b' Any regulatory framework should allow for a scalable SMSTo view the pre-recorded Safety Management since the vast majority of the domestic passenger vessel fleet isSystem ANPRM webinar from April 6,considered small businesses and many have limited shoreside management. CLICK HERE and enter passcode h4.r$&RH Provide a reasonable timeframe for companies to come into compliance.Both SMS and SIP require significant up-front dedication of time and resources. A five-year COI cycle is not unreasonable. In addition to the content and questions in the ANPRM, the virtual seminar went over the elements of a SMS, the history of SMS for U.S. These core recommendations provide a broad foundation for howflag passenger vessels, and the development of PVAs Flagship SMS.PVA will respond to the ANPRM and subsequent proposed rules. The working group also drafted responses to the ANPRMs 22The seminar concluded with a roll out of a template PVA members questions.These responses will be refined by the working groupcan use in providing comments to the docket.The template contains prior to the comment deadline. the strategic recommendations to the Coast Guard and allows for company specific input. The template was provided to all those who COMMENT PERIOD EXTENSION AND MOTIVATINGregistered following the webinar and then to all members in the April THE MEMBERSHIP 9, 2021 PVA Member Update.In early March, PVA submitted a letter to the docket requesting a 45-day extension to the comment period citing the ongoing focus on theIt is critically important that PVA members have their individual pandemic as vessels return to service. The Coast Guard extended thevoices heard.By telling the Coast Guard the benefits and challenges comment period to June 1, 2021 as published in the April 1, 2021of implementing a SMS in their own words, as it relates to their Federal Register.company,memberscandirectlyshapethecontentandscopeof a rulemaking that could have the most significant impact on the On April 6, 2021, PVA hosted a virtual seminar for members onindustry in over 20 years.what was in the ANPRM and encouraging members to comment to the docket.Over 80 members registered, and the seminar wasPVA Staff is ready to assist with any questions members may have.recorded for those who could not attend initially.2021_GH-Interferry_Foghorn.pdf 9 3/4/21 2:36 PMCMYCMMYCY ALL OTHER FERRIESCMYK ARE MISSING ONE VERY IMPORTANT PART.OUR NAME. gladding-hearn.comGLADDING-HEARNSHIPBUILDINGDuclos CorporationAPRIL 2021 29 SAFETY MATTERS'