Guard approved life preserver of a suitable size for each person. On vessels not carrying passengers for hire, an immersion suit may be substituted for a life preserver, buoyant vest or marine buoyant device. (46CFR25.25-5(a))
46 CFR 25.25-5(a)
4.2.1 Are the required life preservers legibly marked with a Coast Guard approval number?
Life preservers must be marked according to the regulations 46 CFR subchapter Q.
46 CFR 25.25-7 The required marking would include a U.S. Coast Guard approval number which must be readable and remain securely attached to the life preserver.
4.2.2 Are the life preservers readily accessible?
Life preservers must be stored in a readily accessible location.
46 CFR 25.25-9(a) According to Coast Guard personnel, life preservers that are designed to be worn should be readily accessible to all crew members, either in their stateroom, the wheel house, engine room, galley, or other accommodation space.
4.2.3 Is there retroreflective material attached to the upper quadrants of the front and back of all life preservers?
Each life preserver must have Type I retroreflective material attached to the upper quadrants of the front and back.
46 CFR 25.25-15
4.2.4 Does each life preserver have a personal flotation device light attached to the front shoulder area? (not required for towing vessels on Inland or Western Rivers)
PFD lights are not required on PFDs used on towing vessels which operate on Western Rivers or Inland routes. PFD lights are required on towing vessels which operate on Ocean, Coastwise or Great Lakes voyages. When required, each light must be securely attached to the front shoulder area and have a non-expired power source.
46 CFR 25.25-13(a)
4.3 Are the number and condition of life preservers noted at least quarterly on the vessel inspection report or in a log entry? (RCP III-C) (RCP IV-C)
The number and condition of life preservers must be noted at least quarterly on the vessel inspection report or in a log entry.
Refer to Section 11.4 of the Management Audit Worksheet for details regarding the vessel internal auditing procedure.
4.4 For vessels greater than 26 feet, is a Coast Guard-approved ring buoy on board the vessel? (RCP III-C-2) (RCP IV-C-2)
Applies to vessels greater than 26 feet. Each towing vessel 26 feet in length or longer must have at least one approved ring life buoy.
46 CFR 25.25-5(b)(3)) Approved under 46 CFR 160.050
4.4.1 Are all ring buoys stored so as to be immediately available for use?
All ring buoys must be stored so as to be immediately available for use.
46 CFR 25.25-9(b)
4.4.2 Are all ring buoys in serviceable condition?
All ring buoys must be in a serviceable condition.
If the company’s safety management system does not specifically permit personnel working on towing vessels to wear Type II or Type III PFDs in lieu of Type V work vests, are a sufficient number of Coast Guard-approved work vests available and in good working condition? (RCP III-C-3) (RCP IV-C-3)
If a company’s safety management system permits personnel working on towing vessels to wear Coast Guard approved Type II or Type III PFDs in lieu of Type V work vests, as discussed in U.S. Coast Guard policy letter (CF-543 policy letter 10-06), the RCP does not require that the vessel have additional work vests available. However, in lieu of such a statement in the safety management system, there must be a sufficient number of Coast Guard approved work vests (Type V) must be available for crew members working where they are exposed to falling overboard.
46 CFR 26.30-5 A sufficient number of work vests is defined as one per crew member. If self-inflating work vests are being used, they should be maintained in accordance with the manufacturer’s directions. For additional information, see 46 CFR 140.430 – the Wearing of Work Vests.
4.5.1 If applicable, are work vests stowed separately from the regular stowage of required lifesaving devices?
If applicable, approved work vests must be stowed separately from the regular stowing of required PFDs.
46 CFR 26.30-10
4.6 For Coastal vessels, does the vessel have an inflatable life raft? (Not required for towing vessels on Inland or Western Rivers) (RCP IV-C-5)
If applicable, coastal towing vessels must carry an inflatable life raft that meets USCG requirements and inspection standards.
Under proposed subchapter M, the route determines whether a SOLAS A Pack or SOLAS B Pack should be used. See Proposed Rule Table 141.305.
4.7 For Coastal vessels, are there immersion suits available for every person aboard? (where applicable) (RCP IV-C-12)
Each vessel not carrying passengers for hire may substitute an immersion suit for a life preserver, buoyant vest or marine buoyant device required under paragraphs (b) or (c) of section 46 CFR 25.25-5. Each vessel, except those vessels operating between 32 degrees north latitude and 32 degrees south latitude, must carry immersion suits approved under approval series 160.171 or anti-exposure suits approved under approval series 160.153 of suitable size for each person assigned to the rescue boat crew and each person assigned to a marine evacuation system crew.
46 CFR 25.25-5(e) 46 CFR 199.70(c)
Refer to USCG Navigation and Inspection Circular (NVIC 7-91).
4.8 Does the vessel have a B-V semi-portable fire extinguishing system and/or a fixed fire extinguishing system installed to protect the engine room?
Towing vessels in Inland service, and towing vessels in Ocean or Coastal service whose construction was contracted for before 8/27/03 must have either a B-V semi-portable fire extinguishing system or a fixed fire extinguishing system installed to protect the engine room. Towing vessels in unrestricted Ocean or Coastal service whose construction was contracted for on or after 8/27/03 must have both a B-V semi-portable fire extinguishing system and a fixed fire extinguishing system installed to protect the engine room.
46 CFR 27.303 46 CFR 27.305
This requirement does not apply to any towing vessel pushing a barge ahead or hauling a barge alongside, when the barge’s coastwise or Great Lakes route is restricted (as indicated on its certificate of inspection), so that the barge may operate “in fair weather only, within 12 miles of shore,” or with words to that effect. (46 CFR 27.305(a)(c)) See 46 CFR 27.101 for more information on fixed fire extinguishing systems. Additional reference - USCG Policy Letter 10-06 which provides “temporary” exemptions from the requirements in 46 CFR 25.25, 46 CFR 25.30-15 (as it pertains to towing vessels) and 46 CFR 27 Subpart C as it establishes guidance with regards to the carriage of excess lifesaving and firefighting equipment on “uninspected” towing vessels.
4.9 Are a sufficient number of Coast Guard-approved hand-portable fire extinguishers and semi-portable fire extinguishing systems available and in good working condition, as per the Table in 46 CFR 25.30-20(A)(1) & (46 CFR 25.30-20)(a))? (RCP III-C-4) (RCP IV-C-4)
When a vessel is 26 feet or more, but less than 40 feet, with a fixed system, the vessel must be equipped with at least one B-I hand portable fire extinguisher. When a vessel is 26 feet or more, but less than 40 feet, without a fixed system, the vessel must be equipped with at least two B-I or one B-II hand portable fire extinguishers. When a vessel is 40 feet or more, but less than 65 feet, with a fixed system, the vessel must be equipped with at least two B-I or one B-II hand portable fire extinguishers. When a vessel is 40 feet or more, but less than 65 feet, without a fixed system, the vessel must be equipped with at least three B-I or two B-II hand portable fire extinguishers. (One B-I and one B-II would also satisfy this requirement.)
46 CFR 25.30-20(a) For the purpose of the fire fighting regulations, paragraph (a) of 46 CFR 25.30-20 applies to motorboats. See 46 CFR 24.10-1 for the following definitions: Motorboats are defined as: any vessel 65 feet or less in length with propulsion machinery. Motor vessel means any vessel more than 65 feet in length, which is propelled by machinery other than steam. An uninspected towing vessel 65 feet or less in length must comply with these regulations.
4.9.1 Does the vessel have a minimum number of hand portable fire extinguishers as required per Table 25.30-20(b)(1) fitted other than in the machinery space, if the vessel is over 65 feet in length?
When a vessel is 50 gross tons or more, but less than 100 gross tons, the vessel must be equipped with at least two B-II hand portable fire extinguishers fitted other than in the machinery space. When a vessel is 100 gross tons or more, but less than 500 gross tons, the vessel must be equipped with at least three B-II hand portable fire extinguishers fitted other than in the machinery space. When a vessel is 500 gross tons or more, but less than 1,000 gross tons, the vessel must be equipped with at least six B-II hand portable fire extinguishers fitted other than in the machinery space. When a vessel is 1,000 gross tons or more, the vessel must be equipped with at least eight B-II hand portable fire extinguishers fitted other than in the machinery space.
46 CFR 25.30-20(c)(1) 46 CFR Table 25.30-20(b)(1)
For the purpose of the fire fighting regulations, paragraph (c) of 46 CFR 25.30-20 applies to motor vessels. Motor vessels are defined as: any vessel more than 65 feet in length which is propelled by machinery other than steam. An uninspected towing vessel more than 65 feet in length must comply with these regulations. Fire extinguishing equipment required by 46 CFR Table 25.30-20(b)(1) are required to be distributed throughout the vessel interior and/or exterior, other than in the machinery spaces. For fire extinguishing equipment required to be carried within the machinery spaces see 46 CFR 25.30-20(c)(2).
4.10 Does the vessel, if it is longer than 65 feet, have one B-II hand portable fire extinguisher for each 1,000 brake horsepower (B.H.P.) of the main engines or fraction thereof fitted in the machinery space?
The vessel must have at least one B-II hand portable fire extinguisher for each 1,000 brake horsepower (B.P.H.) of the main engines or fraction thereof fitted in the machinery space. For vessels greater than 65 feet in length; not more than 6 such fire extinguishers need be carried.
4.11 Are all fire extinguishers Coast Guard or UL approved?
All fire extinguishers must be Coast Guard or UL approved.
46 CFR 25.30-5 See NVIC No. 13-86 for additional information regarding the approval of certain UL listed portable and semi-portable fire extinguishers in lieu of Coast Guard approved extinguishers. In regards to hand portable fire extinguishers, the mounting bracket should have a belly strap.
4.12 If installed, is the CO2 fixed system designed and installed in accordance with 46 CFR 76.15?
The company must provide documentation that the CO2 fixed system, if installed, was designed and installed in accordance with the federal regulations.
46 CFR 25.30-15 46 CFR 76.15
46 CFR 76.15 outlines installation requirements for fixed fire extinguishing equipment. Fixed fire extinguishing equipment installed on uninspected towing vessels must comply with these requirements.
4.13
Are flare kits available (if applicable)? (RCP III-C-6) (RCP IV-C-7)
If the company’s safety management system specifies that flare kits are to be carried onboard their towing vessels, each company owned or operated towing vessel must comply with the company’s specified requirements.
33 CFR 175.101 addresses carriage of flares and other visual distress signals for boats operating on the coastal waters of the United States and on the high seas beyond the territorial seas, for boats owned in the United States. Flares should be regularly inspected and not expired.
4.14
Is a fire axe available? (RCP III-C-7) (RCP IV-C-8)
At least one fire axe must be available on each towing vessel owned or operated by the company in accordance with the expectations listed in the company’s safety management system.
A fire axe is required under Subchapter M. 46 CFR 142.227.
Is a first aid or trauma kit available, properly stocked and maintained? (RCP III-C-8) (RCP IV-C-9)
The vessel must have a first aid kid available, properly stocked and maintained in accordance with expectations listed in the company’s safety management system.
An OSHA Standard listed in 29 CFR 1910.151 refers to an (ANSI) Z308.1-1998 standard which identifies the minimum requirements for a workplace first aid kit. The company determines the meaning of “properly stocked.” The first aid kid should be maintained with medical supplies and equipment that have a current date (unexpired).
4.16
Are smoke alarms to protect all accommodation spaces installed and in good working condition? (RCP III-C-9) (RCP-IV-C-10)
The vessel must have smoke alarms to protect all accommodation spaces. The smoke alarms must be in good working order. Smoke alarms may be hardwired or battery powered.
This item is likely to become a requirement of Subchapter M. See 46 CFR 142.330(b) for requirements for smoke detection in berthing spaces in Subchapter M. The galley should be considered as an accommodation space. The company should provide for a periodic inspection of smoke alarms and records of these inspections should be available to the auditors for verification. Auditors should also check the expiration dates of the smoke detectors.
4.17
Is emergency lighting installed and in good working condition? (RCP III-C-10) (RCP IV-C-11)
The vessel must have emergency lighting installed and in good working condition. The emergency lighting equipment should be provided in accordance with the expectations of the company’s safety management system.
Is the vessel equipped with an operable general alarm?
All vessels must have a general alarm installed. The vessel may use a PA system instead of a general alarm if it meets requirements of 46 CFR 27.201(b).
46 CFR 27.201
4.18.1
Does the general alarm have a contact-maker at the operating station?
The general alarm must have a contact-maker at the operating station.
46 CFR 27.201(a)(1) 46 CFR 27.101 defines an operating station as the principal steering station on the vessel, from which the vessel is normally navigated.
4.18.2
Is the general alarm capable of notifying persons in any accommodation, work space and the engine room?
The general alarm must be capable of notifying persons in any accommodation, work space and the engine room.
46 CFR 27.201(a)(2) 46 CFR 27.101 defines a work space as any area on the vessel where the crew could be present while on duty and performing their assigned tasks.
4.18.3
Does the vessel have installed, in the engine room and any other area where background noise makes a general alarm hard to hear, a supplemental flashing red light that is identified with a sign that reads “Attention General Alarm – When Alarms Sounds or Flashes Go to Your Station?”
The vessel must have a flashing red light that is identified with a sign that reads “Attention General Alarm – When Alarm Sounds or Flashes Go to Your Station” installed in the engine room and any other area where background noise makes a general alarm hard to hear.
46 CFR 27.201(a)(3) Note: The sign required by this regulation is not required for general alarms that are located in areas where background noise does not make it hard to hear the general alarm. It is a best practice to post a sign near the alarm identifying it as the general alarm.
4.18.4
Is the general alarm tested at least once each week?
The general alarm must be tested at least once each week. Note: The general alarm must also be tested in conjunction with the required monthly fire drills as specified in 46 CFR 27.209(c)(3). The results of the weekly test should be entered into the log or other records carried on board the vessel.
46 CFR 27.201(a)(4) 46 CFR 27.209(c)(3)
A record of required general alarm tests should be kept and the entry should state the unit was tested and also state that it was, or was not, found to be in good working order, as appropriate. This record should be available to the auditor.
Is there a fire detection system to detect engine room fires? (RCP III-C-11) (RCP IV-C-13)
Vessels must have a fire-detection system to detect engine-room fires. A vessel whose construction was contracted for prior to 1/18/2000 may use an existing engine-room monitoring system (with fire detection capability) instead of a fire-detection system.
46 CFR 27.203 The company may have a written waiver from the Coast Guard stating the fire detection system is not required for that vessel. That waiver, if one exists, should be displayed in the wheelhouse.
4.19.1
Is each fire detector, each control panel, and each fire alarm approved under 46 CFR 161.002 or listed by an independent testing laboratory?
Each detector, each control panel and each fire alarm must be approved under 46 CFR 161.002 or listed by an independent testing laboratory. If you use an existing engine-room-monitoring system (with fire-detection capability), each detector must be listed by an independent testing laboratory.
Is there documentation to verify that the fire detection system is certified by a Registered Professional Engineer or recognized class society and was installed and tested and maintained in line with the manufacturer’s design manual?
The vessel must have records available from a Registered Professional Engineer or recognized class society member certifying the system complies with paragraphs (a) through (f) of 46 CFR 27.203.
A NICET Level IV, Senior Engineering Technician certification is allowed on a case by case basis if specific requirements are met. See TVNCOE FAQ for details on these requirements. The auditor is to be verifing the presence of inspection records, not testing the system itself. The system is also required to be tested during monthly fire drills and training. If the manufacturer’s manual specifies that testing must occur more frequently than once per month, then that standard would apply, and one of the required tests would need to be accomplished during the required drills and training. See question 4.23.1 for an additional requirement on crew member fire fighting training.
4.19.3
Is the system arranged and installed so a fire in the engine room automatically sets off alarms on a control panel at the operating station?
The system must be arranged and installed so that a fire in the engine room automatically sets off alarms on a control panel at the operating station.
46 CFR 27.203(c) If there is a second wheelhouse, the system must automatically set off alarms at all operating stations.
4.19.4
Does the fire detection system have an audible alarm to notify crew at the operating station(s)?
The system must have an audible alarm to notify crew at the operating station(s).
Does the system have labels for all switches and indicator lights, identifying their function?
The system must have labels for all switches and indicator lights.
46 CFR 27.203(d)(5)
4.19.6
Does the system draw power from two sources?
The system must draw power from two sources.
46 CFR 27.203(e) Typically, the two power sources are the main power from the vessel’s generators and the second is from a battery backup.
4.20
Is the vessel equipped with internal communications between the engine room and operating station with a main or reserve power supply that is independent of the vessel’s electrical system? (two-way communications between operating station & engine room; not required if more than one screw)
The internal communication system must provide voice communication and calling between the operating station and either the engine room or a location immediately adjacent to an exit from the engine room. Twin-screw vessels with operating-station control for both engines are not required to have internal communication systems. When the operating-station’s engine controls and the access to the engine room are within 10 feet of each other and allow unobstructed visual contact between them, direct voice communication is acceptable.
