b'reduced schedules due to a lack of employees. TheSafetyManagementSystem(SMS).SeveralareseekingenrollmentinSIPorFlagship lack of spare parts and inability to get certain foodmembers have contacted PVA staffover theSMStogetthemoverthefi linewithnish itemshascausedlast-minutechangesinvesselpast year to discuss issues they are having withimplementation. Once a few companies have operations. While not something they can control,local Coast Guard inspectors over hull plateimplemented more will likely follow, which seniorCoastGuardleadershipappreciatedtherepair. Pitting repair seems to be a growing issueis a safety goal of both the Coast Guard and PVA perspective on operational challenges.and the Coast Guard, in a growing numberPVA. RADM Mauger stated that We will not of regions, is hesitant to allow repairs such asbe a barrier to implementation.REGULATORY ANDclad welding. PVA Vice President Bob Bijur COMPLIANCE UPDATES displayed a piece of plate cut from his vesselAnewopportunityforcooperationwas PVA leadership was briefed about new regulationsas required by the Coast Guard even thoughidentifi edregardingtheAdministrations coming out of the Coast Guard that implementthelocalinspectorcouldnotclearlystatedesire for heat regulations to protect workers. thelegislationpassedbyCongressinthewhy the plate was bad. PVA recommendedTheOccupationalSafetyandHealth aftermath of the M/V Conception fi re. There willand the Coast Guard accepted the formationAdministration(OSHA)hastheleadand be a new defi nition ofcovered small passengerof a working group to look at the tools usedPVA Legislative Director Ed Welch provided vessel,focusingonvesselswithovernightbytheCoastGuardindetermininghullthe Coast Guard with information on how accommodations, as well as vessels operating onplate strength. theCoastGuardandOSHAcooperate. Coastwise and Oceans routes. These covered smallPVAexpresseditsdesiretorelyonthe passenger vessels will have additional regulatoryRegarding the use of SIP and Flagship SMS,CoastGuardforenforcementofanycrew requirementsintheareasoffi safety,fi thePVASafetyandSecurityCommitteesafety requirements.re re detection, egress, and crew training. The CoasthadaskedPVAstaff toraisetheissueof Guard did not provide a timeline for publication,localCoastGuardhesitationtoassistPVARECAPbut they did indicate it will likely be in the formmembers in enrolling in SIP or Flagship SMS.PVA staffand members will be working with ofanInterimFinalRule(IFR).HavingthePVA staffexplained to the Coast Guard thatthe Coast Guard on three areas of concern regulations published as an IFR means portions ofsome members have been discouraged frombetween now and the spring meeting: cyber it will be enforceable upon publication while theusing the alternative compliance options duesecurity,hullplateassessments,andSIP/Coast Guard will seek comments in areas of thetotheirhighupfrontresourceneeds.PVASMS enrollment. If you would like to assist regulations not ready for implementation. requestedandtheCoastGuardagreedtoPVAintheseareas,pleasecontactmeat work with three or four PVA member firstname.lastname@example.org. The Coast Guard reported on the status of the tiered inspection program. In-service inspections are going well for Tier I vessels. PVA participants in the QP validated the Coast Guards statement regardingin-serviceinspections.MemberhaveINNOVATIVE. indicatedthattheinspectionsconductedwith passengersonboardandpriortodeparture havebeenstraightforwardandunremarkable.UNIQUE.ALL AMERICAN MARINEAspreviouslyreportedinFOGHORN, approximately10percentofthedomestic passengervesselfl isconsideredTierI.ThePROVEN. eet CoastGuardalsoreportedthatTierIvessels make up 40 percent of detentions and 18 percent ofno-sailrequirementssofarthisyear,which isdisproportionatelyhigh.Defi cienciesinthe materielconditionofvesselsandequipment isleadingtheCoastGuardtowardissuingnding detentions when fi that a company is not managing the safety of the vessel eff ectively. PVA askedforafullreportof2021statisticsatthe spring 2022 QP meeting. The Coast Guard will be running their risk model in December to establish tiers for the 2022 operating season. Vessel owners going on to the Tier I list or coming offthe list can expect notifi cation from the Coast Guard in January 2022.PVA CONCERNSIn addition to cyber security, PVA raised issues of hull evaluation and enrollment in the Streamlined InspectionProgram(SIP)andPVAsFlagshipALLAMERICANMARINE.comBellingham, WA | 360.647.7602Pictured: Spirit of Matushka - A 150 Passenger, hydrofoil-assisted catamaran, custom built for Major Marine ToursNOVEMBER 2021 31 SAFETY MATTERS'