On January 26, after “a year of deep listening and robust member dialogue,” The American Waterways Operators published revisions to its Responsible Carrier Program. The new RCP incorporates recommendations approved by the RCP Standards Board that make it easier for AWO’s members to meet the membership requirement to maintain third party audited compliance with a safety management system (SMS). The changes were announced in an email to AWO members by Brian Bailey, director-safety and environmental stewardship.
The changes published by AWO include the following:
• AWO members may use any safety management system that meets the minimum requirements of 46 CFR Part 138 to meet AWO’s SMS membership requirement and secure certification as a Responsible Carrier;
• companies using the TSMS option for Subchapter M compliance can simply supply AWO with a copy of their TSMS Certificate to demonstrate compliance; and
• companies using the RCP as their SMS will benefit from the removal of unduly constraining RCP deadlines for provisional audits and the revision of internal audit and corrective action plan due dates.
The Towing Vessel Inspection Bureau, a third-party provider of SMS audit and survey services, and of training leading to certification of auditors and surveyors, said its staff will be reviewing the changes and working with its leadership in the coming days “to determine what, if any, impacts there are to TVIB processes for its TPO TSMS.”
In his email, Bailey said, “These changes, which were approved by [AWO’s] board of directors in October 2020, are the result of our discussions with AWO members regarding the role of the RCP and our SMS membership requirement. They are designed to uphold our longstanding commitment to safety management systems while giving members more flexibility in meeting the SMS membership requirement, eliminating duplication for companies using the TSMS option for Subchapter M compliance, clarifying requirements for companies using the Coast Guard option, and reducing burdens on members using the RCP as their SMS. Additionally, they will streamline RCP certification and administration processes.”
The changes became effective January 1. Bailey said AWO is encouraging members to review them; it has published an FAQ on its website.