46 CFR 27.205
4.21
Is a remote engine fuel shutoff valve installed? (RCP III-C-12) (RCP IV-C-14)
The vessel is required to have a positive, remote fuel shutoff valve fitted on any fuel line that supplies fuel directly to an engine or generator, located near the source of supply and operable from a safe place outside the space where the valve is installed.
46 CFR 27.207 Refer to USCG Towing Vessel National Center of Expertise website. Select the link for FAQs, then select the link for firefighting and protection, and approximately three quarters down the page is more specific information about fuel shut off valves. The best practice is to ensure the crew knows how to test the remote engine fuel shut off valve.
Each remote valve control is required to be marked in clearly legible letters, at least 25 mm (1 inch) high, indicating the purpose of the valve and the way to operate it.
46 CFR 27.207
4.22 Are heat or flame detectors installed in the galley? (RCP III-C-13) (RCP IV-C-15)
Heat or flame detectors must be installed in the galley, if required by regulation.
This is likely to become a requirement of Subchapter M. See 46 CFR 142.330 (c).
4.23 Does the entire crew of the vessel participate in drills and instruction at least monthly on their fire-fighting duties?
The entire crew must participate in drills and receive instruction at least monthly so that all crew members are familiar with their fire-fighting duties and with the specific contingencies of 46 CFR 27.209(a). Alternatively, to meet the instruction requirement, the crew may view video training materials concerning at least the contingencies listed in 46 CFR 27.209(a) and participate in a discussion led by someone familiar with the contingencies.
46 CFR 27.209
4.23.1 Do the fire training drills take place on board the vessel, and include participation by all crew members, using or simulating use of the emergency equipment, testing of all alarm and detection systems and putting on protective clothing, if the vessel is so equipped?
The fire training drills must take place on board the vessel and include participation by all crew members, breaking out and using, or simulating the use of emergency equipment, testing of all alarms and detection systems, and putting on protective clothing, by at least one person, if the vessel is so equipped.
46 CFR 27.209(c) Note: Testing of the vessel’s fire detection system is required by this paragraph and such testing is required to occur at least once each month as part of the required fire training and drills. Refer to question 4.19.2 for additional information regarding testing of the fire detection system.
4.23.2 Is a safety orientation provided to a crew member who has not participated in the fire drill and instruction within 24 hours of reporting for duty, covering the contingencies listed in 46 CFR 27.209(a)?
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).
46 CFR 27.209(d) & (e)
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.
For questions 4.24 - 4.24.3, where applicable, the company should have written documentation attesting to the vessel’s compliance with the regulation for the auditor to review. The auditor is not expected to be conducting an inspection of these elements of the vessel to verify compliance.
4.24 For vessels contracted for on or after 1/18/2000, except vessels less than 24 meters in length, is each integral fuel tank equipped with a vent that connects to the highest point of the tank, and discharges on a weather deck through a bend of 180 degrees?
This requirement applies to all UTVs contracted for on or after 01/18/2000, except that a towing vessel of less than 24 meters (79 feet) in length may comply with 46 CFR 27.211(f), instead. Each integral fuel tank must be equipped with a vent that connects to the highest point of the weather deck through a bend of 180 degrees. Vents from two or more tanks may combine in a system that discharges on a weather deck.
46 CFR 27.211(d)(1)
4.24.1 If applicable, does each fuel tank vent appear to be equipped with a 30-by-30-mesh corrosion-resistant flame screen?
The fuel tank vent must be equipped with a 30-by-30 mesh corrosion-resistant flame screen.
46 CFR 27.211(d)(1) This requirement applies to all UTVs contracted for on or after 01/18/2000, except that a towing vessel of less than 24 meters (79 feet) in length may comply with 46 CFR 27.211(f), instead.
4.24.2 If applicable, is each vent pipe’s cross-sectional area not less than 0.484 square inches for any tank filled by gravity, or not less than that of the fill pipe for any tank filled under pressure?
Each vent pipe’s cross-sectional area must not be less than 0.484 square inches for any tank filled by gravity, or not less than that of the fill pipe for any tank filled under pressure.
46 CFR 27.211(d)(2) This requirement applies to all UTVs contracted for on or after 01/18/2000, except that a towing vessel of less than 24 meters (79 feet) in length may comply with 46 CFR 27.211(f), instead.
4.24.3 If applicable, is there documentation to verify that the vessel’s fuel piping meets the requirements of 46 CFR 27.211(e)?
The company must provide documentation that verifies the vessel is in compliance with all of the fuel piping requirements of 46 CFR 27.211(e).
46 CFR 27.211(e) This requirement applies to all UTVs contracted for on or after 01/18/2000, except that a towing vessel of less than 24 meters (79 feet) in length may comply with 46 CFR 27.211(f), instead. It may be helpful, if possible, to have documentation from the builder or an engineer that all fuel piping meets the specified requirements.
4.24
4.25
Does the vessel have a fixed fire pump capable of producing the required pressure and volume, or a portable fire-pump capable of producing required pressure and volume?
The towing vessel must be equipped with either a fixed fire pump or a portable fire pump that is capable of producing required pressure and volume. If the vessel is equipped with both a fixed and portable pump, and one meets the requirement but the other does not, answer the question based on the pump that meets the requirement.
Fixed fire pump must comply with: 46 CFR 27.301 opening paragraph & 46 CFR 301(a)(b)(c)&(d) Portable fire pump must comply with: 46 CFR 301 opening paragraph & 46 CFR 301(e)&(f)
Note: The regulations do not require the presence of documentation to verify the portable fire pump capability, but this is a best practice. This documentation could be included on a label on the pump, a company’s record of the result of the pump test or as a separate written document from the pump’s manufacturer.
If the vessel is equipped with a fixed fire pump, is the fixed fire pump capable of delivering water at a pitot-tube pressure of at least 344 kPa (50 psi) and a flow rate of at least 300 lpm (80 gpm)?
If the vessel is equipped with a fixed fire pump, it must be capable of delivering water simultaneously from the two highest hydrants, or from both branches of the fitting if the highest hydrant has a Siamese fitting, at a pitot-tube pressure of at least 344 kPa (50 psi) and a flow rate of at least 300 lpm (80 gpm).
46 CFR 27.301(a)(1) Per AWO, documentation that the fixed fire pump meets this standard is also acceptable. See also NVIC 6-72 A.2.2 regarding proper testing procedures.
4.24.2
4.25.2
If the vessel is equipped with a fixed fire pump, can the fire pump be energized remotely from outside the machinery space and at the pump? (RCP III-C-16) (RCP IV-C-17)
If the vessel is equipped with a fixed fire pump, that pump must be capable of being energized from outside the machinery space and at the pump.
46 CFR 27.301(a)(2) While this item is a previous RCP recommendation, it is a Coast Guard requirement.
4.24.3
4.25.3
If the vessel is equipped with a fixed fire pump, are all valves necessary for the operation of the fire main kept in the open position, or are all valves capable of operation from the same place where the remote fire pump control is located?
If the vessel is equipped with a fixed fire pump, all valves necessary for the operation of the fire main must be kept in the open position, or all valves must be capable of operation from the same place where the remote fire pump control is located.
46 CFR 27.301(b)
4.24.4
4.25.4
If the vessel is equipped with a fixed fire pump, does the fire main have a sufficient number of fire hydrants with an attached hose to reach any part of the machinery space using a single length of fire hose? (RCP III-C-5) (RCP IV-C-6)
The fire main must have a sufficient number of fire hydrants with an attached hose to reach any part of the machinery space using a single length of fire hose.
If the vessel is equipped with a fixed fire pump, does each fire hydrant have attached to it, at least 50 feet of lined commercial fire-hose, at least 40mm (1.5 inches) in diameter, 15 meter (50 feet) in length, and fitted with a nozzle made of corrosion-resistant material, capable of providing a solid stream and a spray-pattern?
If the vessel is equipped with a fixed fire pump, each fire hydrant must have attached to it, at least 50 feet of lined commercial fire-hose, at least 40mm (1.5 inches) in diameter, 15 meters (50 feet) in length, and fitted with a nozzle made of corrosion-resistant material capable of providing a solid stream and a spray-pattern.
46 CFR 27.301(d) The company should have documentation on the fire pump or the testing that has been done to confirm compliance with the regulation.
4.24.6
4.25.6
If the vessel is equipped with a portable fire pump, is the portable fire pump self-priming and power driven?
The portable fire pump must be self-priming and power driven.
46 CFR 27.301(e)
4.24.7
4.25.7
If the vessel is equipped with a portable fire pump, is the portable fire pump capable of delivering a minimum capacity of at least 300 lpm (80 gpm) at a discharge gauge pressure of not less than 414 kPa (60 psi), measured at the pump discharge?
If the vessel is equipped with a portable fire pump, the portable fire pump must be capable of delivering a minimum capacity of at least 300 lpm (80 gpm) at a discharge gauge pressure of not less than 414 kPa (60 psi), measured at the pump discharge.
46 CFR 27.301(e)(1)
4.24.8
4.25.8
If the vessel is equipped with a portable fire pump, is the portable fire pump equipped with a sufficient amount of lined commercial fire hose at least 40mm (1.5 inches) in diameter, 15 meters (50 feet) in length, immediately available to attach to it so that a stream of water will reach any part of the vessel?
If the vessel is equipped with a portable fire pump, the portable fire pump must be equipped with a sufficient amount of lined commercial fire hose at least 40mm (1.5 inches) in diameter, 15 meters (50 feet) in length, immediately available to attach to it so that a stream of water will reach any part of the vessel.
46 CFR 27.301(e)(2)
4.24.9
4.25.9
If the vessel is equipped with a portable fire pump, is the portable fire pump equipped with a nozzle made of corrosion-resistant material capable of providing a solid stream or a spray-pattern?
If the vessel is equipped with a portable fire pump, the portable fire pump must be equipped with a nozzle made of corrosion-resistant material capable of providing a solid stream or a spray-pattern.
5.1 Does the vessel have the required spill containment at each fuel oil and bulk lubricating oil tank vent, overflow and fill pipe? (RCP III-F-1) (RCP IV-F-1)
(a) A ship of 300 GT or more constructed after June 30, 1974 must have a fixed container or enclosed deck area under or around each fuel oil or bulk lubricating oil tank vent, overflow and fill pipe that: (1) For a ship of 300 or more but less than 1600 GT has a capacity of at least one-half barrel; and (2) For a ship of 1600 or more GT has a capacity of one barrel
(b) A ship of 100 GT or more constructed before July 1, 1974, and a ship of 100 or more but less than 300 GT constructed after June 30, 1974 must: (1) meet paragraph (a)(1) of this section; or (2) equip each fuel oil or bulk lubricating oil tank vent, overflow and fill pipe during oil transfer operations with a portable container of at least a 5 U.S. gallon capacity; or (3) if the ship has a fill fitting for which containment is impractical, use an automatic back pressure shut-off nozzle.
33 CFR 155.320
5.2 Is containment of bilge slops sufficient and free of any leaks? (RCP III-F-2) (RCP IV-F-2)
A U.S. non-oceangoing ship in the navigable waters of the U.S. must have the capacity to retain on board all oily mixtures and discharge these oily mixtures to a reception facility. The vessel may retain the oily mixtures on board in the ship’s bilge.
33 CFR 155.330
5.3 Is perimeter containment around fueling stations sufficient and free of any leaks? (RCP III-F-9) (RCP IV-F-9)
Perimeter containment around fueling stations must be sufficient and free of leaks.
5.4 Does the vessel have a pumping/discharge system for oily water mixtures?
Required for non-oceangoing vessels greater than 100 GT and for oceangoing vessels 100 to 399 GT; vessels must have a pumping/discharge system for oily water mixtures.
33 CFR 155.410
5.4.1
Where applicable, does the vessel meet the requirements of 33 CFR 155.410 for pumping, piping and discharge requirements?
A non-oceangoing vessel of 100 GT or more that is fitted with main or auxiliary machinery spaces must have (1) at least one pump installed to discharge oily mixtures through a fixed piping system to a reception facility; (2) the piping system required by this section has at least one outlet that is accessible from the weather deck; (3) each outlet required by this section has a shore connection that is compatible with reception facilities in the ship’s area of operation; and (4) the ship has a stop valve for each outlet required by this section. This does not apply to a ship that has approved oily-water separating equipment for the processing of oily mixtures from bilges or fuel oil tank ballast.
33 CFR 155.410
5.5 If the vessel is equipped with an oily water separator, is the oily water separator equipment functional? (RCP III-F-3) (RCP IV-F-3)
A vessel is not required to be equipped with an oily water separator, but if it is equipped with one, then the regulation must be followed to be in compliance. Oily water separating equipment and bilge alarms must be approved under either 46 CFR 162.050 or MARPOL 73/78 Annex I.
33 CFR 155.380 46 CFR 162.050 MARPOL 73/78 Annex I
When the bilge discharge monitoring alarm is set off, the system is discharging 15 ppm and the system should shut down automatically or be shut down manually if an automatic system is not available.
5.5.1 Where applicable, does the vessel’s staff training include familiarization in the operation and maintenance of the oily water separator equipment?
If the vessel is equipped with an oily water separator, the vessel’s staff training must include familiarization in the operation and maintenance of the oily water separator equipment.
5.5.2 Where applicable, is the routine maintenance of the oily water separating equipment and the bilge alarm clearly defined and recorded?
The routine maintenance of the oily water separating equipment and the bilge alarm must be clearly defined by the manufacturer in the associated operating and maintenance manuals. All routine and repair maintenance must be recorded and should be on board.
33 CFR 155.380(f)
5.6 For vessels over 26 feet, is there an oil pollution placard posted in each machinery space or at the bilge and ballast pump control station? (RCP III-F-4) (RCP IV-F-4)
Vessels larger than 26 feet in length must have a placard of at least 5 by 8 inches made of durable material fixed in a conspicuous place in each machinery space, or at the bilge and ballast pump control station, stating the following: “Discharge of Oil Prohibited.” The placard must be printed in the language or languages understood by the crew.
33 CFR 155.450
5.7 Where applicable, does the vessel’s storage location for oil or hazardous material meet the requirements of 33 CFR 155.470 ? (this question applies to carrying fuel oil or bulk oil forward of a collision bulkhead)
(a) In a vessel of 400 GT and above, for which the building contract or keel was placed after January 1, 1982, oil or hazardous material must not be carried in a forepeak tank or a tank forward of the collision bulkhead.
(b) A self-propelled vessel of 300 GT and above, to which paragraph (a) does not apply, may not carry bulk oil or hazardous material in any space forward of a collision bulkhead except: (1) if constructed after June 30, 1974, fuel oil for use on the ship may be carried in tanks forward of a collision bulkhead, if such tanks are at least 24 inches inboard of the hull structure; or (2) if constructed before July 1, 1974, fuel oil for use on the vessel may be carried in tanks forward of a collision bulkhead, if such tanks were designated, installed or constructed for fuel oil carriage before July 1, 1974.
5.8 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?
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.
VGP Section 4.1 pg 64
Refer to VGP Fact Sheet Section 6 pg 148 for additional information.
5.8.1 If applicable, does the company have written records to document the vessel’s compliance with their written VGP procedures and/or forms?
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 forms.
VGP Section 4.1
5.9 Where applicable, if the vessel utilizes ballast water tanks, does the vessel have a written ballast water management system policy?
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.
33 CFR 151.2025 33 CFR 151.2015
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 that operate in more than one COTP zone take on and discharge ballast water exclusively in one COTP zone.
5.9.1 Where applicable, does the company have written records that document compliance with the written ballast water management policy?
The company must have written records that document compliance with the written ballast water management policy.
5.9.2 Where applicable, for towing vessels that take on and discharge ballast water within a single COTP zone, is the vessel maintaining the necessary records in order to complete the annual report required by 33 CFR 151.2060 (b)-(f)?
Where applicable, towing vessels that take on and discharge ballast water within a single COTP zone must keep records and complete the annual report required by 33 CFR 151.2060 (b)-(f).
33 CFR 151.2060 (e) and (f)
5.10 If applicable, does the vessel have a Garbage Management Plan? (RCP II-E-2)
Garbage Management Plans are only required 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.
33 CFR 151.51 33 CFR 151.57
Even though not required by these regulations, garbage management plans are beneficial to make sure garbage is not discharged into navigable waterways.
5.10.1 Does the vessel appear to meet the requirements of the Garbage Management Plan? (RCP II-E-2)
Required by regulation for oceangoing vessels of 40 feet or more in length. Vessels that have a Garbage Management Plan must meet the requirements of their Garbage Management Plan.
33 CFR 151.57
5.11 If applicable, does the vessel have a written garbage log available for review? (RCP II-E-2)
A written garbage log is required to be maintained by ocean-going vessels larger than 400 GT.
33 CFR 151.55
5.11.1 If applicable, does the vessel appear to be in compliance with the company’s procedure for maintaining a garbage log? (RCP II-E-2)
The vessel must be in compliance with the company’s procedure for maintaining a garbage log.
