Page 20: of Marine News Magazine (March 2016)
Push boats, Tugs & Assist Vessels
COLUMN REGULATORY WATCH
R : 180 . 90 D management system; the second is its antithesis.
ENEWALS VS AYS
Also starting in 2016, the RCP renewal window for re- certi? cation had been shortened from 180 days to 90 days. RCP R C P F YENEWAL YCLE HASING INTO A IVE EARS
However, 180 days is being allowed for in the recently Previously, the RCP renewal cycle was every three years. published AWO ‘frequently asked questions’ guide. It does This has now been increased to every ? ve years, with a appear that when you are at the 5 year (not the previous 3 mid-period RCP external audit to be conducted between year) renewal of your RCP status, the window will shrink Years two and three, or between Months 24 to 36. The to 3 months prior to the renewal date. You can still have requirement is to be phased in over time, based on the your RCP audit conducted by a TVIB certi? ed RCP au- company’s current RCP renewal status date. Also, the re- ditor 180 days prior to your RCP renewal date (the date quirement to have 100 percent of all vessels audited (as op- listed on the RCP “status” page of the AWO website), and posed to as little as 10 percent) will be phased in over the still keep the same renewal date with no “certi? cate creep,” ? ve year cycle. Equipment in lay-up status will not need to but next round, it shrinks to 90 days. The requirement be audited, however, if they are in use just prior to the ? ve- to have all non-conformities corrected prior to recerti? ca- year renewal date and have yet to be audited, these vessels tion is still in place. You’ll only have 180 (then 90) days to will need to be audited prior to the company being issued a correct any line items on the worksheet or checklist with renewal certi? cate. This adds another item to your lay-up which your company is not in compliance. The need for checklist: whether or not to have the vessel go through an a pre-audit to ? nd these issues prior to your external audit external RCP audit prior to lay-up. cannot be emphasized enough.
XTERNAL ESSEL UDITS
For vessel RCP audits (each vessel must now get audited E V A once every 5 years) corrective actions resulting from the Previously, the RCP required vessel audits took place in
RCP audit must be resolved with 90 days. In addition, you conjunction with the management audit, with 10 percent are only allowed a maximum of 90 days prior to renewal of all vessels to be audited during the RCP recerti? cation date to commence an audit. Once the audit is completed (or initiation) process. Now, whereas every vessel must go on a vessel, another audit is due 5 years later, and can be through an audit once during the ? ve year process, the completed up to 90 days prior to the anniversary. This is vessel audits are no longer a part and parcel element of the one-half as many audits required by the ISM Code. And, if management audit. The vessel audit worksheet has been your vessel does not have any other certi? cates, Class must expanded greatly, and includes many of the line items cov- sign off annually. You may be having ISM external audits ered during the management audit. This duplicate work is more often than that (as often as yearly, in addition to you needed as different RCP auditors may be conducting these thorough internal audit). audits. Moreover, the management audit may have been
Vessel non-conformities also now require action within conducted a year or two before the vessel audit, which re- 90 days. It is through this metric that AWO is requiring quires more evidence of compliance with procedure. Mere members to comply with to ensure that management sys- documentation of a procedure is no longer enough; proof tems are adept and nimble enough to address problems of compliance is now required. Any ? nding of non-com- within three, rather than six month time frames. pliance with the RCP requires 90 days for correction(s) before the external audit is deemed successfully completed.
VOIDING ROCEDURE HURN
A ‘P C ’
ESIGNATED ERSON SHORE ORE EFINED
While not implicitly listed in the changes, having ef- D P A (DPA) – M D ,
AND LAYING A TARRING OLE fective measures in place to vet any changes to your man- P S R agement system also is incredibly important. ‘Procedure Straight out of the ISM (International Safety Manage- churn’ – for example, issuing a new procedure merely to ment) Code, the DPA must be an integral part of your ensure conformity, only to have the new procedure itself management system. A DPA’s minimum educational re- later revised and re-issued – should be avoided at all costs. quirements, training and education, and other quali? ca-
It makes for a lot of extra work and an unhappy crew. It tions must be clearly documented as well as his or her in- is better (and less time consuming) to spend a little extra dependence (from the chain of command) and access to time making sure the procedure ? ts, rather than ‘churning’ top level management. Strictly speaking, your port captain your management system. The ? rst method embodies the cannot be a DPA. The DPA needs to be a person outside whole notion of ‘continual improvement’ with respect to a of the ? eet management structure and one able to effect
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