Maritime Activity Reports, Inc.
May 3, 2021
A fire aboard the 75-foot dive boat Conception killed all 33 passengers and one of the vessel’s six crew members in September 2019. (Photo: Ventura County Fire Department)
On January 15, 2021, the U.S. Coast Guard issued an Advanced Notice of Proposed Rulemaking (ANPRM) for Safety Management System (SMS) requirements in the domestic passenger vessel industry (Docket No. USCG-2020-0123). This requirement will have the largest implications on the domestic passenger vessel industry since the revisions of 46 CFR Subchapter T & K in the mid-90s. However, the question remains, is it necessary?
Over the last three decades, the effectiveness and need for Safety Management Systems (SMS) have been at the forefront of discussion by operators and regulators in all maritime sectors, both domestically and internationally. The most recent domestic regulatory requirement was introduced in the tugboat and towing vessel industry with Subchapter M in 2016. The development and introduction of Sub M took nearly a decade to be fully introduced as regulation. Today, the greater domestic passenger vessel industry is facing potentially the same fate (outside of those vessels that already comply with safety management system standards found in 33 CFR 96). This type of decision brings up new questions and concerns to owners and operators. Is this a positive change? Is it necessary? Does it correct the “problem”? Many owners and operators are currently deliberating the pros and cons to this impending and critical requirement. Although, there are many areas of a Safety Management System to be discussed, this article will focus on three key areas to support both sides of the argument: (1) External Audit Certification, (2) Defined Management System Processes and (3) Cost.