Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40MARCH 2017 • FOGHORN 29 REGULATORYREPORT as opposed to $44,000. The SMI was established some years after the $25,000 dollar threshold. While the rationale for the number at the time is not known, it was established as four times the reportable casualty number. Following that logic, the new figure for SMI should be $288,000 based on the Coast Guard’s proposal or $300,000 based on our recommendation of $75,000. Our PVA comment to the docket will follow this line of reasoning. It will be shared with the PVA member- ship before the comment closing date of March 24, 2017 so that members can consider it when writing their own comments to docket USCG-2016-0748. New Drugs Proposed for Testing T h e U . S . D e p a r t m e n t o f Transportation is proposing adding four opiod drugs to the testing regime of listed drugs. They were added to the federal program by the Department of Health and Human Services, to be effective October 1, 2017. They are oxycodone, oxymorphone, hydro- codone and hydromorphone. Since the Coast Guard drug testing regu- lations follow the Department of Transportation rules, this would be applicable to our testing program. Comments are due March 24, 2017 on DOT-OST-2016-0189 Inspection Policies We reviewed CG-CVC Policy Letter 16-15 that outlines Risk-Based Decision Making (RBDM) for Small Passenger Vessels (SPV) Annual Inspection Activity. This policy is offered as a guide to Sector Commanders in aiding the allocation of inspection personnel in light of new duties under the towing vessel regulations, increased emphasis for fishing vessels and the ordinary seasonal flux in demand for inspector services. It is based on a proven process that the Coast Guard has used in port safety as an aid in identifying incoming vessels of interest for boarding. There are three tiers of effort with Tier Three being the normally required annual inspection as per the Marine Safety Manual - not the five year in- spection for certification. Tier One and Tier two are adjustments in Coast Guard physical presence during an annual inspection depending on vessel characteristics such as age and material of construction, vessel performance over the year, and ownership matters. Tier One relies heavily on self-reporting of drills and documentation validation via electronic communication. Tier Two may relax some of the onsite activities of the inspectors. All Tier inspections ensure confor- mance with regulations and polices, but take advantage of historical and contemporary information to adjust Coast Guard presence as appropriate to the need. In reality, this has been intuitive in dedicated marine safety units in the past. This updates the practice for Navigating your risks, day and night. As the owner of a passenger vessel you face tough decisions every day, from hiring qualified crew to making sure your vessel is in prime condition. At Aon, we spend day and night thinking about your maritime risks so buying insurance doesn’t have to be another tough decision. We work with you to develop creative approaches and customized solutions that deliver more efficiencies, improved profitability and greater value. For more information, please call 1.800.730.7053 or visit passengervessel.com/member-resources.html#insurance Risk. Reinsurance. Human Resources. Navigating your Aon Risk Solutions Marine CONTINUED ON PAGE 30