b'PVA has an alternativegulf between the primary impact ofour safety and regulatory efforts on security program forMTSAselementsandthepracticaldevelopingavoluntarysafetyplan requirementsforourindustry.Thecalled Flagship that would serve our its member in goodsolution was adoption of regulationsbroadrangeofmembersoperations standing. The PVAthatpermittedindustryassociationsfrom the smallest to the largest and for vessels and/or faculties to developcould be recognized as an alternative plan, called Flagship,alternativesecurityprograms(ASPs)to the forthcoming SMS regulations. is renewed every fivethat accommodated industry uniqueThe Coast Guard has recognized our years to keep pace withfeatures while providing a level of safe- Flagship product as covering the ele-ty provided by the regulations. PVAments of an SMS. changes in identifiedhasanalternativesecurityprogram problem areas. for its member in good standing. TheThe challenge we face is responding PVA plan is renewed every five yearsto the forthcoming SMS NPRM with to keep pace with changes in identi- comments on what we see as pluses and We know that SMS is a given fromfied problem areas. potential problems of implementation the(CGACT).Wealsoknowthatof the SMS and that it will recognize Congress,theNationalTransporta- Intheadvancednoticeofproposedalternative plans such as Flagship. The tion Safety Board (NTSB), the CoastrulemakingforSMSPVAproposedfoundation of an alternative program Guard, and even some of our memberadoption of our SMS like Flagship. Asis equivalency so we will need to see companies have pointed to the caus- a result of our early awareness of SMSthat our plan can be seen as equivalent esandconsequencesofunwantedelements we have, since 2010, focusedto the final regulations. events that should have been avoided throughtheimplementationofan effective SMS.Given the inevitability of the forth-coming SMS regulation, the Passen-ger Vessel Association, soon after the CGACT adoption, began researching theorigin,elements,andpotential difficulties associated with SMS im-plementationforourmembership. We saw a process that was developed andimplementedininternational trade,bluewaterapplicationswith much of the mechanics of sustenance and validation overseen by classifica-tion societies. We realized we were facing a challenge similar to the adoption of Maritime TransportationSafetyAct(MTSA) wherethebasicelementsofcompli-ancewereproblematicfordomestic vesseladoption.Weworkedtoen-suretheregulationsrecognizedthe 29 JUNE 2023'