With increased emphasis on accountability and responsibility, the American Waterways Operators (AWO) is moving closer to having the Coast Guard accept its Responsible Carrier Program (RCP) as a Towing Safety Management System (TSMS) under the new Subchapter M regulations.
At a webinar recently, AWO outlined some recent changes to strengthen the RCP and get the Coast Guard’s OK. The changes are effective January 2016, and the long-awaited towing vessel inspection rule is now expected to be published in February. A TSMS designee will be able to inspect a vessel instead of the Coast Guard.
Internal auditing programs, for instance, must describe the auditor’s qualifications and training, and auditors can’t evaluate their own areas. AWO suggests employees be trained by an outside organization and have the right temperament for the job.
“They need to remain objective and impartial,” said Doug Carlson, safety manager, Seabulk Towing Inc., and a webinar leader.
Other RCP requirements include:
• Annual evaluations of the effectiveness of the safety management system
• Reporting of non-conformities
• Conducting internal audits up to three months before the original anniversary date
• Auditing each managing office and each vessel annually
• Including “complete corrective actions” from internal audits in an organization’s continuous improvement program
In a June 1 letter to AWO, the Coast Guard indicated it intends to accept the RCP, noting it is “substantively equivalent” to the International Safety Management (ISM) code. When the final rule is published, the Coast Guard said it will “work with AWO to identify any changes to the RCP that are needed” for formal acceptance.
Safety management systems are a key component of Subchapter M, one of the most significant rules for the towing industry since operators were required to be licensed in 1972.
The Coast Guard “did not specifically give us suggestions as to what we should change,” said Holly Riester, AWO’s director of Safety & Environmental Stewardship, also a webinar leader. “They did give us guidance making sure we were going in the right direction.”
And even with the changes, “There may be some additional tweaks once the final rule comes out,” she said.
