The evidence and industry subject matter experts both say ‘yes.’
In its recently released SAFER SEAS DIGEST, Lessons Learned from Marine Accident Investigations (2017), the National Transportation Safety Board (NTSB) reports investigating numerous accidents across all modes of transportation where a properly implemented safety management system (SMS) could have prevented injuries, loss of life, or material damage. That document spans analysis of casualties across the full spectrum of all manners of marine craft, blue water and brown, foreign and domestic.
Different authorities and subject matter experts (SME) differ on how they might explain a SMS, but it all adds up to one thing. But, what is a Safety Management System? A sampling of descriptive language is a good place to start:
An effective SMS has a company safety policy, a risk management program, a safety assurance system, and a safety promotion program. The safety policy is management’s commitment to continually improve safety.
A safety culture refers to the attitudes, beliefs, perceptions, and values that employees share in relation to safety. An effective QMS should support and encourage a “safety culture” to address issues of human error and omissions while continually improving compliance with the applicable regulations.
A safety management system (SMS) is a structured and documented system enabling both shore side and vessel side personnel to effectively manage safety through a proactive culture of continual improvement.
Safety Management Systems in Practice
Safety Management Systems (SMS) have been around a long time, and take their most prominent roots from blue water shipping. Eventually – in places like the towboat industry’s newly regulated Subchapter M rules – those procedures and systems found their way into brown water operations. They are here to stay. Some passenger vessel operators have had their own unique SMS up and running for years.
PVA’s Flagship SMS, for example, is a voluntary safety management system that is tailored for domestic passenger and small passenger vessels. The PVA Flagship SMS was developed in cooperation with the U.S. Coast Guard, and in December 2016, PVA submitted Flagship SMS to Coast Guard Headquarters for acceptance. On June 12, 2017, the Coast Guard's Director of Inspections and Compliance formally recognized PVA's Flagship SMS as an acceptable method for developing and implementing a company specific voluntary SMS. Specifically, the Coast Guard determined that Flagship SMS meets the objectives and functional requirements of a SMS as per 33 Code of Federal Regulations Part 96, Rules for the Safe Operation of Vessels and Safety Management Systems. It provides the framework to develop, implement and maintain the SMS.
That effort is now yielding fruit. Dozens of PVA member companies, representing nearly 200 vessels have requested the framework and tools associated with Flagship SMS. Being a voluntary system, members implementing Flagship or its elements do not need to have third party verification. Much like the approved Alternate Security Program, the PVA Flagship SMS incorporates internal audits to determine the effectiveness of implementation.
Regulators & Operators: a unique safety partnership
Captain Lee Boone is the Chief of the U.S. Coast Guard’s Office of Investigations & Casualty Analysis. Assigned to U.S. Coast Guard Headquarters from 2008 to 2012, he led the U.S. Coast Guard’s Domestic Vessel Compliance Division, responsible for U.S. Flag marine inspection policy. Boone knows a problem when he sees it, and in most cases, what to do about it, when he does.
More than a few domestic passenger vessel operators use SMS in their daily operation. Some do not. That’s because, despite being a heavily regulated sector, SMS is not required for passenger vessels. Boone answers the obvious question by saying, “The Coast Guard encourages the implementation of best practices, like SMS’s, even in the absence of regulation. Successful operators will probably tell you that compliance with safety standards is but one ‘fruit’ of an SMS and healthy safety culture. The beauty of a voluntarily implemented SMS is that everybody knows that you’re doing it ‘because you want to, not because you have to.’ This is a powerful commitment to safety that goes beyond posting ‘safety first’ signs.”
Similarly, Richard Paine, the Regional Director, HSSQE, for Hornblower NYC Ferry and Statue Cruises has his own opinions. Hornblower’s commitment to safety and customer service is something that has been at the heart of the organization since its early years. “I’ve been with Hornblower for over ten years and to see what we have been able to accomplish and provide our crews and the public is something I am very proud to be a part of,” he told MarineNews, adding quickly, “Our management system is an integrated management system that focuses on Quality, Health & Safety, as well as environmental stewardship. Our robust system is certified and audited at the highest level under the ISO 9001, ISO 14001 & ISO 45001/OHSAS 18001 standards.”
Notably, explains Paine, each of Hornblower’s operations – from coast to coast – have some differences in their system, related to types of services offered and their fleet, but overall share the same commitment to continual improvement.
Measuring Success: ROI comes in many forms
Some SMS advocates tout a ‘return on investment’ of an SMS. But, measuring that ROI means different things to different people, and isn’t necessarily a linear metric. Paine explains it from the operator’s standpoint, saying, “A strong SMS will allow operators to monitor and measure equipment usage to determine how best to procure parts inventories, or how to use information from a near-miss incident to prevent an injury. Accidents will still happen, but an effective SMS will minimize exposure by closing holes in an operation that may lead to ‘swiss-cheese’ effect, which means that incidents and injuries don’t happen because of just one hole or error, but instead multiple layers of problems that allow an incident to take place.”
