Page 18: of Marine News Magazine (March 2016)

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REGULATORY WATCH

The (Updated) Responsible Carrier Program

A Primer: (...and Please Don’t Shoot the Messenger).

By (Captain) Katharine Sweeney

Last summer, the United States Coast the management worksheet were already underway. Your

Guard (USCG) announced their in- procedure for control of records hopefully required you to tent to accept the American Waterway keep this documentation as it will be of interest at external

Operators (AWO) Responsible Carrier (RCP initial or renewal) audit time. This year, all vessels

Program (RCP) as an acceptable Towing will need to be internally audited utilizing 100% of the

Safety Management System (TSMS) un- worksheet or whatever internal auditing tool your com- der pending Subchapter M regulations. pany develops.

The acceptance did not come without No longer is it suf? cient to audit each vessel utilizing a

Sweeney some major changes to the RCP, chang- portion of the RCP, merely ensuring 100% of the RCP is es that were needed to ensure the RCP covered by your ? eet at large. Each vessel is required to be would meet USCG requirements and become a viable op- audited completely, utilizing all elements of the RCP vessel tion for operators once new Subchapter M regulations take worksheet. These audits need to happen every 12 months, effect. When that happens is anyone’s guess. but unlike the ISM code, the anniversary of when the au-

At the AWO Safety Conference in New Orleans in Feb- dit is required for each vessel can remain the same, provid- ruary, the USCG stated their preferred method was for ed the audit is completed in the 3 month window prior to companies to have an audited TSMS in place with the con- the audit anniversary date. Originally when the ISM came tinual improvement aspect of the company’s operation and out, only periodic internal audits were required. In 2010, maintenance of the company’s vessels an audited TSMS the wording was changed to ‘at least every 12 months.’ It is brings. Further, the USCG did not want the “USCG Op- also assumed, that it is a metric of the company’s manage- tion” available to operators. They also admitted that two ment system as to the ability to conduct thorough internal years after publication of Sub M, only 25% of the cur- audits in a timely fashion. Meaning, that if you don’t get it rent uninspected ? eet will have been audited. There will be done in 12 months, this could be construed as a sign that growing pains, but the Coast Guard remains committed to your company is not committed to the continual improve- working with companies to work out the kinks. ment process.

The internal management audits are much the same

RCP M story. Every year, 100 percent of the RCP management

ODIFICATIONS

The modi? cations are extensive. It is very important to audit worksheet must now be completed, at all of? ces of realize all of these changes were the result of input from your organization that have an input in managing the ves- the USCG and the AWO partnership to ensure all require- sels. These audits must be completely every 12 months, ments for approval as a TSMS were met. Beyond this, these and they can be completed early (up to 3 months prior to changes were not proposed by the facilitator of the RCP, the annual date) and still maintain the original anniversary the Towing Vessel Inspection Bureau (TVIB). The revised date. Unlike the ISM code, towboat operators won’t suffer worksheets for both the RCP Management Audit and the from “certi? cate creep.”

RCP Vessel Worksheet were approved by the AWO and are Your system should further include a policy for inter- available to download from the TVIB website. Any con- nal audits and that a review of the management system is cern over these changes should therefore not be directed at completed as part of the internal audit (or in addition to) the TVIB. As Cathy Hammond, immediate past President and procedures outlining as to what this review will con- of the TVIB implored, “Don’t shoot the messenger.” tain at a minimum. Also required are procedures outlining

If you performed internal audits last year of both your an internal auditor’s minimal educational requirements, of? ces and vessels, then your document control procedures training and experience, as well as any other quali? cations should have required you to use the most recent version required and the procedures should clearly dictate the pa- of the RCP checklist or worksheet. If that was the case, rameters to allow for independence with respect to the as- then you are ahead of the game, as some of the changes to sets being audited.

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