b'4. When a passenger vessel operator has a multi- 12. How many new or additional employees16.ShouldtheCoastGuard-requiredSMS vessel fleet, how is an SMS best implementedwould be needed to implement an SMS? Whatbe subject solely to independent third-party across the fleet? would be the potential position titles, roles,audits?Ifso,howfrequentlyshouldaudits responsibilities, and training requirements oftake place?5.ShouldtheCoastGuardconsiderthethese employees? How many hours of work ISMCode(IMOResolutionA.741(18)aswould be associated with each position? What17. What training or knowledge requirements amended), sections of 46 CFR parts 136144additional costs would companies incur relatedare appropriate for crewmembers on passenger (SubchapterM),InternationalOrganizationto these employees? In your response, pleasevessels with an SMS?for Standardization 9001:2015, or any otherindicate how company size or fleet size affects process-based safety management alternativesthe estimate. 18. If you are a small business, what economic orequivalencies?Ifso,whatalternativesimpact would an SMS requirement have on orequivalenciesshouldtheCoastGuard13.Ifyouareanoperatorthathaschosenyou, your business, or your organization? In consider? Do sections of these process-basednot to implement an SMS, what are reasonsyourcomments,pleaseexplainhowandto safetymanagementstandardsapplytothenot to use an SMS? What type of operationswhat degree the requirement would have an passenger vessel industry more or less than tomaynotbenefitfromanSMS,andwhy?economicimpact.Also,pleaseexplainwhy other industries? Please provide specific details,Would the implementation of an SMS havethese requirements affect your small business if possible. anydetrimentaleffectsonpassengervesseldifferently than it might affect a larger business.operations? In addition to possibly needing to 6. In lieu of an SMS, should 46 CFR parts 78,hire new employees, what other costs would19.Howwouldthecostsandbenefitsof 121, 122, 184, or 185 be expanded to coverbe incurred by an operator implementing anexpandingotherexistingregulations,as items commonly found in an SMS, such as aSMS? detailed in question 4, differ from the costs and preventative maintenance program, emergencybenefits of requiring SMSs for all passenger preparednessandresponseprocedures,and14. How long do you estimate it would take tovessels?procedures for key shipboard operations? develop and fully implement an SMS in your organization?WouldtheSMSbedeveloped20. What costs and benefits are associated with 7. If a comprehensive SMS is required, are therebysomeonewithinyourorganizationorinternalorthird-partyauditsofSMSs?To more prescriptive USCG regulations currentlywould outside experts be contracted? In yourwhat extent is there already capacity to audit intheCFRthatcouldberemovedbecauseresponse, please indicate how company size orsystems through industry associations? Where theSMSwouldserveasimilarfunctioninfleet size affects the estimate. possible,pleasebreakdownthecostsand promoting safety? If so, which regulations? benefits associated into the different elements 15.ShouldtheCoastGuardrequireaof SMS audits.8.IfacomprehensiveSMSisnotnecessarycertificationprocess,anauditprocess,or orjustified,whataspectsofanSMSwouldboth? If so, why, and who should certify or21. What incentives could the Coast Guard beappropriatetoincludeinthisregulatoryaudit the SMS, how often, and what shouldprovide passenger vessel companies to adopt framework?Whywouldyourecommendtheinspectionorauditentail?Shouldthean SMS? And what is the most appropriate includingtheseaspectsinthisregulatorycertification or audit requirement be limited tomeansormethodfortheCoastGuardto framework and not others? certain vessels? If not, why not? incentivize these companies to adopt an SMS?9.Whichindustrystandards,suchtheISM Code, should be incorporated by reference? To what extent should an industry standard SMS, such as the PVAs Flagship SMS, be recognized?10. What guidance should the Coast Guard make available to the passenger vessel industry inordertohelpownersandoperators implement an SMS? Would such guidance save costs or time implementing an SMS?11. If you are a vessel owner or operator with a Safety Management Certificate issued underMaintenancethe ISM Code, or if you employ another type of SMS (for example, PVA Flagship), have youSimplified!seenimprovementsinsafetyandoperation from implementing the SMS? Please provide any supporting data, if available. 17978-562-5211WheelHouseTech.comFEB 2021 31 SAFETY MATTERS'