Responsible Carrier Program
What is the Responsible Carrier Program?
The Responsible Carrier Program (RCP) is intended to serve as a template for AWO member companies to use in developing company-specific safety programs that are consistent with applicable law and regulation, that incorporate sound operating principles and practices, and that are practical and flexible enough to reflect a company's unique operational needs.
The RCP does not attempt to catalogue or to duplicate that which is already mandated by federal law or regulation. Rather, the RCP seeks to complement and build upon existing law and regulation and to identify sound operating principles and practices that will enhance the safety of a company's operations. The RCP is intended to be a practical program and it takes its inspiration not from a government-prescribed standard or from a deep-sea, ship-focused model, but from the experience of the tugboat and towboat industry and its operators themselves, based on principles of safe and sound operation that many companies in the industry already voluntarily embraced.
It is not the aim of the RCP to homogenize industry operations, however; the industry is far too diverse for such a simplistic approach. Rather, the RCP aims to combine a set of common principles and practices that can be observed and incorporated by a company regardless of its trade or its size, with an emphasis on company-specific policies and procedures which may vary significantly both between and among industry sectors. The policies and procedures developed by a small inland grain carrier will inevitably differ from those of a large coastal oil transporter; indeed, the policies developed by one carrier will likely differ even from those of a similarly situated company. The RCP is rooted in the premise that common principles of safe operation, and industry practices that are recognized as sound standards industry-wide, can and must coexist with the operational diversity that has long been a hallmark of the U.S. tugboat, towboat and barge industry.
Current RCP Status & AWO Third Party Audited SMS Membership Requirement
At the outset of 2020, recognizing that significant changes had occurred in the towing industry and the safety and regulatory landscape since the Responsible Carrier Program’s (RCP) original development, AWO initiated a process of deep listening, inviting members to discuss the role of the RCP and AWO’s requirement that carrier members maintain third-party audited compliance with an RCP-equivalent safety management system. Based on this feedback, in August 2020, the Executive Committee adopted a motion affirming AWO’s commitment to leading and supporting members in continuously improving safety, security and environmental stewardship, and directing the RCP Standards Board to develop recommendations on how to implement the following principles:
- Continuing to promote adoption of robust safety management systems throughout the tugboat, towboat and barge industry;
- Reaffirming that AWO membership is open to carriers that comply with the RCP or other, equivalent third party-audited safety management system; and,
- Maintaining the Responsible Carrier Program for members who wish to use the RCP as their safety management system and exploring opportunities to streamline the administration of RCP certification for AWO members and for AWO.
At its October 2020 meeting, the Board of Directors adopted RCP Standards Board recommendations designed to: 1) enhance flexibility for all AWO member companies; 2) eliminate duplication for member companies using the TSMS option; 3) clarify requirements for member companies using the Coast Guard option; 4) reduce burdens on members using the RCP as their safety management system; and 5) reduce administrative burdens on AWO and the RCP Standards Board. These recommendations were incorporated as authorized revisions to the standard and addenda with an effective date of January 1, 2021.
To remain members in good standing, AWO members must achieve third-party audited compliance with a safety management system that meets the minimum requirements of 46 CFR Subchapter M Part 138. However, a carrier member is not required by AWO to utilize the TSMS option to satisfy its Subchapter M compliance requirements. A company may instead elect to utilize the Coast Guard option for the purposes of Subchapter M compliance and, separately, maintain third-party audited compliance with a safety management system that meets the aforementioned minimum requirements in order to satisfy AWO’s membership requirement.