5.12 Does the vessel have garbage placards (MARPOL) posted in prominent locations and in sufficient numbers so that they can be read by the crew and passengers? (RCP III-F-5) (RCP IV-F-5)
The vessel must have one or more placards at least 20 cm wide by 12.5 cm high, made of a durable material and legible, notifying the reader of the following requirements: (1) The discharge of all garbage is prohibited into the navigable waters of the U.S. and into all other waters except as specifically allowed; (2) The discharge of all forms of plastic into all waters is prohibited; (3) A person who violates the above requirements is liable for civil and/or criminal penalties; and (4) Regional, state and local restrictions on garbage discharges may also apply. For vessels while operating on the Great Lakes or their connecting or tributary waters, the placard must (1) notify the reader of the information in paragraph (c) of this section; or (2) notify the reader of the following: (i) except as allowed by 33 CFR 151.66, the discharge of all garbage into the Great Lakes or their connecting or tributary waters is prohibited; and (ii) a person who violates the above requirements is liable for a civil penalty for each violation, and the criminal penalties of a class D felony.
33 CFR 151.59 The USCG requires a minimum of one placard, but is authorized to require the vessel to display additional placards if it deems necessary to provide sufficient notification of the requirements. Placards can often be found, but are not required to be, in the galley and wherever garbage is stowed prior to being removed from the vessel.
5.13 Does the vessel comply with the requirements for universal waste disposal?
The vessel must comply with the requirements for universal waste disposal. Per 40 CFR 273.13, the small quantity handler of universal waste must manage said universal waste in a way that prevents releases of any universal waste or component of universal waste to the environment.
40 CFR part 273 Universal waste means any of the following hazardous wastes that are subject to the universal waste requirements of part 273, including includes certain types of batteries, fluorescent lighting/lamps, mercury-containing equipment (eg. mercury switches and thermostats) and pesticides.
5.14 If the vessel is equipped with installed toilet facilities, is the certified marine sanitation device (MSD) installed appropriate for the length of the vessel and the operating area? (RCP II-E-5) (RCP III-F-6) (RCP IV-F-6)
If the vessel is equipped with installed toilet facilities, the MSD installed must be appropriate for the length of the vessel and the operating area.
33 CFR 159.7(a) A type I MSD is allowed if the vessel is 65 feet or less in overall length. If over 65 feet in overall length, the vessel must have either a Type II MSD or Type III holding tank. An incinolet system must be a “WB” model to be an approved Type III MSD.
5.15 Is there an adequate supply of chemicals for Types I and/or II MSD installed on board in accordance with manufacturer instructions? (RCP II-E-5) (RCP III-F-6)
The vessel must have an adequate supply of chemicals on board for the Types I and/or II MSD installed on the vessel, in accordance with manufacturer instructions.
33 CFR 159.65 The device must be equipped with either a means of indicating the amount in the device of any chemical that is necessary for its effective operation; or a means of indicating when chemicals must be added for the proper continued operation of the device. It is recommended that chemicals be stored in a well-ventilated area, and kept outside of the engine room.
5.16 If the vessel is equipped with a Type I or Type II MSD, does the MSD have the proper certification label, operating instructions and safety precautions placard? (RCP II-E-5)
If the vessel is equipped with a Type I or Type II MSD, the device must have a placard suitable for posting on which is printed the operating instructions, safety precautions and warnings pertinent to the device.
5.17 If the vessel is equipped with a Type I or Type II MSD and operating on a body of water where the discharge of treated or untreated sewage is prohibited by the EPA under 40 CFR 140.3 or 40 CFR 140.4, is each MSD secured in a manner that prevents the discharge of treated or untreated sewage overboard? (RCP II-E-2)
Each Type I or Type II MSD must be secured in a manner which prevents the discharge of treated or untreated sewage. Acceptable methods of securing the device include: (1) closing the seacock and removing the handle; (2) padlocking the seacock in the closed position; (3) using a non-releasable wire-tie to hold the seacock in the closed position; or (4) locking the door to the space enclosing the toilets with a padlock or door handle key lock.
33 CFR 159.7 (b)
5.18 If the vessel is equipped with a Type III MSD, is the vessel’s MSD piping secured to prevent overboard discharge? (RCP II-E-2)
A Type III MSD must be designed to prevent the overboard discharge of treated or untreated sewage or any waste derived from sewage. Acceptable methods of securing the device include: (1) closing each valve leading to an overboard discharge and removing the handle; (2) Padlocking each valve leading to an overboard discharge in the closed position; or (3) using a non-releasable wire-tie to hold each valve leading to an overboard discharge in the closed position.
33 CFR 159.53(c) 33 CFR 159.7(c)
5.19 Are oil transfer procedures available for transfers TO the vessel? (RCP III-F-7) (RCP IV-F-7)
Oil transfer procedures are required for vessels with 10,500 gallon or greater total capacity of fuel and/or oils. The 10,500 gallon threshold includes all oils stored onboard the vessel in bulk, such as fuel, lube oil, hydraulic steering oil, waste oils, etc. It does not include oils stored in barrels, cans or buckets.
33 CFR 155.720(a)
5.20 Where applicable, are oil transfer procedures available for transfers FROM the vessel? (RCP III-F-7) (RCP IV-F-7)
Oil transfer procedures addressing transfers from the vessel are required if either vessel’s total capacity of fuel and/or oils is greater than 10,500 gallons. The 10,500 gallon threshold includes all oils stored onboard the vessel in bulk, such as fuel, lube oil, hydraulic steering oil, waste oils, etc. It does not include oils stored in barrels, cans or buckets.
5.21 Where applicable, are oil transfer procedures available for transfers from tank to tank within the vessel? (RCP III-F-7) (RCP IV-F-7)
Oil transfer procedures are required for vessels with 10,500 gallon or greater total capacity of fuel and/or oils. The 10,500 gallon threshold includes all oils stored onboard the vessel in bulk, such as fuel, lube oil, hydraulic steering oil, waste oils, etc. It does not include oils stored in barrels, cans or buckets.
33 CFR 155.720(b)
5.22 Where required, is advanced notification made to the COTP prior to the transfer in accordance with the COTP requirements?
Advanced notification must be made to the COTP prior to the transfer in accordance with the COTP requirements. This requirement applies to the originator of the transfer.
33 CFR 156.118 33 CFR 156.100 33 CFR 154.500
The individual COTP may require advanced notification for transfers to, from or tank to tank within a vessel. The regulation defines advanced notice as at least four hours prior to the transfer.
5.23 Are fuel oil transfer procedures legibly printed and permanently posted or available for inspection by the COTP or OCMI whenever the vessel is in operation? (RCP III-F-7) (RCP IV-F-7)
Oil transfer procedures are required for vessels with 10,500 gallon or greater total capacity. The transfer procedures required by 33 CFR 155.720 must be available for inspection whenever the vessel is in operation; legibly printed and permanently posted or available at a place where the procedures can be easily seen and used by members of the crew when engaged in transfer operations.
33 CFR 155.740 The auditor should also verify the procedures are current in the document control program and match what is posted in the vessel, if applicable.
5.24 Are oil transfer procedures completed in accordance with 33 CFR 155.750?
Oil transfer procedures are required for vessels with 10,500 gallon or greater total capacity. The transfer procedures must contain: (1) a list of each product transferred to or from the vessel, including the generic or chemical name, cargo information as described in 33 CFR 154.310(a)(5)(ii) and applicability of transfer procedures; (2) a description of each transfer system on the vessel, including a line diagram of the vessel’s transfer piping, the location of the shutoff valve or other isolation device that separates any bilge or ballast system from the transfer system, and a description of and procedures for emptying the discharge containment system required by 33 CFR 155.310 and 33 CFR 155.320; (3) the number of persons required to be on duty during transfer operations; (4) the duties by title of each officer, person in charge, tankerman, deckhand and any other person required for each transfer operation; (5) procedures and duty assignments for tending the vessel’s moorings during the transfer of oil or hazardous material; (6) procedures for operating the emergency shutdown and communications means required by 33 CFR 155.780 and 33 CFR 155.785; (7) procedures for topping off tanks; (8) procedures for ensuring that all valves used during the transfer operations are closed upon completion of transfer; (9) procedures for reporting discharges of oil or hazardous material into the water; and (10) procedures for closing and opening the vessel openings in 33 CFR 155.815.
5.25 Does the vessel operator 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?
The vessel operator must keep written records available for inspection by the COTP or OCMI of the name of each person currently designated as a person in charge of transfer operations. This is required regardless of total capacity of fuel and/or oils.
33 CFR 155.820 33 CFR 155.700
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). The auditor should verify the current PIC onboard is also on the list that is onboard the vessel. The PIC needs to be trained in the vessel-specific procedures.
5.26
Does the vessel operator keep written records available for inspection of the date and result of the most recent test and inspection of each item tested or inspected as required by 33 CFR 156.170?
The vessel operator must keep written records available of the date and result of the most recent test and inspection of the transfer hose, transfer system, pressure gauge, loading arm and transfer pipe system, and each item of remote operating or indicating equipment, tank level alarm or emergency shutdown device. This is required if the vessel is equipped with a transfer pump, piping and/or hose used to transfer fuel and/or oils to or from the towing vessel, if the total capacity of either vessel of fuel and/or oils is greater than 10,500 gallons.
33 CFR 155.820 33 CFR 156.170
5.26.1
Does the vessel operator keep written records available for the hose information required by 33 CFR 154.500(e) and (g)?
The vessel operator must keep written records available about the hose information required by 33 CFR 154.500(e) and (g) if the vessel conducts transfers to or from the vessel using the vessel’s own transfer hose, unless that information is marked on the hose.
Does the vessel operator keep written records available of the Declaration of Inspection for the last 30 days as required by 33 CFR 156.150(f)?
The vessel operator must keep a written record of the Declaration of Inspection for the last 30 days. This is required when either the transferring or receiving vessel has over 10,500 gallon total capacity of fuel and/or oils. The 10,500 gallon threshold includes all oils stored on board the vessel in bulk, such as fuel, lube oil, hydraulic steering oil, waste oils, etc. This does not include oils stored in barrels, cans or buckets.
33 CFR 155.820 33 CFR 156.150(f)
5.27
For coastal vessels, if applicable, is an oil record book maintained on board the vessel? (n/a for inland vessels)
Coastal vessels 400 GT and over must maintain an oil record book on board the vessel.
33 CFR 151.25
5.27.1
For coastal vessels, If applicable, are entries made in the oil record book as required by 33 CFR 151.25? (n/a for inland vessels)
For coastal vessels 400 GT and over; entries must be made in the oil record book on each occasion, on a tank to tank basis if appropriate, whenever any of the following machinery space operations take place: (1) ballasting or cleaning of fuel oil tanks; (2) discharge of ballast containing an oily mixture or cleaning water from fuel oil tanks; (3) disposal of oil residue; and (4) discharge overboard or disposal otherwise of bilge water that has accumulated in machinery spaces.
33 CFR 151.25(d)
5.28
For vessels not required to have a Coast Guard approved Non-Tank Vessel Response Plan, is an oil spill contingency plan in place outlining procedures to be followed in case of fuel spill from the towing vessel? (RCP III-F-8) (RCP IV-F-8)
If applicable, an oil spill contingency plan must be in place outlining procedures to be followed in case of fuel spilled from the towing vessel. This is an RCP requirement for vessels that are not otherwise required to have a CG approved Non-Tank Vessel Response Plan.
5.28.1 If applicable, does the self-propelled vessel have on board a copy of the Coast Guard approved Non-Tank Vessel Response Plan? (RCP III-F-8) (RCP IV-F-8)
A CG approved Non-Tank Vessel Response Plan is required for self-propelled towing vessels over 400 GT. A response plan meeting RCP requirements is required for vessels under 400 GT.
33 CFR 155.5030 general content 33 CFR 155.5035 non-tank vessel specific requirements
See NVIC 01-05 CH1 and NPRM addressing non-tank vessel response plans, published in Federal Register on Page 44970, August 31, 2009.
5.29 Is a spill kit sufficient for ondeck spills carried aboard the towing vessel? (RCP III-F-10) (RCP IV-F-10)
A spill kit sufficient for ondeck spills must be carried aboard the towing vessel.
The company is responsible for determining what is “sufficient.”
5.30 If the vessel is 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)?
If the vessel burns 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).
MARPOL Annex VI 49 CFR 94
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.
5.31 Does the vessel have a currently valid Certificate of Financial Responsibility?
Applicable for vessels over 300 GT, the vessel must have a currently valid Certificate of Financial Responsibility.
33 CFR 138.65 As of October 2008, a hard copy is not required to be on the vessel. According to 33 CFR 138.65, a copy of the certificate may be downloaded from https://npfc.uscg.mil/cofr. This information is now only available online, and the auditor will need to access the information online.
6.1 Do propulsion systems, including engines, reduction gears, clutches, controls, shafting, and bearings show evidence of compliance with the company maintenance program? (RCP III-B-1a) (RCP IV-B-1a) (RCP II-B-6)
Propulsion systems, including engines, reduction gears, clutches, controls, shafting and bearings, must show evidence of compliance with the company maintenance program. During the visual inspection of the propulsion system, if the auditor observes evidence that the system appears to be consistently in compliance with the maintenance program, the system would be considered compliant. If the auditor discovers an issue that is of immediate safety concern with regard to critical systems, the issue may be considered a non-conformity or an opportunity for improvement, as appropriate to the observed condition.
The auditor should compare the company's written maintenance program requirements to the conditions observed on the boat. The auditor should ask for the vessel maintenance records for the vessel in particular to indicate whether the vessel is in compliance with the written maintenance program. See also TVIB Management Audit Worksheet 7.2.1.
6.2 Do steering systems show evidence of compliance with the company maintenance program? (RCP III-B-1b) (RCP IV-B-1b)
Steering systems must show evidence of compliance with the company maintenance program. During the visual inspection of the steering system, if the auditor observes evidence that the system appears to be consistently in compliance with the maintenance program, the system would be considered compliant. If the auditor discovers an issue that is of immediate safety concern with regard to critical systems, the issue may be considered a non-conformity or an opportunity for improvement, as appropriate to the observed condition.
6.3 Do miscellaneous auxiliary systems show evidence of compliance with the company maintenance program? (RCP III-B-1c) (RCP IV-B-1c)
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.) must show evidence of compliance with the company maintenance program. During the visual inspection of the miscellaneous auxiliary systems, if the auditor observes evidence that the system appears to be consistently in compliance with the maintenance program, the system would be considered compliant. If the auditor discovers an issue that is of immediate safety concern with regard to critical systems, the issue may be considered a non-conformity or an opportunity for improvement, as appropriate to the observed condition.
See also 6.1 and Management Audit Worksheet 10.9.3.
6.4 Are electrical systems labeled, or is a schematic available outlining electrical wiring systems? (RCP III-B-1d) (RCP IV-B-1d)
Major electrical systems or their components, such as breaker boxers, switches or contactors operating critical machinery, control panels, etc., must be labeled, or a schematic must be available outlining the electrical wiring systems. The company is responsible for determining the method of labeling, however the label must be of a durable substance that is permanently affixed.
The auditor should conduct a visual inspection of visible electrical components. If the auditor observes electrical components such as switches, contactors, circuit breakers or fuses, control panels, or other electrical components which are not labeled or otherwise identified by schematic drawings which are immediately available, the auditor should issue either an NC for an entire component which is not labeled or an OFI for a couple of unlabeled circuit breakers.
6.5 Are exposed moving parts, such as shafts, belts and pulleys sufficiently guarded? (RCP IV-B-4) (RCP III-B-4)
Exposed moving parts, such as shafts, belts and pulleys must be sufficiently guarded or provide restricted access.
The auditor should conduct a visual inspection of the machinery spaces to identify machinery which has exposed moving parts. If the auditor observes any unguarded exposed moving parts, the auditor should issue a NC. See also 29 CFR 1910.212.
6.6 Is a main engine water temperature alarm installed and functional, or is an individual assigned the responsibility to monitor and document the main engine water temperature? (RCP III-B-5a-1) (RCP IV-B-5a-1)
A main engine water temperature alarm must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the main engine water temperature, in accordance with the company procedures.
If the company chooses to utilize an individual to monitor the engine room in lieu of having required alarms, the company’s maintenance program should specifically instruct the assigned individual to monitor the required item on some specified frequency and to keep a written record of compliance with this expectation. This written record should be available to the auditor for inspection and verification. The auditor can request to see written documentation showing the equipment is in good operating condition by log entries or other documents that are generated during periodic required alarm tests, and can ask the engineer if they all work and/or can look for log entries on the daily engine room logs which may show temperatures and pressures from gauge readings.
6.7 Is a main engine lube oil pressure alarm installed and functional, or is an individual assigned the responsibility to monitor and document the main engine lube oil pressure? (RCP III-B-5a-2) (RCP IV-B-5a-2)
A main engine lube oil pressure alarm must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the main engine lube oil pressure in accordance with the company procedures.
See also 6.6.
6.8 Is a bilge alarm installed and functional, or is an individual assigned the responsibility to monitor and document the bilge? (RCP III-B-5a-3) (RCP IV-B-5a-3)
A bilge alarm must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the bilge in accordance with the company procedures.
See also 6.6.
