53 JULY 2026 REGULATORY REPORT LEE BOONE // PVA SENIOR REGULATORY AND PROGRAMS ADVISOR Building Safety In, Not Bolting It On SAFETY MANAGEMENT ALSO BELONGS AT THE KEEL-LAYING M ost operators think of a safety management system (SMS) like PVA’s Flagship SMS as something that governs a vessel once she’s in service: the manuals, the drills, the audits, the discipline that keeps a crew and passengers safe day to day. That’s good practice, full stop. The next level is extending that same discipline upstream, into the shipyard, whether you’re commissioning a new- build, converting a hull, or planning a major refit. Operators have real influ- ence there, and real choices. At an abso- lute minimum, that means feeding les- sons learned from operations into the design of the next boat or refit, rather than starting from a blank sheet or just taking what the shipyard hands you. SMS IS A PHILOSOPHY BEFORE IT’S A DOCUMENT I spent years in U.S. Coast Guard ma- rine inspection before coming to PVA, and in that role I mostly saw the down- stream impacts of design decisions: vessels needing rework because an early choice never accounted for how they’d actually be operated or maintained. Since leaving the Coast Guard, I’ve seen the other side of the table, and it’s eye-opening how much opportunity exists upstream to prevent those same problems before they happen. That experience also taught me the limits of regulatory compliance itself. A Coast Guard inspection tells you a vessel meets the regulations. It doesn’t tell you if the owner got what they paid for. Conflating those two ques- tions is exactly the trap SMS thinking is meant to catch: a vessel can pass every inspection and still fall short of the workmanship or performance the owner actually contracted for. PVA’s Flagship SMS was built to meet the functional requirements of 33 CFR Part 96, and at its core it runs on hazard identification, risk assessment, and a documented feedback loop that turns lessons learned into safer outcomes. That discipline doesn’t care whether a vessel is five years into service or five weeks from delivery: a shipyard project is its own high-stakes operation, with its own hazards and workforce, deserving the same disciplined safety culture. Owners who treat construction over- sight as purely technical and contractu- al including hull scantlings, propulsion specs, and delivery milestones often miss the chance to have that SMS think- ing inform the build itself and can end up with a vessel that meets every regula- tion on paper but was never evaluated against how she’ll actually be operated, maintained, and inspected. Many of you already run this disci- pline daily without calling it PDCA (plan, do, check, act): you plan the schedule, run the pre-departure brief- ing, check equipment against the plan, and act on any problem before getting underway. Do that enough and it be- comes muscle memory. That’s exactly the mindset a shipyard project needs and sometimes doesn’t get, and it asks more than a Coast Guard inspection ever will: not just “will this meet the regulations?” but “will it fit how I actually operate?”, “have risks been engineered out as much as possi- ble?”, and “does this shipyard produce consistent, verifiable results?” WHERE THE TWO WORLDS SHOULD MEET A few practical intersections stand out for operators and shipyards. Design-stage risk assessment: Na- val architects are used to structural and stability analyses. A construc- tion-phase hazard review, walking through embarkation flows, machin- ery access, egress, and crew worksta- tions with the same mindset used in an SMS hazard log, catches problems while they’re still line items on a draw- ing, not retrofits after delivery. Documentation continuity. An SMS lives on recordkeeping. As-built draw- ings, equipment manuals, and com- missioning reports are the bones of a vessel’s eventual SMS documentation, and they need a defined review point, not an assumption that day-one paper- work stays accurate forever. Coordinat- ing early on format saves real duplica- tion by translating shipyard paperwork into operational manuals later. Owner’s rep and crew involvement before delivery. Vessels built with input from an owner’s rep and the
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