RCP Standards Board Memos
What is the role of the RCP Standards Board?
The role of the Standards Board is to make recommendations to the AWO Board of Directors on the implementation of the RCP and AWO’s membership requirement that all carrier members must demonstrate third party audited compliance with an SMS that meets the minimum requirements of 46 CFR Part 138.
The Standards Board has the authority to issue Clarifications and Directives Memoranda, as needed, to guide RCP interpretation by TPOs. Clarifications and Directives Memoranda must not conflict with the minimum requirements of 46 CFR Subchapter M. The AWO Safety & Environmental Stewardship Department is responsible for maintaining and archiving Standards Board Clarifications and Directives Memoranda, and issuing copies to affected parties.
The Standards Board may be called upon to adjudicate a dispute arising from the conduct of an audit between a U.S. Coast Guard-approved TPO and an AWO member using the Coast Guard option for Subchapter M compliance and, separately, maintaining a third party audited SMS. Following disputants’ attempt at and failure to resolve the disagreement, an appeal may be filed via written notification to the AWO Safety & Environmental Stewardship Department detailing the dispute and requesting adjudication.
What is the composition of the RCP Standards Board?
The AWO Standards Board must include one AWO member each representing the Coastal, Inland Liquid, and Inland Dry sectors, one member each representing the inland and coastal Harbor Services sector, and two shipper members, preferably one liquid and one dry cargo shipper. Standards Board membership is limited to AWO carrier members only. A representative of the AWO Safety & Environmental Stewardship Department must serve ex officio, as a nonvoting member of the Standards Board.
Standards Board members are appointed by the AWO Board of Directors to three-year terms. Standards Board members may be reappointed for multiple terms. Standards Board members are divided as equally as practicable into three classes, with one class per year subject to appointment/reappointment and approval by the Board of Directors.
Revised July 23, 2020 RCP/TSMS External Audit Extension Requests Due to COVID-19
December 6, 2017 Policy for Non-RCP/ISM Code Safety Management Systems
November 9, 2017 Alignment of RCP Audit Due Dates and Subchapter M Compliance Dates
April 28, 2017 Failure to conduct internal audits; Mid-period audit time period requirement and notification procedures, et al
April 4, 2017 10 percent Vessel Audit(s) RCP Requirement
January 17, 2017 Audit scheduling notifications; auditor qualifications and training equivalency; corrective action plans; major nonconformities; SMS review requirements; certain equipment issues, et al