6.9 Is a generator water temperature alarm installed and functional, or is an individual assigned the responsibility to monitor and document the generator water temperature? (RCP III-B-5a-4) (RCP IV-B-5a-4)
A generator water temperature alarm must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the generator water temperature in accordance with the company procedures.
See also 6.6.
6.10 Is a generator lube oil pressure alarm installed and functional, or is an individual assigned the responsibility to monitor and document the generator lube oil pressure? (RCP III-B-5a-5) (RCP IV-B-5a-5)
A generator lube oil pressure alarm must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the generator lube oil pressure in accordance with the company procedures.
6.11 Is a hydraulic steering fluid level alarm installed and functional, or is an individual assigned the responsibility to monitor and document the hydraulic steering fluid level? (RCP III-B-5a-6) (RCP IV-B-5a-6)
A hydraulic steering fluid level alarm must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the hydraulic steering fluid level in accordance with the company procedures.
See also 6.6.
6.12 Are alarm tests recorded at least quarterly)? (RCP IV-B-5a-8) (RCP III-B-5a-8)
Alarm tests must be recorded at least quarterly. This requirement applies to all vessel engines or auxiliary system alarms that are installed onboard the towing vessel, including alarms on engines, generators, bilge level, hydraulic fluid levels, day tanks, electrical components, operator incapacitation alarms, etc.
Machinery alarm tests required for RCP compliance must be conducted at least quarterly. Alarm system manufacturers may require testing at more frequent intervals in the equipment’s operation manual. See also section 4 for general alarm weekly testing requirement and monthly fire detection system testing requirements.
6.12.1 Records of required alarm tests must provide sufficient detail to identify each of the alarm components that were tested. Date of last documented test: (RCP IV-B-5a-8) (RCP III-B-5a-8)
6.13 Is a main engine water temperature gauge installed and functional, or is an individual assigned the responsibility to monitor and document the main engine water temperature? (RCP III-B-5b-1) (RCP IV-B-5b-1)
A main engine water temperature gauge must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the main engine water temperature in accordance with company procedures.
If the company chooses to utilize an individual to monitor the engine room in lieu of having required gauges, the company’s maintenance program should specifically instruct the assigned individual to monitor the required item on some specified frequency and to keep a written record of compliance with this expectation. This written record should be available to the auditor for inspection and verification.
6.14 Is a main engine lube oil pressure gauge installed and functional, or is an individual assigned the responsibility to monitor and document the main engine lube oil pressure? (RCP III-B-5b-2) (RCP IV-B-5b-2)
A main engine lube oil pressure gauge must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the main engine lube oil pressure in accordance with company procedures.
Same as 6.13
6.15 Is a generator water temperature gauge installed and functional, or is an individual assigned the responsibility to monitor and document the generator water temperature? (RCP III-B-5b-3) (RCP IV-B-5b-3)
A generator water temperature gauge must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the generator water temperature in accordance with company procedures.
6.16 Is a generator lube oil pressure gauge installed and functional, or is an individual assigned the responsibility to monitor and document the generator lube oil pressure? (RCP III-B-5b-4) (RCP IV-B-5b-4)
A generator lube oil pressure gauge must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the generator lube oil pressure in accordance with company procedures.
Same as 6.13
6.17 Is a main engine tachometer installed and functional, or is an individual assigned the responsibility to monitor and document the main engine tachometer? (RCP III-B-5b-5) (RCP IV-B-5b-5)
A main engine tachometer must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the main engine tachometer in accordance with company procedures. It is up to the company to decide the location and the use of installed or portable tachometers.
Same as 6.13; see also Management Audit Worksheet 10.14.5.
6.18 Is a hydraulic steering fluid level (sight glass) installed and functional, or is an individual assigned the responsibility to monitor and document the hydraulic steering fluid level? (RCP III-B-5b-6) (RCP IV-B-5b-6)
A hydraulic steering fluid level (sight glass) must be installed and appear to be functional, or an individual must be assigned the responsibility to monitor and document the hydraulic steering fluid level in accordance with company procedures.
Same as 6.13 Sight glasses not integral to the tank should be protected with guards. Sight glass guards installed according to a manufacturer’s design specification are acceptable.
? # Question RCP Expectation Regulatory Requirements Additional Information
7.1 Is a routine hull inspection performed? (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. For inland vessels, a drydock period (routine hull inspection) is recommended as needed; with a maximum of 36 months between inspections. For coastal vessels, a drydock period (routine hull inspection) is recommended twice every five years; with a maximum 36 months between inspections for all vessels. For vessels operating exclusively in coastal harbor services (i.e. not beyond the boundary line), inspections are recommended as needed, with a minimum of once every five years with a mid-term underwater inspection between the 24th and 36th months. Participation in the UWILD (underwater survey in lieu of drydocking) program would require Coast Guard approval prior to use. If the vessel is to be inspected utilizing UWILD, the company’s inspection program must be approved by the Coast Guard or class society.
46 CFR 115.615 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.
? # Question RCP Expectation Regulatory Requirements Additional Information
7.1.1 Are there written records to demonstrate the company’s compliance with the requirement for routine hull inspections? (RCP II) (RCP III-A-1) (RCP IV-A-1)
The company must have written records to demonstrate compliance with the requirement for routine hull inspections.
7.2 For coastal/ocean towing vessels, does the vessel have routine hull gaugings and ballast tank inspections? (RCP IV-A-2)
For coastal/ocean towing vessels, the vessel must have hull gauging inspections at least once every five years, and ballast tank and voids inspected at least every 36 months.
See additional information comments regarding written inspection programs in 7.1 above.
7.2.1 If applicable, are there written records to demonstrate the company’s compliance with the requirement for routine hull gaugings and ballast tank inspections? (RCP II) (RCP IV-A-2)
For coastal/ocean towing vessels, there must be written records to demonstrate the company’s compliance with the requirement for routine hull gaugings and ballast tank inspections.
7.3 If applicable, are watertight closures (doors, hatches, air ports, windows, hatch coamings etc.) able to be secured? (RCP III-A-2) (RCP IV-A-3)
If the vessel has watertight closures (doors, hatches, air ports, windows, etc.), they must be able to be secured.
See additional information comments regarding written inspection programs in 7.1 above.
7.3.1 If applicable, are the watertight closures fitted with seals or gaskets? (RCP III-A-2) (RCP IV-A-3)
Watertight closures (doors, hatches, air ports, windows, etc.) must be fitted with seals or gaskets.
See additional information comments regarding written inspection programs in 7.1 above.
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7.3.2 If applicable, are the watertight closures inspected annually? (RCP III-A-2) (RCP IV-A-3)
If the vessel has watertight closures (doors, hatches, air ports, windows, etc.) they must be inspected annually, with particular attention to main or freeboard deck closures.
7.3.3 If applicable, are there written records to demonstrate the company’s compliance with the requirement to inspect watertight closures annually? (RCP II) (RCP III-A-2) (RCP IV-A-3)
If the vessel has watertight closures, the company must have written records to demonstrate compliance with the requirement to inspect watertight closures annually.
7.4 Are other openings (such as ventilators, air pipes, tank vents, etc.) water or weather tight, and do they have sufficient structural integrity? (RCP III-A-3) (RCP IV-A-4)
Other openings, such as ventilators, air pipes, and tank vents, must be either water or weather tight, and must have sufficient structural integrity.
See additional information comments regarding written inspection programs in 7.1 above. Additional examples of other openings may include engine swap hatches, stuffing boxes for wires and hydraulic cables, and wire runways.
7.4.1 Are other openings (such as ventilators, air pipes, tank vents, etc.) inspected for water or weather tightness and structural integrity, and the findings recorded at least annually? (RCP III-A-3) (RCP IV-A-4)
Records of required annual inspections of other openings must provide sufficient detail to identify which openings were inspected.
See additional information comments regarding written inspection programs in 7.1 above. Additional examples of other openings may include engine swap hatches, stuffing boxes for wires and hydraulic cables, and wire runways.
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7.5 Are rails, ladders, bulwarks, lighting, walking surfaces, guard chains, safety chains and handrails securely installed and free of excessive wastage or weakness? (RCP III-A-4a) (RCP IV-A-5)
Rails, ladders, bulwarks, lighting, walking surfaces, guard chains, safety chains and handrails must be securely installed and free of excessive wastage or weakness.
See additional information comments regarding written inspection programs in 7.1 above.
7.5.1 For inland vessels, if installed, are stanchions upright along the outboard sides of the main deck with guard chains or safety chains in place? (RCP III-A-4b)
For inland vessels, if installed, stanchions must be upright along the outboard sides of the main deck with guard chains or safety chains in place.
See additional information comments regarding written inspection programs in 7.1 above.
7.5.2 Are rails, ladders, bulwarks, lighting, walking surfaces, guard chains, safety chains and handrails inspected and the findings recorded at least annually? (RCP III-A-4a) (RCP IV-A-5)
Records of required annual inspections of rails, ladders, bulwarks, lighting, walking surfaces, guard chains, safety chains and handrails for wastage, weakness and personnel safety considerations must provide sufficient detail to identify what was inspected.
See additional information comments regarding written inspection programs in 7.1 above.
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7.6 If applicable, are emergency walkways and hatchways secure, clearly marked and free of obstruction? (RCP III-A-5) (RCP IV-A-6)
Emergency walkways and hatchways must be secure, clearly marked and free of obstruction.
See additional information comments regarding written inspection programs in 7.1 above. This question may not be applicable if the vessel’s engine room is contained within a single compartment and the vessel does not have emergency walkways/hatchways. The auditor should look for signage above or below the emergency walkways and hatches indicating that the opening is an emergency walkway or hatch and to keep the space clear. Spaces above/below the opening need to be kept clear as well.
7.6.1 If applicable, are emergency walkways and hatchways inspected and the findings recorded at least annually? (RCP III-A-5) (RCP IV-A-6)
Records of the required annual inspections of the emergency walkways must provide sufficient detail to identify what was inspected.
See additional information comments regarding written inspection programs in 7.1 above. This question may not be applicable if the vessel’s engine room is contained within a single compartment and the vessel does not have emergency walkways/hatchways.
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7.7 Are piping systems labeled, color coded or numbered? (RCP III-A-6a) (RCP IV-A-8a)
Piping systems must be labeled, color coded or numbered. 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.
33 CFR 155.750(a)(2)
All piping systems must be labeled, color corded or numbered. As related to piping diagrams, 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.
7.7.1 Are diagrams for the piping systems maintained on board the vessel? (RCP III-A-6a) (RCP IV-A-8a)
Diagrams for the piping systems must be maintained on board the vessel. This should include a check that the onboard piping diagrams are accurate to the actual piping systems and tanks.
33 CFR 155.750(a)(2)
7.7.2 Are piping systems free of excessive leaks and wastage or weakness? (RCP III-A-6b) (RCP IV-A-8b)
Piping systems must be free of excessive leaks and wastage or weakness.
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7.7.3 Are piping systems inspected and the findings recorded at least annually? (RCP III-A-6b) (RCP IV-A-8b)
Records of the required annual inspection of the vessel’s piping systems must provide sufficient detail to indicate what had been inspected. Inspection checklists containing detailed instructions necessary to ensure the result of the inspection will meet the company’s expectations regarding how the vessel should be maintained, should be included in the inspection records.
7.8 Is the company lock-out/tag-out procedure available for use aboard the vessel? (RCP III-B-3) (RCP IV-B-3)
The company lock-out/tag-out procedure must be available for use aboard the vessel.
Additional guidance regarding lock-out/tag-out may be found in 29 CFR 1910.147. OSHA 29 CFR 1915.89. See also Management Worksheet 10.11.
7.8.1 If required by company procedure, is lock-out/tag-out equipment available onboard the vessel?
If required by company procedure, lock-out/tag-out equipment must be available onboard the vessel.
7.9 Are freeing ports and scuppers (if applicable) inspected at least annually while underway to note satisfactory drainage of the main deck, to maintain seaworthiness? (RCP III-A-7) (RCP IV-A-7)
Freeing ports and scuppers (if applicable) must be inspected at least annually while underway to note satisfactory drainage of the main deck, to maintain seaworthiness.
The auditor is not being asked to verify seaworthiness, but rather to confirm that documentation exists confirming that freeing ports are inspected at least annually.
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7.10 If the company has a smoking policy, is the company’s policy being adhered to onboard the vessel?
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.
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The questions in Section 8 are divided first by whether a vessel is towing alongside/pushing ahead or towing astern. Then the questions are divided by section based upon whether the vessel is operated upon inland or coastal waters. The auditor must answer each set of applicable questions for the vessel being audited.
8.1 The following set of questions applies to vessels towing alongside or pushing ahead:
8.1.1 Are face wires, spring lines and push gear appropriate for the vessel’s horsepower?
Applicable for vessels towing alongside and pushing ahead. The master or operator of the vessel must ensure that the face wires, spring lines and push gear used are appropriate for the vessel’s horsepower.
33 CFR 164.76(a) The term “terminal gear” may also be used interchangeably throughout the regulations to describe the towing vessel’s rigging. The use of terminal gear or push gear, face wires and/or spring lines is intended to apply to all of the vessel’s rigging in use during towing operations. See 33 CFR 164.76 and 164.80 for a definition of “terminal gear.”
8.1.2 Are face wires, spring lines and push gear appropriate for the arrangement of the tow?
Applicable for vessels towing alongside and pushing ahead. The master or operator of the vessel must ensure that the face wires, spring lines and push gear used are appropriate for the arrangement of the tow.
33 CFR 164.76(b) See Additional Information in 8.1.1.
8.1.3 Are face wires, spring lines and push gear frequently inspected?
Applicable for vessels towing alongside and pushing ahead. The master or operator of the vessel must ensure that the face wires, spring lines and push gear are frequently inspected.
33 CFR 164.76(c) See also additional information in 8.1.1. The auditor should be verifying the company’s inspection requirements have been identified and are being complied with, by means of examining the inspection records.
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8.1.4 Are there written records to demonstrate the company’s compliance with the inspection requirements in 8.1.3?
The company must have periodic written records to verify that face wires, spring lines and push gear are frequently inspected and were in serviceable condition at the time of the last inspection.
33 CFR 164.76(c)
8.1.5 Are face wires, spring lines and push gear in serviceable condition?
Applicable for vessels towing alongside and pushing ahead. The master or operator of the vessel must ensure that the face wires, spring lines and push gear remain in serviceable condition.
33 CFR 164.76(d) See additional information in 8.1.1.
8.2 The following set of questions applies to vessels towing astern:
8.2.1 Is the tow wire of sufficient size and strength for the vessel's size and horsepower? (RCP IV-E-1a)
For towing vessels towing astern, the owner, master or operator of the vessel must ensure that the towline is adequate for its intended service, considering at least the following factors: (1) the size and material of each towline must be – (i) Appropriate for the horsepower or bollard pull of the vessel; (ii) Appropriate for the static loads and dynamic loads expected during the intended service; (iii) Appropriate for the sea conditions expected during the intended service (iv) Appropriate for exposure to the marine environment and to any chemicals used or carried on board the vessel; (vi) Compatible with associated navigational-safety equipment; and (vii) Appropriate for the likelihood of mechanical damage.
33 CFR 164.74(a)
8.2.2 For vessels towing astern, is there a written record of the towline’s initial minimum breaking strength, as determined by the manufacturer kept on file?
A record of the towline’s initial minimum breaking strength, as determined by the manufacturer, should be kept available on board or in the company office.
33 CFR 164.74(a)(3)(i)
8.2.3
For vessels towing astern, are there written records of retests of the towline’s minimum breaking strength kept on file?
For vessels towing astern, records must be kept on board the vessel or at the company office documenting the retests of the towline’s minimum breaking strength.
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8.2.4
For vessels towing astern, are there written records available to verify visual inspections of the towline are conducted at least monthly?
For vessels towing astern, visual inspections of the towline must be conducted at least monthly, or in accordance with the manufacturer’s recommendations. Written records documenting the inspections should be kept on board or at the company office.
33 CFR 164.74(a)(3)(iii)
8.2.5
For vessels towing astern, is the towline as rigged free of knots, and is it spliced with a thimble or have a poured socket at its end?
For vessels towing astern, the towline must be free of knots, and be either spliced with a thimble or have a poured socket at its end.
33 CFR 164.74(a)(2)(i) and (ii)
8.2.6
Where applicable, for vessels towing astern, are any temporary repairs to the towline made with a thimble and a minimum of five wire clips?
Where applicable, for vessels towing astern, any temporary repairs to the towline must be made with a thimble and a minimum of five wire clips or as many wire clips as the manufacturer specifies for the nominal diameter and construction of the towline, whichever is more.
33 CFR 164.74(a)(2)(iii)
8.2.7
For vessels towing astern, are each connection in the terminal gear secured by at least one nut with at least one cotter pin or other means of preventing its failure?
For vessels towing astern, each connection in the terminal gear must be secured by at least one nut with at least one cotter pin or other means of preventing its failure.
33 CFR 164.74(b)(2)
8.2.8
For vessels towing astern, is the lead of the towline appropriate to prevent sharp bends in the towline from fairlead blocks, chocks or tackle?
