On 01/26/2021, the American Waterways Operations (AWO) published the revised Responsible Carrier Program (RCP) that incorporates the RCP Standards Board recommendations and board approved changes designed to make it easier for their members to meet the membership requirement to maintain third party audited compliance with a safety management system (SMS). Following are a few of the key areas of change:
- Members may use any SMS 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.
- 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 staff will be reviewing the changes and working with our leadership in the coming days to determine what, if any, impacts there are to TVIB processes for our TPO TSMS option customers currently using the RCP for compliance with 46 CFR Subchapter M as well as for those customers that have elected the USCG option and are AWO members that must maintain compliance with the RCP to meet AWO membership requirements.
Additional information about the RCP may be found on the AWO RCP webpage.