Proceedings magazine is a communication tool for the Coast Guard's Marine Safety & Security Council. Each quarterly magazine focuses on a specific theme of interest to the marine industry.
Issue link: http://uscgproceedings.epubxp.com/i/665311
33 Spring 2016 Proceedings www.uscg.mil/proceedings beta test companies work with the code and guidelines, the more refned the system will become. Further, while accident reporting is (arguably) clear in regulations, tracking and acting upon incidents that aren't defned as casualties but could still impact personnel and property is a work in progress. Another area not yet fully developed is the role of internal and external audits of com- pany operations. There are a number of members within the association that have already implemented a safety management system. Some have done so due to regulatory mandates associated with international operations, while others have found that a proactive system of continuous improvement leads to reduced accidents, greater vessel availability, and more widespread crew commitment to operate in a safe and envi- ronmentally sound manner. The level of interest in Flagship within PVA has dramatically increased as a result of having these experienced members share their safety management system experience with other members. Moving Forward As more PVA members embrace Flagship and safety man- agement systems in general, Coast Guard engagement, com- mitment, and approval will be key to our success. We have already experienced their engagement through the quality Code compliance for small passenger vessels cer- tifcated under 46 Code of Federal Regulations, Subchapter T. There are, of course, an entire group of U.S. pas- senger vessels that are not subject to SOLAS; therefore, they are not required to comply with the ISM Code. The Coast Guard has long sought to encourage voluntary compliance with the safety management system requirements of the ISM Code to the maximum extent possible on these domestic vessels. Most recently, Section 610 of the Coast Guard Authorization Act of 2010 amended Section 3202 of Title 46 U.S. Code to include passenger and small passenger vessels with other vessels requir- ing a safety management system. However, there were no thresholds (passenger capacity, inspec- tion subchapter, etc.) specifed in the amended law. That's where the PVA Flagship initiative comes into play. Flagship Flagship is a safety management system appro- priate and scalable for the domestic passenger vessel industry. While it does provide structure, it's also designed to be fexible enough to readily capture typical passenger vessel procedures and processes, document compliance with all applicable laws and regulations, iden- tify nonconformities for corrective action and continuous improvement, and establish a program of audits. In the name of enhancing regulatory compliance and safety on domestic passenger vessels, Flagship's goals are to pro- vide PVA members with a program template, providing guidance to implement programs in a way that the Coast Guard will recognize and accept. To develop Flagship, a chartered working group of PVA members and Coast Guard participants harvested best practices by reviewing existing public and private sector practices and processes for maintenance, management, and internal reporting systems. The working group also took the existing ISM Code template that the Coast Guard developed for small passenger vessels on international voyages and modifed it to meet domestic requirements. Observations So Far Ten Passenger Vessel Association member companies are currently beta testing the draft Flagship code and guidelines the PVA/Coast Guard working group developed. A safety management system is iterative by design, and the more the Who is This Elephant, and Why is He in the Room? While voluntary compliance is a goal — and we should strive for it and show the public that Passenger Vessel Association (PVA) members take safety and environmental stewardship seriously — there's no denying that federal requirements are looming on the horizon. The 2010 Coast Guard Authorization Act called for the Coast Guard to develop regulations requiring safety management systems on passenger vessels. That process is underway, but regulations take time. While the Coast Guard doesn't need to reinvent the wheel regarding the elements of a safety management system, what it will need is the industry's input. Through the notice and comment process of rulemaking, the industry can suggest how best to implement safety management systems in an industry with an enviable safety record. If the PVA can show a model path to compliance through our voluntary safety management system, "Flagship," without overburdening our members, then we stand a good chance of infuencing the regulatory outcome for the beneft of all.