For vessels towing astern, the lead of the towline must appear to be appropriate to prevent sharp bends in the towline from fairlead blocks, chocks or tackle. Depending on the vessel configuration, the auditor will need to visually verify.
33 CFR 164.74(b)(3)
8.2.9
For vessels towing astern, is there a method provided, whether mechanical or non-mechanical that does not endanger operating personnel but that easily releases the towline?
For vessels towing astern, there must appear to be either a mechanical or non-mechanical method to easily release the towline that does not endanger operating personnel. To confirm compliance, the auditor will examine records that this has been included in the vessel’s maintenance system and is tested and operated in accordance with the company’s policy or procedure.
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8.2.10
For vessels towing astern, is the towline protected from abrasion or chafing by chafing gear, lagging or other means?
For vessels towing astern, the towline must be protected from abrasion or chafing by chafing gear, lagging or other means.
33 CFR 164.74(b)(5)
8.2.11
If applicable for vessels towing astern (not required for a vessel towing in ice on Western Rivers or vessels using a towline of synthetic or natural fiber), is the vessel fitted with a winch that evenly spools and tightly winds the towline?
Not required to be on board a vessel towing in ice on Western Rivers or one using a towline of synthetic or natural fiber. For vessels towing astern, the vessel must be fitted with a winch that evenly spools and tightly winds the towline.
33 CFR 164.74(b)(6)
8.2.12
For vessels towing astern, if the vessel is fitted with a winch, is there a brake attached to the main drum that has holding power appropriate for the horsepower or bollard pull of the vessel and can be operated without power to the winch?
For vessels towing astern that are fitted with a winch. The vessel must have a brake attached to the main drum that appears to have holding power appropriate for the horsepower or bollard pull of the vessel, and can be operated without power to the winch.
33 CFR 164.74(b)(7)
8.3 The following set of questions applies only to inland towing vessels:
8.3.1 For inland vessels, are there documented procedures on board the vessel for the safe use of wires, lines, chains, shackles, ratchets, winches and capstans? (RCP III-E-1)
Inland vessels must have documented procedures on board the vessel for the safe use of wires, lines, chains, shackles, ratchets, winches and capstans.
8.3.2 For inland vessels, are there documented procedures on board the vessel that identify the minimum amount of rigging requirements for the vessel? (RCP III-E-2)
Inland vessels must have documented procedures on board the vessel that identify the minimum amount of rigging requirements for the vessel. This question pertains to the quantities of rigging inventory that must be on board the vessel.
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8.3.3 If applicable for inland vessels, is there a copy on board the vessel or readily available of the inspection and replacement program for rigging? (RCP III-E-3)
For inland vessels, if the company procedures indicate that the vessel carries or uses rigging, the vessel must have a copy of the company’s written inspection and replacement program for the rigging and towing gear on board or readily available. 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.
8.3.3.1 If applicable for inland vessels, are there written records to demonstrate the company’s compliance with their rigging inspection and replacement program? (RCP II) (RCP III-E-3)
The company must have written records to demonstrate their compliance with the rigging inspection and replacement program.
8.3.4 For inland vessels, is a copy of the company’s procedures for the minimum specifications for each element of rigging on board the vessel? (RCP III-E-4)
The vessel must have a copy of the company’s 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 following is a list of examples auditors may see during an audit, including but not limited to, length and diameter of wires including eye sizes, chain straps with number of chain links, shackle size by diameter of the shackle pin, ratchet length and diameter of the screw (e.g. 1 3/8” or 1 ¾”), etc.
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8.4 The following set of questions applies only to coastal towing vessels:
8.4.1 For coastal vessels, is the nominal breaking strength of the tow wire/towing hawser at least 2.5 times the certified or calculated bollard pull of the tug? (RCP IV-E-1a-1)
For coastal vessels, the minimal nominal breaking strength of the tow wire/towing hawser must be at least 2.5 times the certified or calculated bollard pull of the tug. The static bollard pull of the tug should be determined by a static bollard pull test certified by the American Bureau of Shipping or other competent organization, or calculated using the engine manufacturer’s rated brake horsepower (BHP) at the maximum engine rpm times the factor 27.5 pounds per BHP.
8.4.2 For coastal vessels, does the vessel's tow wire have an independent wire rope core (IWRC)? (RCP IV-E-1b-1)
The coastal vessel’s tow wire must have an independent wire rope core (IWRC).
8.4.3 For coastal vessels, is the vessel's tow wire manufactured of improved plow steel or extra improved plow steel? (RCP IV-E-1b-2)
The coastal vessel’s tow wire must be manufactured of improved plow steel or extra improved plow steel.
8.4.4 For coastal vessels, is the tow wire galvanized or does it appear to be properly lubricated? (RCP IV-E-1b-3)
The coastal vessel’s tow wire must be either heavily lubricated, or galvanized at the time of manufacture.
8.4.5 For coastal vessels, is the tow wire construction at least 6x19? (RCP IV-E-1b-4)
The coastal vessel’s tow wires must be 6 x 19 or larger (more flexible).
8.4.6 For ocean-going towing vessels using soft lines, are the soft lines rated at 2.5 times the certified or calculated bollard pull of the tug? (RCP IV-E-1b-5)
Soft lines used in ocean towing must be rated at 2.5 times the certified or calculated bollard pull of the tug.
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8.4.7 For coastal vessels, is the breaking strength of the tow wire or hawser certified by the manufacturer by pull-testing to destruction a portion of the wire or hawser from the mill run from which it originated? (RCP IV-E-1b-6)
The breaking strength of the tow wire or towing hawser must be certified by the manufacturer by pull-testing to destruction a portion of the wire or hawser from the mill run from which it originated.
8.4.8 For coastal vessels, does the tow wire terminate in a spelter or thermo-set resin poured socket, or a spliced eye with thimble? (RCP IV-E-1c)
For coastal vessels, the tow wire must terminate in a spelter or thermo-set resin poured socket or a spliced eye with thimble.
8.4.8.1 For coastal vessels, is the poured socket sized to exceed the breaking strength of the tow wire? (RCP IV-E-1c)
For coastal vessels, the poured socket must be sized to exceed the breaking strength of the tow wire.
8.4.9 For coastal vessels, is the barge towed using a two-legged bridle? (RCP IV-E-2a-1)
For coastal vessels engaging in ocean towing, the barge must be towed using a two-legged bridle.
8.4.9.1 For coastal vessels, is the breaking strength of each leg at least 1.3 times the minimum required breaking strength of the main towing hawser? (RCP IV-E-2a-2)
For coastal vessels engaging in ocean towing, the breaking strength of each bridle leg must be at least 1.3 times the minimum required breaking strength of the main towing hawser.
8.4.9.2 For coastal vessels, is the bridle made of Grade 2 or higher welded or forged integral stud link chain or IWRC wire rope? (RCP IV-E-2a-3)
For coastal vessels engaging in ocean towing, the bridle must be made of Grade 2 or higher welded or forged integral stud link chain or IWRC wire rope.
8.4.10 For coastal vessels, does the vessel tow using surge gear?
The following set of questions apply to coastal towing vessels using surge gear.
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8.4.10.1
For coastal vessels, if used, are the surge chains Grade 2 or higher welded or forged integral stud link chain? (RCP IV-E-2b-1)
If applicable, the surge chains must be Grade 2 or higher welded or forged integral stud link chain.
8.4.10.2
For coastal vessels, if used, is the surge chain of the same grade and type and at least as large as that in the towing bridle? (RCP IV-E-2b-2)
If applicable, the surge chain must be of the same grade and type and at least as large as that in the towing bridle.
8.4.10.3
For coastal vessels, if used, does each end of the chain have an end link or one studless link? (RCP IV-E-2b-3)
If applicable, each end of the surge chain must have an end link or one studless link.
8.4.11 For coastal vessels, does the vessel tow using a synthetic shockline?
For coastal vessels, a synthetic shockline may be used as surge gear if it meets the requirements of the following question.
8.4.11.1
If used, is the breaking strength of the synthetic shockline at least 1.3 times the minimum strength required for steel tow wires based on bollard pull of the towing vessel? (RCP IV-E-2b-4)
If used, the breaking strength of the synthetic shockline must be at least 1.3 times the minimum strength required for steel primary tow wires based on the bollard pull of the towing vessel.
8.4.12 For coastal vessels, is the associated towing gear (e.g., shackles, flounder/fish plates, shock hawser) of sufficient size for its intended use? (1.3 times the breaking strength of the primary tow gear) (RCP IV-E-3)
For coastal vessels, the associated towing gear (e.g. shackles, flounder/fish plates, shock hawser) must be of sufficient size for its intended use, which has been determined to be 1.3 times the breaking strength of the primary tow gear.
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8.4.13 For coastal vessels, does the towing system include proper chafe protection at points where wear may occur during normal operations? (RCP IV-E-4a)
For coastal vessels, the towing system must include proper chafe protection at points where wear may occur during normal operations.
8.4.14 For coastal vessels, are all surfaces that routinely come in contact with the tow wire smooth and properly maintained? (RCP IV-E-4b)
For coastal vessels, all surfaces that routinely come in contact with the tow wire must be smooth and properly maintained.
8.4.15 For coastal vessels, does the company have a program to address the inspection, maintenance and replacement criteria for wire rope and synthetic hawsers used in the towline assembly? (RCP IV-E-6)
For coastal vessels, the company must have a written program that addresses the inspection, maintenance and replacement criteria for tow wire rope and synthetic hawsers.
As a minimum, the wire rope program should be consistent with the recommendations outlined in Coast Guard Navigation and Vessel Inspection Circular (NVIC) 5-92.
8.4.16 For coastal vessels, is the tug equipped with an emergency barge recovery system? (RCP IV-E-5)
For coastal vessels, the tug must be equipped with an emergency barge recovery system.
8.4.17 For coastal vessels, are all components of the emergency towing system rated with a breaking strength equal to 1.5 times the rated bollard pull of the vessel? (RCP IV-E-5)
For coastal vessels, all components of the emergency towing system must be rated with a breaking strength equal to 1.5 times the rated bollard pull of the vessel.
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8.5 For the following coastal vessel questions, if a barge is unavailable for inspection, verify by querying tug crew or checking company documentation.
8.5.1 Are the bridles Grade 2 or higher welded or forged integral stud link chain or an independent wire rope core (IWRC)? (RCP IV-E-3a-3)
The bridles must be Grade 2 or higher welded or forged integral stud link chain or have an independent wire rope core (IWRC).
8.5.2 Does the barge or tug carry an emergency towing system that has been rated with a breaking strength equal to 1.5 times the rated bollard pull of the towing vessel? (RCP IV-E-5)
The barge or tug must carry an emergency towing system that has been rated with a breaking strength equal to 1.5 times the rated bollard pull of the towing vessel.
8.5.3 Are all components of the emergency towing system rated with a breaking strength 1.5 times the rated bollard pull of the towing vessel? (RCP IV-E-5)
All components of the emergency towing system must be rated with a breaking strength 1.5 times the rated bollard pull of the towing vessel.
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9.1 Except as otherwise provided, such as 46 USC 8104(c), are licensed wheelhouse personnel prohibited from working more than 12 hours in a consecutive 24-hour period, except in an emergency? (RCP V-B)
Except as otherwise provided, licensed wheelhouse personnel must be prohibited from working more than 12 hours in a consecutive 24-hour period, except in an emergency.
46 USC 8104 (c) and (h) 46 CFR 15.705
In some cases, on towing vessels operating on certain Great Lakes routes such as between Chicago, IL and Milwaukee, WI, a licensed Master is permitted to work up to 15 hours in a 24 hour period as long as the work period is followed by an off-duty period of at least 21 hours before beginning a new work cycle. (46 U.S.C. 8104 (c))
9.2 Are other crewmembers prohibited from working more than 15 hours in any 24-hour period or more than 42 hours in a 72-hour period, except in an emergency or drill? (RCP V-B)
Except for during an emergency or a drill, other crewmembers must be prohibited from working more than 15 hours in any 24-hour period, or more than 42 hours in a 72 hour period.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.3
Is the Master properly licensed for towing vessels?
The Master must be properly licensed for towing vessels. 46 CFR 15.610 (a): Except as provided in this paragraph, every towing vessel of at least 8 meters (at least 26 feet) in length, measured from end to end over the deck (excluding sheer), must be under the direction and control of a person holding a license or MMC officer endorsement as master or mate (pilot) of towing vessels or as a master or mate of vessels of greater than 200 gross register tons holding either an endorsement on his or her license or MMC for towing vessels or a completed Towing Officer’s Assessment Record (TOAR) signed by a designated examiner indicating that the officer is proficient in the operation of towing vessels.
46 CFR 15.610(a) The auditor should look at the license and check the towing endorsement and route endorsement. If spare glasses are required, the auditor should ask the master to see them.
9.3.1
Is the Master’s license properly endorsed for the towing vessel’s route/geographic area of operation and available for inspection?
The Master’s license must be properly endorsed for the towing vessel’s route/geographic area of operation and available for inspection.
Column 1 in the table found in 46 CFR 11.464(a) and Column 1 in the table found in 46 CFR 11.464(b) list the route endorsements for a Master’s license. 46 CFR 15.610
The possible endorsements include Oceans (O), Near-Coastal (NC), Great Lakes – Inland (GL-I), Western Rivers (WR) and Limited Local Area (LLA). In the 8th Coast Guard district, there’s an additional program for limited geographic area licenses.
9.3.2
Is the Master properly endorsed as Radar Observer appropriate for the vessel’s area of operation, and does the Master have his or her Certificate of Training for the appropriate area of operations readily available to demonstrate that the endorsement is still valid?
The Master must be properly endorsed as Radar Observer appropriate for the vessel’s area of operation, and must have his or her Certificate of Training for the appropriate area of operations readily available to demonstrate that the endorsement is still valid. For this section, “readily available” means that the documentation must be provided within 48 hours of a request.
46 CFR 11.480 46 CFR 15.815(c) (d) and (e)
The expiration date will not appear on the face of the certificate.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.3.3
What is the Master’s license reference number?
9.3.4
What is the Master’s license’s expiration date?
9.3.5
If applicable, is the Master carrying his/her valid medical certificate with him/her when operating under the authority of their MMC, and is the certificate readily available for inspection?
If the Master has been issued a medical certificate, it must be carried when operating under the authority of their MMC.
46 CFR 15.401(a) & (c)
See NVIC 01-14 for additional information.
9.3.6
If applicable, is the Master holding a medical certificate with a medical waiver carrying the waiver with him/her when operating under the authority of their MMC, and is the waiver readily available for inspection?
If the Master has a medical waiver, s/he must carry it when operating under the authority of their MMC, and have it readily available for inspection.
46 CFR 15.401(c) See NVIC 01-14 for additional information.
9.4
Does the Master hold a valid (unexpired) Transportation Worker Identification Credential (TWIC)?
The Master must hold a valid (unexpired) Transportation Worker Identification Credential.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.5
Does the vessel have a second Master or Mate/Pilot for voyages longer than 12 hours?
The vessel must have a second Master or Mate/Pilot for voyages longer than 12 hours.
46 CFR 15.705 Per 46 CFR 15.705 (d), subject to exceptions, 46 U.S.C. 8104(h) permits a master or mate (pilot) operating a towing vessel that is at least 26 feet in length measured from end to end over the deck (excluding sheer) to work not more than 12 hours in a consecutive 24 hour period except in an emergency. The USCG interprets this, in conjunction with other provisions of the law, to permit masters or mates (pilots) serving as operators of towing vessels that are not subject to the provisions of the Officers’ Competency Certificates Convention, 1936, to be divided into two watches regardless of the length of voyage.
9.5.1
If applicable, what is the second Master or Mate/Pilot’s license reference number?
9.5.2
If applicable, what is the second Master or Mate/Pilot’s license’s expiration date?
9.5.3
If applicable, is the second Master or Mate/Pilot carrying his/her valid medical certificate with him/her when operating under the authority of their MMC, and is the certificate readily available for inspection?
If the vessel has a second Master or Mate/Pilot who has been issued a medical certificate, s/he must carry it when operating under the authority of their MMC.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.5.4
If applicable, is the second Master or Mate/Pilot holding a medical certificate with a medical waiver carrying the waiver with him/her when operating under the authority of their MMC, and is the waiver readily available for inspection?
If the vessel has a second Master or Mate/Pilot and if that Master or Mate/Pilot has a medical waiver, s/he must carry it when operating under the authority of their MMC, and have it readily available for inspection.
46 CFR 15.401(c) See NVIC 01-14 for additional information.
9.6
If applicable, is the second Master or Mate/Pilot properly licensed for towing vessels?
If the vessel has a second Master or Mate/Pilot, he or she must be properly licensed for towing vessels. 46 CFR 15.610 (a): Except as provided in this paragraph, every towing vessel of at least 8 meters (at least 26 feet) in length, measured from end to end over the deck (excluding sheer), must be under the direction and control of a person holding a license or MMC officer endorsement as master or mate (pilot) of towing vessels or as a master or mate of vessels of greater than 200 gross register tons holding either an endorsement on his or her license or MMC for towing vessels or a completed Towing Officer’s Assessment Record (TOAR) signed by a designated examiner indicating that the officer is proficient in the operation of towing vessels.
