b'REGULATORY REPORT:REGULATORY PVA Meets SMSPETER LAURIDSEN // PVA REGULATORY AFFAIRS CONSULTANTS afety Management System (SMS) is theevolution but I will not attempt to name therequirements.WhereSIPwasimplemented, current issue of interest for the membersdozens of people who contributed along thetherewasmutualrespect,understandingof of PVA and the passenger vessel industryway.Withouttheireff ortswewouldbeillroles, and trust.ingeneral.OnJanuary15,2021,theU.S.preparedforthiscomingregulatorychange. CoastGuardpublishedanadvancenoticeNeedlesstosay,theybroughttheirtalents,TherightsizingoftheCoastGuardwas ofproposedrulemaking(ANPRM)seekingexperience, enthusiasm, and career roles to thefollowed by 9/11 and the draw down of marine assistance in formulating regulations requiringtable. inspection personnel for manning the Coast some passenger-carrying vessels to have a SMS. Guard activities complying with the Maritime In 1996, PVA and Coast Guard entered into aTransportation Security Act.PVA is preparing to respond to this invitationchartered partnership under the Coast Guards of helping the Coast Guard begin to defi ne aPrevention Through People program. At theThis was a period that led to speculation that the SMSthatwillapplytodomesticpassenger- time, we called this agreement the PartnershipCoast Guard would seek to fi nd a way to carry carryingvessels.ImplementingsafetyAction Team. The goal was to address issues ofout its commercial vessel inspection program management systems for the passenger vesselmutual concern and where possible throughthrough delegation to other entities. Congress industryhasthepotentialtosignifi cantlyjointworkgroupsdeveloprecommendedalsowasconcernedenoughaboutdeclining alterthegovernment/industryinterface.Insolutions.Oneoftheearlyeff ortswastoCoast Guard resources and performance that ourcommentswewillseektoensurethataddress marine inspection services in a rightit held a hearing on transferring the marine this process meets the goals set by Congresssizing the Coast Guard era that was depletinginspection program back to the Department whilepreservingthefamiliarregulatedandmarine inspection personnel. The product wasof Transportation (DOT). The Coast Guard regulator partnering and working toward ourtheStreamlinedInspectionProgram(SIP).had left the DOT just fi ve short years before at common goal of safety of life and property inThe goal here was to have vessel personnel onthe creation of the Department of Homeland the maritime environment.a routine basis check the vessel for regulatorySecurity.compliance so that a vessel was continually in PVAhas,inmanyways,beenpreparingcompliance with its Certifi cate of inspection.In a parallel path starting in 1997, the Coast forthiseventintentionallyandsometimesIn return, the Coast Guard would and couldGuardpublishedregulationsforSMSthat unintentionallyforovertwodecades.Iwillaccept the crews actions as fulfi llment of manycoveredourU.S.fl passengervesselsinag point to events and conditions that made thisofthetime-consumingannualinspectioninternationalservice.Therewereandaresome one hundred or so Subchapter T vessels thathaveSMSintheircompliancewith theprovisionsofInternationalMaritime Organizationconventions.Theinspection andauditingrequirementsoftheirSMSis under Coast Guard supervision along with the regular Certifi cate of Inspection events. TheseparallelpathscametogetherasPVA begantothinkdefensivelyabouthowto survive if the Coast Guard lost or delegated its marine inspection program. Could a SMS aid PVA in maintaining the familiar body of regulations under a scheme that was essentially supervised self-inspection? Could we preserve whatweknewandavoidbeginningagain in a new department or in the international drivenclassifi cationsocietyasagentforthe government scenario?The idea of Flagship, a voluntary SMS, was seen as a way to prepare for controlling our REGULATORY REPORT 30 FOGHORN'