I have been listening to Coast Guard officials recently to try and get an indication of where the agency is heading on a number of fronts. Budget constraints, resource challenges, and Congressional and regulatory mandates will bring changes. Here are a few things to watch:
Safety management systems. Most U.S. commercial vessels on international voyages and foreign vessels are required to have a safety management system (SMS). Under Subchapter M, towboats will be required to have a towing vessel SMS. Congress has also directed the Coast Guard to develop a regulation that would require some U.S.-flagged passenger vessels to have an SMS. A SMS is good for everyone. As a Streamlined Inspection Program (SIP) participant, I welcome the idea. An SMS allows us to better manage risk and improve safety. The Passenger Vessel Association (PVA) has developed an SMS called Flagship and submitted it to the Coast Guard for approval.
Coast Guard inspections and risk-based decisions. Some decisions by the Coast Guard relating to vessel operations and safety regulations have not always used risk as a starting point. Recently, however, I was pleased to learn that the Coast Guard has developed a comprehensive inspection matrix to be used by inspectors that ranks Subchapter T and K passenger vessels based on a risk analysis. Now, a vessel operator that, based on the matrix, is considered low risk may receive an expedited inspection. This is a positive step forward and will allow both the operator and the Coast Guard to improve efficiency without jeopardizing safety.
Third-party inspections. With the release of Subchapter M, we now know that the Coast Guard will look to third parties to handle the majority of inspections for the towing industry. I am concerned that this will also be the case with passenger vessel inspections. I am against any initiative that would replace Coast Guard inspection for passenger vessels.
So what does all this mean? It signifies a major change in the way the Coast Guard will do business in the future. While change can be intimidating, we should keep an open mind while closely monitoring the situation.