46 CFR 15.610(a)
9.7
If applicable, is the second Master or Mate/Pilot’s license properly endorsed for the towing vessel’s route/geographic area of operation and available for inspection?
If the vessel has a second Master or Mate/Pilot, his or her license must be properly endorsed for the towing vessel’s route/geographic area of operation and available for inspection.
Column 1 in the table found in 46 CFR 11.464(a) and Column 1 in the table found in 46 CFR 11.464(b) list the route endorsements for a Master’s license. 46 CFR 15.610
The possible endorsements include Oceans (O), Near-Coastal (NC), Great Lakes – Inland (GL-I), Western Rivers (WR) and Limited Local Area (LLA). In the 8th Coast Guard district, there’s an additional program for limited geographic area licenses.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.8
If applicable, is the second Master or Mate/Pilot properly endorsed as Radar Observer appropriate for the vessel’s area of operation, and does the second Master or Mate/Pilot have his or her Certificate of Training for the appropriate area of operations readily available to demonstrate that the endorsement is still valid?
If the vessel has a second Master or Mate/Pilot, he or she must be properly endorsed as Radar Observer appropriate for the vessel’s area of operation and must have his or her Certificate of Training for the appropriate area of operations readily available. For this section, “readily available” means that the documentation must be provided within 48 hours of a request.
46 CFR 11.480 46 CFR 15.815(c) (d) and (e)
9.9
If applicable, does the second Master or Mate/Pilot hold a valid (unexpired) Transportation Worker Identification Credential (TWIC)?
If the vessel has a second Master or Mate/Pilot, he or she must hold a valid (unexpired) Transportation Worker Identification Credential.
46 CFR 10.203
9.10
If applicable, does the vessel have a third Master or Mate/Pilot for voyages greater than 600 NM?
The vessel must have a third Master or Mate/Pilot for voyages greater than 600 NM.
46 CFR 15.705 46 CFR 15.610
Subject to exception, 46 U.S.C. 8104(g) permits the officers and crew members (except the coal passers, firemen, oilers and water tenders) to be divided into two watches when at sea and engaged on a voyage of less than 600 NM. The auditor should look at the voyage plan and what the company’s procedure states to confirm whether the vessel is using the three man watch system when the voyage length requires it.
9.10.1
If applicable, what is the third Master or Mate/Pilot’s license reference number?
9.10.2
If applicable, what is the third Master or Mate/Pilot’s license’s expiration date?
? # Question RCP Expectation Regulatory Requirements Additional Information
9.10.3
If applicable, is the third Master or Mate/Pilot carrying his/her valid medical certificate with him/her when operating under the authority of their MMC, and is the certificate readily available for inspection?
If the vessel has a third Master or Mate/Pilot who has been issued a medical certificate, s/he must carry it when operating under the authority of their MMC.
46 CFR 15.401(a) & (c)
See NVIC 01-14 for additional information.
9.10.4
If applicable, is the third Master or Mate/Pilot holding a medical certificate with a medical waiver carrying the waiver with him/her when operating under the authority of their MMC, and is the waiver readily available for inspection?
If the vessel has a third Master or Mate/Pilot and if that Master or Mate/Pilot has a medical waiver, s/he must carry it when operating under the authority of their MMC, and have it readily available for inspection.
46 CFR 15.401(c) See NVIC 01-14 for additional information.
9.11
If applicable, is the third Master or Mate/Pilot properly licensed for towing vessels?
If the vessel has a third Master or Mate/Pilot, he/she must be properly licensed for towing vessels. 46 CFR 15.610 (a): Except as provided in this paragraph, every towing vessel of at least 8 meters (at least 26 feet) in length, measured from end to end over the deck (excluding sheer), must be under the direction and control of a person holding a license or MMC officer endorsement as master or mate (pilot) of towing vessels or as a master or mate of vessels of greater than 200 gross register tons holding either an endorsement on his or her license or MMC for towing vessels or a completed Towing Officer’s Assessment Record (TOAR) signed by a designated examiner indicating that the officer is proficient in the operation of towing vessels.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.12
If applicable, is the third Master or Mate/Pilot’s license properly endorsed for the towing vessel’s route/geographic area of operation and available for inspection?
If the vessel has a third Master or Mate/Pilot, his or her license must be properly endorsed for the towing vessel’s route/geographic area of operation and available for inspection.
Column 1 in the table found in 46 CFR 11.464(a) and Column 1 in the table found in 46 CFR 11.464(b) list the route endorsements for a Master’s license. 46 CFR 15.610
The possible endorsements include Oceans (O), Near-Coastal (NC), Great Lakes – Inland (GL-I), Western Rivers (WR) and Limited Local Area (LLA). In the 8th Coast Guard district, there’s an additional program for limited geographic area licenses.
9.13
If applicable, is the third Master or Mate/Pilot properly endorsed as Radar Observer appropriate for the vessel’s area of operation, and does the third Master or Mate/Pilot have his or her Certificate of Training for the appropriate area of operations readily available to demonstrate that the endorsement is still valid?
If the vessel has a third Master or Mate/Pilot, he or she must be properly endorsed as Radar Observer appropriate for the vessel’s area of operation and must have his or her Certificate of Training for the appropriate area of operations readily available to demonstrate that the endorsement is still valid. For this section, “readily available” means that the documentation must be provided within 48 hours of a request.
46 CFR 11.480 46 CFR 15.815(c) (d) and (e)
9.14
If applicable, does the third Master or Mate/Pilot hold a valid (unexpired) Transportation Worker Identification Credential (TWIC)?
If the vessel has a third Master or Mate/Pilot, he or she must hold a valid (unexpired) Transportation Worker Identification Credential.
46 CFR 10.203
Crewmember Licenses
9.15
Do all crewmembers available during the audit holding MMDs/active licenses, other than Masters and Mates/Pilots, hold a valid (unexpired) Transportation Worker Identification Credential (TWIC)?
All crewmembers available during the audit holding MMDs/active licenses must hold a valid (unexpired) Transportation Worker Identification Credential (TWIC). An example of a crewmember with an active license would be an Apprentice Mate (Steersman), and an example of a crewmember with a MMD would be a tankerman.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.16
Do all unlicensed crewmembers available during the audit needing unescorted access to restricted or secure areas hold a valid (unexpired) Transportation Worker Identification Credential (TWIC)?
All unlicensed crewmembers available during the audit needing unescorted access to restricted or secure areas must hold a valid (unexpired) Transportation Worker Identification Credential (TWIC).
33 CFR 101.514
9.17
For vessels operating on Near- Coastal/Ocean & Great Lakes/Inland routes, do all crewmembers available during the audit have a Merchant Mariner Credential (MMC) or Merchant Marine Document (MMD), and do they have all appropriate endorsements for the position served?
Every seaman employed on any merchant vessel of the United States of 100 gross tons or upward, except vessels employed exclusively in trade on the navigable rivers of the United States, must carry a valid merchant mariner credential (MMC) or merchant mariner’s document (MMD) with all appropriate endorsements for the position served. Provisions of this section are not applicable to unrigged vessels except seagoing barges and certain tank barges.
46 CFR 15.401
See also Federal Reg. Vol. 78, No. 247, dated 12/24/2013. Not applicable to vessels less than 100 gross tons or vessels operating exclusively in the Western Rivers.
9.18
For vessels operating on Near- Coastal/Ocean & Great Lakes/Inland routes; if the vessel is using a three-watch system, is at least 65% of the deck crew endorsed as an Able Seaman (AB)?
With certain exceptions, 46 U.S.C. 8702 applies to all vessels of at least 100 gross tons. At least 65 percent of the deck crew of these vessels excluding individuals serving as officers, must be Able Seamen.
46 CFR 15.840 Union agreements may prevent this from being seen; the COI will tell you how many ABs you need to have. If there isn’t a COI, there will be a manning letter that states what the vessel is required to have.
9.19
For vessels operating on Near- Coastal/Ocean & Great Lakes/Inland routes; if the vessel is using a two-watch system, is at least 50% of the deck crew endorsed as an Able Seaman (AB)?
With certain exceptions, 46 U.S.C. 8702 applies to all vessels of at least 100 gross tons. For vessels permitted to maintain a two watch system, the percentage of Able Seamen may be reduced to 50 percent.
46 CFR 15.840 Not applicable to vessels less than 100 gross tons, or vessels engaging in voyages less than 12 hours, or vessels using a three watch system, or vessels operating exclusively in the Western Rivers.
? # Question RCP Expectation Regulatory Requirements Additional Information
9.20
For vessels operating on Near- Coastal/Ocean routes; does the vessel have an engineer holding a MMC or license endorsed as a chief engineer, or other credential authorizing service as chief engineer (seagoing documented UTVs greater than or equal to 200 gross tons)?
There must be an individual holding a MMC or license endorsed as a chief engineer or other credential authorizing service as chief engineer employed on board the following inspected mechanically propelled vessels: seagoing or Great Lakes vessels of 200 gross tons and over.
46 CFR 15.820 Not applicable for vessels less than 200 gross tons or vessels reportedly not operating on Near Coastal or Ocean routes.
Questions 9.21-9.23 are only applicable to vessels operating under the International Convention on Standards of Training, Certification and Watchkeeping (STCW).
9.21
For vessels operating on Near- Coastal/Ocean routes, do crewmembers available during the audit have STCW Endorsements (applicable to towing vessels 200 gross tons or greater; NOT applicable for towing vessels less than 200 gross tons) on near coastal domestic voyages?
Personnel serving on the following vessels, and the owners and operators of these vessels, are in compliance with subpart J and are not subject to further obligation for the purposes of STCW, on account of the vessels’ special operating conditions as small vessels engaged in domestic voyages: (1) small passenger vessels subject to subchapter T or K of title 46, CFR; (2) vessels of less than 200 GRT (other than passenger vessels subject to subchapter H of title 46 CFR).
46 CFR 15.103 Not applicable for vessels less than 200 gross tons or vessels reportedly not operating on Near Coastal or Ocean routes.
9.22
For vessels operating on Near- Coastal/Ocean routes; does the crew have familiarization and basic safety training?
The crew of vessels operating on Near Coastal or Ocean routes must have received familiarization and basic safety training. Basic safety training consists of four courses – Basic Firefighting, Personal Survival, Personal Safety and Social Responsibility, and Elementary First Aid.
46 CFR 15.1105 Training records need to be verified, typically by showing an AB or MMD credential with an STCW endorsement or be able to provide proof of training.
Auditor note: The company has the responsibility to determine the methods used to train employees, and methods for retaining training records. Examples of training may include instructor led, in-person training sessions, online or web-based programs, DVDs, hands-on programs or information disseminated during safety meetings, etc. Examples of training records may include safety meeting sign-off sheets, electronic attendance records, sign-in sheets, certificates from third-party training, etc. Training records should document an individual’s name, date and subject matter covered, and may include instructor, length of class/training, lesson plan or curriculum, etc.
Company Orientation
10.1 Have all new hires, including entry-level and experienced personnel, received a company orientation? (RCP V-C-5a)
All new hires, including entry-level, experienced personnel and new trip personnel as appropriate to their job position, must have received a company orientation. “Entry-level” refers to individuals new to the barge and towing industry.
10.1.1 Did the company orientation include the company’s drug and alcohol policy? (RCP V-C-5a-1)
The company orientation must include the company’s drug and alcohol policy.
See 33 CFR Part 95, 46 CFR Parts 4 and 16, and 49 CFR Part 40 for additional information.
10.1.2 Did the company orientation include the company safety program and policy? (RCP V-C-5a-2)
The company orientation must include the company safety program and policy.
10.1.3 Did the company orientation include safety as a condition of employment? (RCP V-C-5a-2)
The company orientation program must include safety 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.
10.1.4 Did the company orientation include vessel layout and deck operations? (RCP V-C-5a-3)
The company orientation must include vessel layout and 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.
10.1.5 Did the company orientation include required safety equipment and PPE requirements? (RCP V-C-5a-4)
The company orientation must include safety equipment and PPE requirements, in accordance with the company’s written PPE policies or procedures (refer to Management Worksheet section 2).
10.1.6 Did the company orientation include fall overboard prevention? (RCP V-C-5d)
The company orientation must include fall overboard prevention.
Additional information regarding fall overboard prevention can be found in lesson plans published by the AWO Safety Committees.
10.1.7 Did the company orientation include injury prevention? (RCP V-C-5e)
The company orientation 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.
10.1.8 Did the company orientation include back training? (RCP V-C-5e)
The company orientation must include back training. This includes training for proper lifting and body mechanics as appropriate for the employee’s job duties.
10.1.9 Did the company orientation include slip, trip and fall prevention training? (RCP V-C-5e)
The company orientation must include slip, trip and fall prevention training.
See 29 CFR 1910.20 through 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.
10.1.10 Did the company orientation include job responsibilities? (RCP V-C-5a-5)
The company’s orientation must include job responsibilities, in accordance with the well documented responsibilities of vessel personnel (in Management Section 5).
10.2 Have all new hires, including entry-level and experienced personnel, received emergency procedures orientation? (RCP V-C-5b)
All new hires, including entry-level and experienced personnel, must receive emergency procedures orientation. The company’s written employee orientation program must include exposure to the written emergency response procedures (in Management Section 8) and the station bill requirements and directions.
10.2.1 Did the emergency procedures orientation cover fire response procedures? (RCP V-C-5b-1)
The company’s written employee orientation program must include training on the emergency response procedures for fire response and the station bill, as applicable to the employee’s job position.
46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training.
10.2.2 Did the emergency procedures orientation cover collision or allision? (RCP V-C-5b-2)
The company’s written employee orientation program must include training on the emergency response procedures for collision and allision (as applicable in Management Worksheet Section 8) and in accordance with the station bill.
10.2.3 Did the emergency procedures orientation cover sinking? (RCP V-C-5b-3)
The company’s written employee orientation program must include training on the emergency response procedures for vessel sinking (as applicable in Management Worksheet Section 8) and in accordance with the station bill.
10.2.4 Did the emergency procedures orientation cover grounding? (RCP V-C-5b-4)
The company’s written employee orientation program must include training on the emergency response procedures for grounding (as applicable in Management Worksheet Section 8) and in accordance with the station bill.
10.2.5 Did the emergency procedures orientation cover man overboard procedures? (RCP V-C-5b-5)
The company’s written employee orientation program must include training on the emergency response procedures for man overboard (as applicable in Management Worksheet Section 8) and in accordance with the station bill.
10.2.6 Did the emergency procedures orientation cover personal injury and illness? (RCP V-C-5b-6)
The company’s written employee orientation program must include training on the emergency response procedures for personal injury and illness (as applicable in Management Worksheet Section 8) and in accordance with the station bill.
10.2.7 Did the emergency procedures orientation cover company specific-confined space entry hazard awareness for all involved personnel? (RCP V-C-5c)
The company’s written employee orientation program must address confined space entry hazard awareness, in accordance with the company’s written confined space procedures (in Management Worksheet Section 2). All crewmembers, not just those who are allowed access into confined spaces, should receive training. Companies that explicitly prohibit their employees from entering confined spaces must include their policy addressing 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 “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.
10.3 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 employees.
10.4 The following set of questions applies to training every Master (Captain), and Mate/Pilot on the vessel at the time of the audit must have received within the past five years:
10.4.1 Have the Master and Mate/Pilot received radar training within the past five years? (RCP V-C-1a)
The Master and Mate/Pilot must have received radar training within the past five years.
46 CFR 11.480 The auditor should refer back to vessel worksheet question 9.5.2. The training the Master/Mate/Pilot has received must have been the same as what appears on their license.
10.4.2 Have the Master and Mate/Pilot received initial or refresher navigation and boat handling training or had a proficiency evaluation within the past five years? (RCP V-C-1b)
The Master and Mate/Pilot must have received initial or refresher navigation and boat handling training or have had a proficiency evaluation within the past five years.
10.4.3 Have the Master and Mate/Pilot received initial or refresher Rules of the Road training within the past five years? (RCP V-C-1b)
The Master and Mate/Pilot must have received initial or refresher Rules of the Road training within the past five years.
Inland Navigation Rules: 33 CFR parts 83-90
10.4.4 Have the Master and Mate/Pilot received company policy and procedure initial or refresher training within the past five years? (RCP V-C-1c)
The Master and Mate/Pilot must have received company policy and procedure initial or refresher training within the past five years.
10.4.5 Have the Master and Mate/Pilot received initial or refresher training on federal requirements and company conformance to federal requirements within the past five years? (RCP V-C-1c)
The Master and Mate/Pilot must have received initial or refresher training on federal requirements and company conformance to federal requirements within the past five years.
10.4.6 Have the Master and Mate/Pilot received initial or refresher marine firefighting and fire prevention training within the past five years? (RCP V-C-1d)
The Master and Mate/Pilot must have received initial or refresher marine firefighting and fire prevention training within the past five years.
RCP Addendum C Item 14 for RCP requirements for firefighting training 46 CFR 27.209
10.5 Questions 10.5.1-10.5.4 pertain to the Master and Mate/Pilot’s personal safety initial or refresher training within the past five years: (RCP V-C-1e)
10.5.1 Did the Master and Mate/Pilot’s personal safety initial or refresher training include first aid and CPR awareness? (RCP V-C-1e-1)
The Master and Mate/Pilot must receive personal safety initial or refresher training in first aid and CPR awareness, in accordance with the company’s written procedures for wheelhouse personnel. The training can be provided internally or by a third party.
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.
10.5.2 Did the Master and Mate/Pilot’s personal safety initial or refresher training include confined space entry hazard awareness? (RCP V-C-1e-2)
The Master and Mate/Pilot must receive personal safety initial or refresher training including confined space entry hazard awareness in accordance with the company’s written confined space procedures. Companies that explicitly prohibit their employees from entering confined (or possibly enclosed) spaces must include their policy addressing 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 “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.
10.5.3 (a) Did the Master and Mate/Pilot’s personal safety initial or refresher training include injury prevention? (RCP V-C-1e-3)
The Master and Mate/Pilot’s personal safety initial or refresher training must include injury prevention. 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.
10.5.3 (b) Did the Master and Mate/Pilot’s personal safety initial or refresher training include back training? (RCP V-C-1e-3)
The Master and Mate/Pilot’s personal safety initial or refresher training must include back training. This includes training for proper lifting and body mechanics as applicable to the job responsibilities of the position.
10.5.3 (c) Did the Master and Mate/Pilot’s personal safety initial or refresher training include slip, trip and fall prevention? (RCP V-C-1e-3)
The Master and Mate/Pilot’s personal safety initial or refresher training must include slip, trip and fall prevention.
See 29 CFR 1910.20 through 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.
10.5.4 Did the Master and Mate/Pilot’s personal safety initial or refresher training include fall overboard prevention? (RCP V-C-1e-4)
The Master and Mate/Pilot’s personal safety initial or refresher training must include fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures.
Additional information regarding fall overboard prevention can be found in lesson plans published by the AWO Safety Committees.
10.6
Have the Master and Mate/Pilot received additional initial and refresher training including cargo knowledge and hazard awareness? (RCP V-C-1g)
The Master and Mate/Pilot must have received initial and refresher training including cargo knowledge and hazard awareness, in accordance with the company’s written procedures for cargo knowledge and hazard communications
29 CFR 1910.1200 Additional information regarding cargo knowledge may be found in 33 CFR Parts 154, 155 and 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.
10.7
Have the Master and Mate/Pilot received initial and refresher training including responsibility and authority of the Master? (RCP V-C-1h)
The Master and Mate/Pilot must have received initial and refresher training including responsibility and authority of the Master, in accordance with the company’s documented vessel personnel authorities and responsibilities.
10.8
Have the Master and Mate/Pilot received initial and refresher training for supervisory skills? (RCP V-C-1h)
The Master and Mate/Pilot must have received initial and refresher training in supervisory skills, as determined by the company.
This training may include human resources training, communications skills, dealing with difficult employees, leadership training, etc.
Questions 10.9.1-10.9.2 apply to wheelhouse personnel working with tank barges in tow:
10.9.1
Have the Master and Mate/Pilot working with tank barges in tow received additional initial or refresher training including first responder, spill mitigation and emergency response (may include HAZWOPER training) within the last five years? (RCP V-C-1f-1)
The Master and Mate/Pilot working with tank barges in tow must have received additional initial or refresher training, including first responder, spill mitigation and emergency response orientation, in accordance with the company’s written procedures for spill response within the last five years (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.
10.9.2
Have the Master and Mate/Pilot working with tank barges in tow received additional initial or refresher training including benzene awareness training and entry precautions (where applicable)? (RCP V-C-1f-2)
The Master and Mate/Pilot working with tank barges in tow must have received initial or refresher training in benzene awareness and entry precautions, in accordance with the company’s written benzene handling policy/procedures.
46 CFR Part 197 29 CFR 1910.1200
Additional information regarding benzene may be found in 46 CFR Part 197 Subpart C.
10.10 The following set of questions applies to training the engineer, or the person responsible for the engineer’s duties, must have received within the past five years, and are applicable only if an engineer or a person responsible for the engineer’s duties is a part of the vessel crew
10.10.1 Has the engineer received initial or refresher marine diesel school or in-house training, including equipment and technical enhancements within the past five years? (RCP V-C-2a)
The engineer must have received initial or refresher marine diesel school or in-house training, including equipment and technical enhancements, within the past five years.
Auditors should expect to see a certificate of training if completed at an outside facility, training logs, or a company-provided record of training completed in-house.
10.10.2 Has the engineer received initial or refresher training on company policies and procedures within the past five years? (RCP V-C-2b)
The engineer must have received initial or refresher training on company policies and procedures within the past five years.
10.10.3 Has the engineer received initial or refresher training on federal requirements and the company’s conformance to the federal regulations within the past five years? (RCP V-C-2b)
The engineer must have received initial or refresher training on federal requirements applicable to his or her position and the company’s conformance to the federal regulations within the past five years.
Federal regulations may include USCG, EPA, OSHA, DOT, etc., and company conformance may include the methods the company uses to comply with the regulations.
10.10.4 Has the engineer received initial or refresher training including marine firefighting and fire prevention within the past five years? (RCP V-C-2c)
The engineer must have received initial or refresher marine firefighting and fire prevention training within the past five years.
46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training
10.11 If applicable, questions 10.11.1-10.11.6 apply to the engineer’s personal safety training within the past five years (RCP V-C-2d):
10.11.1 Did the engineer’s personal safety initial or refresher training include first aid and CPR awareness? (RCP V-C-2d-1)
The engineer’s personal safety initial or refresher training must include first aid and CPR awareness, in accordance with the company’s written procedures. The training can be provided internally or by a third party.
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.
10.11.2 Did the engineer’s initial or refresher personal safety training include confined space entry hazard awareness? (RCP V-C-2d-2)
The engineer must receive personal safety initial or refresher training including confined space entry hazard awareness in accordance with the company’s written confined space procedures. Companies that explicitly prohibit their employees from entering confined (or possibly enclosed) spaces must include their policy addressing 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 “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.
Did the engineer’s personal safety initial or refresher training include injury prevention? (RCP V-C-2d-3)
The engineer’s personal safety initial or refresher training must include injury prevention.
The training program could include methods such as job hazard analyses, risk assessments, lessons learned, safety briefings, team assessments while performing activities, etc.
10.11.3 (b)
Did the engineer’s personal safety initial or refresher training include back training? (RCP V-C-2d-3)
The engineer’s personal safety initial or refresher training must include back training. This includes training for proper lifting and body mechanics as applicable to the job responsibilities of the position.
10.11.3 (c)
Did the engineer’s personal safety initial or refresher training include slip, trip and fall prevention? (RCP V-C-2d-3)
The engineer’s personal safety initial or refresher training must include slip, trip and fall prevention.
See 29 CFR 1910.20 through 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.
10.11.4 Did the engineer’s personal safety initial or refresher training include fall overboard prevention? (RCP-V-C-2d-4)
The engineer’s personal safety initial or refresher training must include fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures.
Additional information regarding fall overboard prevention can be found in lesson plans published by the AWO Safety Committees.
10.11.5 Did the personal safety initial or refresher training include lock-out/tag-out procedures? (RCP V-C-2d-5)
The engineer’s personal safety initial or refresher training must include lock-out/tag-out procedures, in accordance with the company’s written lock-out/tag-out procedures.
10.11.6 Has the engineer received first responder and spill mitigation initial or refresher training within the past five years (for engineers working on tank barge tows)? (RCP V-C-2e-1)
The engineer working on tank barge tows must have received first responder and spill mitigation initial or refresher training within the past five years, in accordance with the company’s written procedures for spill response.
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.
10.12 The following set of questions applies to the training the tankerman, or other properly licensed persons responsible for those duties must have received within the past five years, and are only applicable if a tankerman is a part of the vessel crew:
10.12.1 Has the tankerman received initial or refresher training on tank barge safety within the past five years? (RCP V-C-3a)
The tankerman must have received initial or refresher training on tank barge safety within the past five years. 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.
46 CFR 13.121(e) Table 2 46 CFR 13.120(c)
10.12.2 Has the tankerman received initial or refresher training on loading and discharge operations within the past five years? (RCP V-C-3a-1)
The tankerman must have received initial or refresher training on loading and discharge operations within the past five years. 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.
10.12.3 Has the tankerman received initial or refresher training on safety practices within the past five years? (RCP V-C-3a-2)
The tankerman must have received initial or refresher training on safety practices within the past five years, as determined by the company.
46 CFR 13.121(e) Table 2 46 CFR 13.120(c)
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.
10.12.4 Has the tankerman received initial or refresher training on environmental protection and loading procedures within the past five years? (RCP V-C-3a-3)
The tankerman must have received initial or refresher training on environmental protection and loading procedures within the past five years, in accordance with the company’s written procedures for loading vessel fuel, cargo transfer/handling and environmental policy.
46 CFR 13.121(e) Table 2 46 CFR 13.120(c)
10.12.5 Has the tankerman received initial or refresher federal regulation review and training within the past five years? (RCP V-C-3a-4)
The tankerman must have received initial or refresher training on federal regulations applicable to the position within the past five years.
Federal regulations may include USCG, EPA, OSHA, DOT, etc.
10.12.6 Has the tankerman received initial or refresher training for first responder, spill mitigation, and emergency response (may include HAZWOPER training) within the past five years? (RCP V-C-3a-5)
The tankerman must have received initial or refresher training for first responder, spill mitigation and emergency response, in accordance wit hthe company’s written procedures for spill response within the past five years (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.
10.12.7 Has the tankerman received initial or refresher training on vapor recovery/control operations within the past five years? (RCP V-C-3a-6)
The tankerman must have received initial or refresher training on vapor recovery/control operations within the past five years, in accordance with the company’s written vapor recovery/control procedures.
Additional guidance can be found in 46 CFR Part 39 and 40 CFR Part 61.
10.12.8 Has the tankerman received initial or refresher training on company policy and procedures within the past five years? (RCP V-C-3b)
The tankerman must have received initial or refresher training on company policy and procedures, as applicable to the position, within the past five years.
10.12.9 Has the tankerman received initial or refresher training reviewing federal requirements and the company’s conformance to the federal regulations within the past five years? (RCP V-C-3b)
The tankerman must have received initial or refresher training reviewing federal requirements applicable to the position and the company’s conformance to the federal regulations within the past five years.
Federal regulations may include USCG, EPA, OSHA, DOT, et.c, and company conformance may include the methods the company uses to comply with the regulations.
10.12.10 Has the tankerman received initial or refresher training on marine firefighting and fire prevention within the past five years? (RCP V-C-3c)
The tankerman must have received initial or refresher training on marine firefighting and fire prevention within the past five years. See 46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training.
46 CFR 13.121
10.13 If applicable, questions 10.13.1-10.13.5 apply to the tankerman’s personal safety training within the past five years (RCP V-C-3d):
10.13.1 Did the tankerman’s personal safety initial or refresher training include first aid and CPR awareness? (RCP V-C-3d-1)
The tankerman’s personal safety initial or refresher training must include first aid and CPR awareness, in accordance with the company’s written procedures. The training can be provided internally or by a third party.
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.
10.13.2 Did the tankerman’s personal safety initial or refresher training include confined space entry hazard awareness? (RCP V-C-3d-2)
The tankerman’s personal safety initial or refresher training must include confined space entry hazard awareness, in accordance with the company’s written confined space procedures. Companies that explicitly prohibit their employees from entering confined (or enclosed) spaces must include their policy addressing 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 “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 confied space hazard awareness can be found in lesson plans published by the AWO Safety Committees.
Did the tankerman’s personal safety initial or refresher training include injury prevention? (RCP V-C-3d-3)
The tankerman’s personal safety initial or refresher training must include injury prevention. 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.
10.13.3 (b)
Did the tankerman’s personal safety initial or refresher training include back training? (RCP V-C-3d-3)
The tankerman’s personal safety initial or refresher training must include back training. This includes training for proper lifting and body mechanics as applicable to the job responsibilities of the position.
10.13.3 (c)
Did the tankerman’s personal safety initial or refresher training include slip, trip and fall prevention? (RCP V-C-3d-3)
The tankerman’s personal safety initial or refresher training must include slip, trip and fall prevention.
See 29 CFR 1910.20 through 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.
10.13.4 Did the tankerman’s personal safety initial or refresher training include fall overboard prevention? (RCP V-C-3d-4)
The tankerman’s personal safety initial or refresher training must include fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures.
Additional information regarding fall overboard prevention can be found in lesson plans published by the AWO Safety Committees.
10.13.5 Did the tankerman’s personal safety initial or refresher training include cargo-specific training? (RCP V-C-3d-5)
The tankerman’s personal safety initial or refresher training must include cargo-specific training, in accordance with the company’s written procedures for cargo handling.
10.13.6 Has the tankerman received initial or refresher training on vessel communications system and procedures for communication related to tankerman duties within the past five years? (RCP V-C-3e)
The tankerman must have received initial or refresher training on vessel communications system and procedures for communication related to tankerman duties within the past five years. 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.
See 33 CFR 155.785 for additional information.
10.14 The following set of questions applies to training the deck crew must have received within the past five years:
10.14.1 Has the deck crew received initial or refresher training on deck operations and safety training within the past five years? (RCP V-C-4a)
The deck crew must have received initial or refresher training in deck operations and safety training within the past five years.
10.14.2 Has the deck crew received initial or refresher training on company policies and procedures within the past five years? (RCP V-C-4b)
The deck crew must have received initial or refresher training on company policies and procedures (as applicable to their position) within the past five years.
10.14.3 Has the deck crew received initial or refresher training on federal requirements and the company’s conformance to federal requirements within the past five years? (RCP V-C-4b)
The deck crew must have received initial or refresher training on federal requirements applicable to the position and the company’s conformance to federal requirements within the past five years.
Federal requirements may include USCG, EPA, OSHA, DOT, etc., and company conformance may include the methods the company uses to comply with the regulations.
10.14.4 Has the deck crew received initial or refresher training for vessel firefighting and fire prevention within the past five years? (RCP V-C-4c)
The deck crew must have received initial or refresher training for vessel firefighting and fire prevention within the past five years.
46 CFR 27.209 and RCP Addendum C Item 14 for RCP requirements for firefighting training.
10.15 Questions 10.15.1-10.15.5 apply to the deck crew’s personal safety training within the past five years (RCP V-C-4d):
10.15.1 Did the deck crew’s personal safety initial or refresher training include first aid and CPR awareness? (RCP V-C-4d-1)
The deck crew’s personal safety initial or refresher training must have included first aid and CPR awareness, in accordance with the company’s written procedures. The training can be provided internally or by a third party.
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.
10.15.2 Did the deck crew’s personal safety initial or refresher training include training for confined space entry hazard awareness? (RCP V-C-4d-2)
The deck crew’s personal safety initial or refresher training must have included training for confined space entry hazard awareness, in accordance with the company’s written confined space entry procedures. Companies that explicitly prohibit their employees from entering confined (or possibly enclosed) spaces must include their policy addressing this.
Additional information regarding confined or enclosed space entry may be found in 29 CFR 1910.146 and 29 CFR 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.
10.15.3 (a)
Did the deck crew’s personal safety initial or refresher training include injury prevention? (RCP V-C-4d-3)
The deck crew’s personal safety initial or refresher training must have included injury prevention. This includes training for the 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.
10.15.3 (b)
Did the deck crew’s personal safety initial or refresher training include back training? (RCP V-C-4d-3)
The deck crew’s personal safety initial or refresher training must have included back training. This includes training for proper lifting and body mechanics as applicable to the job duties of the position.
Did the deck crew’s personal safety initial or refresher training include slip, trip and fall prevention? (RCP V-C-4d-3)
The deck crew’s personal safety initial or refresher training must have included slip, trip and fall prevention.
See 29 CFR 1910.20 through 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.
10.15.4 Did the deck crew’s personal safety initial or refresher training include fall overboard prevention? (RCP V-C-4d-4)
The deck crew’s personal safety initial or refresher training must have included fall overboard prevention, in accordance with the company’s written fall overboard prevention procedures.
Additional information regarding fall overboard prevention can be found in lesson plans published by the AWO Safety Committees.
10.15.5 Did the deck crew’s personal safety initial or refresher training include lock-out/tag-out procedures? (RCP V-C-4d-5)
The deck crew’s personal safety initial or refresher training must have included lock-out/tag-out procedures, in accordance with the company’s written lock-out/tag-out procedures.
29 CFR 1910.147
10.16 Has the deck crew received first responder and spill mitigation initial or refresher training (for crewmembers working on tank barge tows) within the past five years? (RCP V-C-4e-1)
For crewmembers working on tank barge tows, the deck crew must have received first responder and spill mitigation initial or refresher training within the past five years, in accordance with the company’s written procedures for spill response.
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.
The following question applies to any individual who has been designated as the Person In Charge (PIC):
10.17 Has the PIC received Coast Guard required training on procedures for fuel transfer? (RCP II-B-5 and III-F-7)
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.
33 CFR 155.700-820 33 CFR 155.715 33 CFR 155.720
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.
10.18
Have the appropriate crewmembers been trained in vessel control procedures? (RCP II-F-5)
The appropriate crewmembers must have been trained in vessel control procedures for those crewmembers who will respond to operator incapacitation situations.
Has the crew received training on an employee assistance program?
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.
46 CFR 16.401(b) The auditor should find documentation of the training the crewmembers received.
10.19.2
Have the supervisory personnel received training on an employee assistance program?
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.
46 CFR 16.401(b) The appropriate person(s) must have been trained. Supervisory personnel may be any position on the vessel, not just the master.
Auditor note: The auditor shall use the questions in this section to interview multiple different crewmembers during the course of the vessel audit, to determine crewmembers’ familiarity with the company’s policies and procedures. Questions shall be asked to all crew positions, not just the Master or Mate/Pilot. These questions are designed to start a conversation with the crewmembers, and the auditor is encouraged to ask additional questions if s/he feels they are necessary to verify the vessel crew’s compliance with the RCP.
11.1 (a) Do crewmembers appear to be familiar with the company’s risk assessment and risk management procedures for dealing with hazards which may contain risks to onboard personnel? (RCP II-A-1)
Crewmembers must appear to be familiar with the company’s risk assessment and risk management procedures for dealing with hazards that may contain risks to onboard personnel.
The auditor should determine if crewmembers are familiar with risk discovery, risk evaluation, and risk controls.
11.1 (b) Do crewmembers appear to be familiar with the company’s risk assessment and risk management procedures for dealing with hazards which may contain risks to the company vessels? (RCP II-A-1)
Crewmembers must appear to be familiar with the company’s risk assessment and risk management procedures for dealing with hazards that may contain risks to the company’s vessels.
The auditor should determine if crewmembers know about risks to the company’s vessels, including fire, sinking, allusion, collision, etc.
11.1 (c) Do crewmembers appear to be familiar with the company’s risk assessment and risk management programs for dealing with hazards which may contain risks to the environment? (RCP II-A-1)
Crewmembers must appear to be familiar with the company’s risk assessment and risk management procedures for dealing with hazards that may contain risks to the environment.
The auditor could ask the crewmembers what some of the hazards would be, including oil spills and groundings. The auditor could ask the crewmembers what their responsibilities are in regards to oil spills, fire, etc.
11.2 (a) Do crewmembers appear to be familiar with the company’s procedures for near-miss reporting? (RCP II-A-5)
Crewmembers must appear to be familiar with the company’s procedures for near-miss reporting.
The auditor should determine if the crewmembers know what a near-miss is.
11.2 (b) Do crewmembers appear to be familiar with the company’s procedures for near-miss investigation? (RCP II-A-5)
Crewmembers must appear to be familiar with the company’s procedures for near-miss investigation.
11.3 Do crewmembers appear to be familiar with the company’s vessel operating procedures? (RCP II-B)
Crewmembers must appear to be familiar with the company’s specific vessel operating procedures. The auditor should ask open ended questions of the crew to determine their awareness of all vessel operating procedures. The crewmembers should be able to identify familiarity with procedures dealing with the following: bridge transit, locking, skiff/yawl; making up tow; etc.
The auditor should be asking crewmembers questions that have them describing their duties during locking, docking, bridge transit, etc.
11.4 Do crewmembers appear to be familiar with the vessel’s company-specified critical systems or equipment? (RCP II-B-6)
Crewmembers must appear to be familiar with the vessel’s critical systems or equipment, which may place the towing vessel, the towing vessel crew or the environment into a hazardous situation if there was a sudden failure of said equipment.
The auditor could ask the crewmembers to give examples of critical systems and have the crewmembers describe what their responsibilities are during a critical system failure.
11.5 (a) Do crewmembers responsible for vessel maintenance personnel appear to be familiar with the company’s procedures for conducting a risk assessment and obtaining required approvals before critical equipment or systems are shut down for maintenance? (RCP II-B-7f) (RCP II-A-1)
The crewmembers responsible for vessel maintenance must appear to be familiar with the company’s procedures for conducting a risk assessment and obtaining required approvals before critical equipment or systems are shut down for maintenance.
The auditor could ask the crewmembers to describe how they would perform a critical system shutdown, and who they would need to obtain approval from before shutting down the equipment.
11.5 (b) Do crewmembers responsible for vessel maintenance appear to be familiar with the company’s procedures for conducting a risk assessment and obtaining required approvals before critical equipment or systems are bypassed for maintenance? (RCP II-B-7f) (RCP II-A-1)
Crewmembers responsible for vessel maintenance must appear to be familiar with the company’s procedures for conducting a risk assessment and obtaining required approvals before critical equipment or systems are bypassed for maintenance.
11.5 (c) Do crewmembers responsible for vessel maintenance appear to be familiar with the company’s procedures for conducting a risk assessment and obtaining required approvals before critical equipment or systems are taken out of service for maintenance? (RCP II-B-7f) (RCP II-A-1)
Crewmembers responsible for vessel maintenance must appear to be familiar with the company’s procedures for conducting a risk assessment and obtaining required approvals before critical equipment or systems are taken out of service for maintenance.
11.6 Do crewmembers appear to be familiar with the requirement to maintain proper quantities of critical stores as identified by the company’s procedure for critical stores? (RCP II-B-11)
Crewmembers must appear to be familiar with the requirement to maintain proper quantities of critical stores as identified by the company’s procedure for critical stores.
11.7 For inland vessels, do crewmembers appear to be familiar with the inspection and replacement program for rigging? (RCP III-E-3)
Crewmembers of inland vessels must appear to be familiar with the inspection and replacement program for the rigging.
The auditor could ask a crewmember to show how they would inspect the rigging on a face wire, rope, etc.
11.8 For coastal vessels, do crewmembers appear to be familiar with the tow wire inspection, maintenance and replacement program? (RCP IV-E-6)
For coastal vessels, crewmembers must appear to be familiar with the tow wire inspection, maintenance and replacement program.
11.9 Do crewmembers appear to be familiar with the company’s safety policy? (RCP II-C)
Crewmembers must appear to be familiar with the company’s safety policy.
11.10 Do crewmembers appear to be familiar with the company’s security program? (RCP II-D)
Crewmembers must appear to be familiar with the company’s security program, whether it is RCP-required security program, USCG Approved Security Plan or USCG Approved Alternative Security Program.
The auditor could ask the crewmembers what MARSEC level the vessel is currently operating under.
11.11 (a) Are crewmembers familiar with MARSEC levels? (RCP II-D)
Crewmembers must appear to be familiar with the meaning of MARSEC levels, and the company’s expectation for crewmember response when levels change.
The auditor could ask the crewmembers how many MARSEC levels there are, and what are their responsibilities at each level?
11.11 (b) Do crewmembers appear familiar with specific activities that are required to be reported to the USCG? (RCP II-D)
Crewmembers must appear to be familiar with the specific activities that are required to be reported to the USCG. Several resources are available to companies that are not required to comply with MTSA requirements, which can provide guidance for those companies to use. The Homeland Security River Watch Program Brochure, which includes contact information for reporting suspicious activities to the USCG at 1-800-424-8802 is one example.
11.12 Do crewmembers appear to be familiar with the company’s written environmental policy? (RCP II-E)
Crewmembers must appear to be familiar with the company’s written environmental policy.
The auditor could ask the crewmembers where MARPOL placards should be posted, and what the crew does with different waste on board.
11.13 Do crewmembers appear to be familiar with the company’s emergency response procedures? (RCP II-F)
Crewmembers must appear to be familiar with the company’s emergency response procedures. These include but are not limited to: personal injury response, spill response plan and/or contingency plan, vessel accident response, onboard emergency response training and drills and operator incapacitation.
The auditor could ask crewmembers what their duties are during an onboard injury to a crewmember.
11.13 (a) Do crewmembers appear to be familiar with the company’s procedures for operator incapacitation? (RCP II-F-5)
Crewmembers must appear to be familiar with the company’s procedures for operator incapacitation.
The auditor could ask crewmembers questions to determine if they know how to stop the tow and communicate with other vessels.
11.13 (b) Do crewmembers appear to be familiar with operator incapacitation notification procedures? (RCP II-F-5)
Crewmembers must appear to be familiar with the notification procedures for an incident involving operator incapacitation.
11.14 Are crewmembers aware of the name of the company’s designated person ashore? (RCP II-I-2)
Crewmembers must be aware of the name of the company’s designated person ashore.
The crewmembers should understand the kinds of situations which might require them to contact the designated person ashore.
11.15 Do crewmembers appear to be familiar with the company’s drug and alcohol policy? (RCP II-J-3)
Crewmembers must appear to be familiar with the company’s drug and alcohol policy.
46 CFR 16.210 46 CFR 16.401
See 33 CFR Part 95, 46 CFR Parts 4 and 16, and 49 CFR Part 40 for additional information.
11.16 Do crewmembers appear to be familiar with the company’s employee performance evaluation program? (RCP II-J-4)
Crewmembers must appear to be familiar with the company’s employee performance evaluation program.
The auditor could ask the crewmembers if they have ever been evaluated by anyone. Ask if they know what functions they are evaluated on.
11.17 Are the crewmembers implementing the company’s on board vessel orientation policy or program? (RCP II-J-5)
The crewmembers must be implementing the company’s on board vessel orientation policy or program.
Auditors will want to ask individual crew members about their familiarity with the on board vessel orientation and look for vessel-specific orientation records.
11.18 Do crewmembers appear to be familiar with the company’s personnel development program? (RCP II-J-6)
Crewmembers must appear to be familiar with the company’s personnel development program.
Auditors can ask crewmembers what steps they have to take to move up in the ranks.
11.19 Do crewmembers appear to be familiar with the company’s prescription medication notification policy/procedure? (RCP II-J-7)
Crewmembers must appear to be familiar with the company’s prescription medication notification policy/procedure.
11.20 Do crewmembers appear to be familiar with the company’s personal hygiene policy/procedure? (RCP II-J-8)
Crewmembers must appear to be familiar with the company’s personal hygiene policy/procedure.
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 evaluations.
11.21 Do crewmembers appear to be familiar with the company’s sanitation and safe food handling policy/procedure? (RCP II-J-9)
Crewmembers must appear to be familiar with the company’s sanitation and safe food handling policy/procedure.
Additional information regarding safe food handling and galley safety can be found in lesson plans published by the AWO Safety Committees.
11.22 Do crewmembers appear to be familiar with the company’s disciplinary policy/procedure? (RCP II-J-10)
Crewmembers must appear to be familiar with the company’s disciplinary policy/procedure.
The auditor could ask the crewmembers if they know what things would get them fired.
11.23 Do crewmembers have a clear understanding of the company's work hours policy? (RCP V-B)
Crewmembers must have a clear understanding of the company’s work hours policy.
The following set of questions are applicable to wheelhouse personnel:
11.24 Do wheelhouse personnel appear to be familiar with the company’s procedures for making horsepower-to-tow size decisions? (RCP II-B-3)
Wheelhouse personnel must appear to be familiar with the company’s procedures for making horsepower-to-tow size decisions.
11.25 Do wheelhouse personnel appear to be familiar with the required list of documentation that is to be carried onboard the towing vessel? (RCP II-B-4)
Wheelhouse personnel must appear to be familiar with the required list of documentation that is to be carried onboard the towing vessel.
11.26 If applicable, do wheelhouse personnel appear to be following the company’s change of watch procedure? (RCP II)
If the company has a change of watch procedure, wheelhouse personnel must appear to be following the company’s change of watch procedure.
The auditor could ask the crew to describe the procedure.
11.27 Except in an emergency, is there at least one qualified wheelhouse person and one additional crewmember on duty at all times while the vessel is underway? (verify) (RCP V-A-2)
Except in an emergency, there must be at least one qualified wheelhouse person and one additional crewmember on duty at all times while the vessel is underway.
11.28
Is the Master aware that he or she is responsible for the safety of the towing vessel? (RCP II-I-1a)
The Master must be aware that he or she is responsible for the safety of the towing vessel.
Is the Master aware that he or she is responsible for adhering to the provisions of the Certificate of Inspection (COI), if issued? (RCP II-I-1a-1)
The Master must be aware that he or she is responsible for adhering to the provisions of the Certificate of Inspection, if issued.
11.28.2
Is the Master aware that he or she is responsible for the vessel’s compliance with applicable regulations? (RCP II-I-1a-2)
The Master must be aware that he or she is responsible for the vessel’s compliance with applicable regulations.
11.28.3
Is the Master aware that he or she is responsible for compliance with the safety management system applicable to towing vessels? (RCP II-I-1a-3)
The Master must be aware that he or she is responsible for compliance with the safety management system applicable to towing vessels.
11.28.4
Is the Master aware that he or she is responsible for reviewing the contents of the safety management system applicable to the towing vessel, and reporting non-conformities to shore-base management? (RCP II-I-1a-4)
The Master must be aware that he or she is responsible for reviewing the contents of the safety management system applicable to the towing vessel, and for reporting non-conformities to shore-based management.
11.29
Is the Master aware that he or she is responsible for supervising all persons onboard in carrying out their assigned duties? (RCP II-I-1a-5)
The Master must be aware that he or she is responsible for supervising all persons onboard in carrying out their assigned duties.
11.30
Is the Master aware that he or she has the authority to determine if it is unsafe for the towing vessel to proceed? (RCP II-I-1b-1)
The Master must be aware that he or she has the authority to determine if it is unsafe for the towing vessel to proceed.
Is the Master aware that if he or she has determined that 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? (RCP II-I-1b-1)
The Master must be aware that if he or she has determined that 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.
11.30.2
Is the Master aware that he or she has the authority to determine that an operation endangers the vessel or crew? (RCP II-I-1b-1)
The Master must be aware that he or she has the authority to determine that an operation endangers the vessel or crew.
11.30.3
If the Master has determined that an operation endangers the vessel or crew, is the Master aware that he or she 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 Master must be aware that if he or she has determined that 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.
11.30.4
Is the Master aware that he or she has the authority to determine that an unsafe condition exists? (RCP II-I-1b-1)
The Master must be aware that he or she has the authority to determine that an unsafe condition exists.
11.30.5
If the Master has determined that an unsafe condition exists, is the Master aware that he or she 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 Master must be aware that if he or she 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.
Is the Master aware that nothing in the company’s 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 for taking such steps as he or she deems necessary and prudent to assist vessels in distress or for other emergency conditions? (RCP II-I-1b-2)
The Master must be aware that nothing in the company’s 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 he or she deems necessary and prudent to assist vessels in distress, or for other emergency conditions.
11.31
Is the Master aware that he or she has the ability to request the company’s help when necessary? (RCP II-I-1b-3)
The Master must be aware that he or she has the ability to request the company’s help when necessary.
11.32
Is the Master knowledgeable about general operating rules for intoxicant use?
The Master must know, or be able to find the source of information for the following: 33 CFR 95.050 (a) The marine employer shall exercise due diligence to assure compliance with the applicable provisions of this part. (b) If the marine employer has reason to believe that an individual is intoxicated, the marine employer shall not allow that individual to stand watch or perform other duties. 33 CFR 95.020 (b) The individual is operating a vessel other than a recreational vessel and has an alcohol concentration of .04 percent by weight or more in their blood; or (c) The individual is operating any vessel and the effect of the intoxicant(s) consumed by the individual on the person’s manner, disposition, speech, muscular movement, general appearance or behavior is apparent by observation.
Is the Master knowledgeable about requirements for marine casualty reporting?
The Master must know, or be able to find the source of information for reporting of marine casualties to the U.S. Coast Guard, as outlined in 46 CFR 4.05-1 and 46 CFR 4.05-10.
46 CFR 4.05-1 46 CFR 4.05-10
11.34
Is the Master aware of the requirements for hazardous conditions reporting?
The Master must know, or be able to find the source of information for the following: 33 CFR 160.204 Hazardous condition means any condition that may adversely affect the safety of any vessel, bridge, structure, or shore area or the environmental quality of any port, harbor, or navigable waterway of the United States. It may, but need not, involve collision, allision, fire, explosion, grounding, leaking, damage, injury or illness of a person onboard, or manning-shortage. 33 CFR 160.215 Whenever there is a hazardous condition, either aboard a vessel or caused by a vessel or its operation, the owner, agent, master, operator, or person in charge shall immediately notify the nearest Coast Guard Sector Office or Group Office. (Compliance with this section does not relieve responsibility for the written report required by 46 CFR 4.05-10.)
33 CFR 160.215 33 CFR 160.204
11.35 Is the Master aware of the company specific reporting requirements? (RCP II-A-4f)
The Master must be aware of any additional company-specific reporting requirements.
The following set of questions applies to towing vessel crew’s authorities and responsibilities, in addition to the master, and mate/pilot’s authorities and responsibilities, and the auditor should ask these questions to multiple crew members of different positions:
11.36
Are the crewmembers aware that they are responsible for the safety of the towing vessel? (RCP II-I-1c-1)
The crewmembers must be aware that they are responsible for the safety of the towing vessel.
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