Measuring success can be achieved via data collection and seeing a reduction in injuries, incidents or damages. It can be measured in reductions of insurance premiums, fines or turnover. It can be measured by having zero non-conformities during an audits or no 835’s in a USCG inspection. Paine puts it a different way. “The quantitative data speaks loudly, but I believe the most successful way to measure safety is by watching your people. Do they take drills and training seriously? Do they hold others and more importantly, themselves accountable for working in a safe environment? If the answer is yes, to any of those questions, then that is how you can truly not only measure, but define ‘success.’ Safety is about people. Hornblower’s top priority is to maintain and safety for all of our passengers.”
Separately, the NTSB recently issued the Coast Guard two safety recommendations (M-02-5 and M-12-3) to require all operators of U.S.-flag passenger vessels develop and implement a preventive maintenance program, and a safety management system, respectfully. These recommendations were reiterated as a result of the Island Lady casualty in January 2018. Captain Boone adds, “The U.S. Coast Guard is addressing both of these recommendations through a regulatory project to implement the requirements of Section 610 of the 2010 Coast Guard Authorization Act (Pub. L. 111-281). In the meantime, operators don’t have to wait to be told to implement a SMS … they can implement one voluntarily and be ahead of the game.”
Importantly, the Coast Guard sees and offers benefits to those operators with strong SMS. In fact, by policy signed in April 2017, the US Coast Guard offers reduced scope inspections to small passenger vessels if their SMS is audited by a third-party organization. Even if not audited by a third-party organization, SMS’s should result in higher performing vessels that could also result in reduced scope inspections. Boone reports that, in just a short time since the Coast Guard has offered this program, many small passenger vessels have taken advantage of this opportunity, amounting to 209 reduced scope inspections in 2018. He explains further, “As SMS’s grow in the domestic fleet of small passenger vessels, we expect reduced scope inspections to also grow.”
The PVA Flagship SMS program, as another example, was developed in partnership with the Coast Guard, and exemplifies PVA's commitment to safety. From a US Coast Guard perspective, however, the program is too new, and the numbers are too small to (yet) provide any national-level metrics. Says Boone, “One would expect to see over time, reduced deficiencies during inspections and reduced marine casualties, among other ‘fruit’ from a healthy safety culture.”
Looking (& Planning) Ahead
The SMS has been around a long time. Subchapter M is now heralding the advent of similar changes for the inland towboat sector. And, the passenger vessel sector is cooking up its own version of this emerging safety culture tool. Not everyone is on board with it. USCG Captain Boone thinks that’s about to change, but at the same time, change won’t come easily.
“Quite simply, culture is complex and hard to change. Even with the implementation of the International Safety Management Code (ISM) decades ago, there are still pockets of non-believers, skeptics and those that are simply not familiar with it. Let’s face it, ‘systems thinking’ is a higher-level skill and it takes investment to get there. The US Coast Guard recognized its own SMS issues in the aftermath of the sinking and loss of EL FARO, when the Commandant directed in his Final Action Memo (FAM) for marine inspectors to be better trained in ISM and SMS.”
As a starting point, most stakeholders agree that while certainly it takes leadership commitment to create a healthy safety culture, just as important is the reciprocal engagement of employees, their personal accountability, and their inquiring attitude that sustains it. The Coast Guard’s Chief of Investigations & Casualty Analysis, perhaps, says it best when he insists, “The fear of getting bitten by the U.S. Coast Guard is NOT why you should have a SMS. Fear usually gets you compliance at best, concealment at worst; falling far short of the target for which we all should be aiming … For all its merits, however, we should all keep our eyes open for the pervasive by-product called compliance culture, wherein safety is static, only achieves the minimum, and exists mostly to satisfy regulators; all of which leads to overconfidence in our system, which can be dangerous.”
For all that, however, improved compliance with safety standards can sometimes dominate what the Coast Guard sees and measures. To truly assess whether SMS is doing what was intended, operators should assess their own safety culture regularly. Boone, of course, has his ideas on how that should evolve. “I recommend using the Bureau of Safety and Environmental Enforcement’s (BSEE) “Nine characteristics of a robust safety culture” as a benchmark to assess how you’re doing: www.bsee.gov/newsroom/latest-news/statements-and-releases/press-releases/bsee-announces-final-safety-culture. Outside help may be needed to get started, but vessel operators should be willing to use whatever works including climate surveys and interviews to get the truth.”
Whatever your route to compliance and safe operations, don’t wait until it’s too late to find out you’ve got a safety culture problem.
This article first appeared in the January print edition of MarineNews magazine.
As safety management systems (SMS) on board vessels evolve, the vessel’s master still holds ultimate authority. Subchapter M is finally underway. A starring role in this new CFR is a safety management system onboard all vessels. While this system dictates how the vessel is to be operated and under what
more urgently so, as the proverbial clock is now ticking for real. The deadline for meeting the USCG requirement for having a safety management system (SMS) in place and completed vessel surveys and external audits, may be July 20, 2018, but it’s less a date you should be looking at meeting, as it is the
An extra T in TSMS, nowhere left to hide from systems documentation, and an emphasis on continuous improvement. Back in January of this year, the United States Coast Guard (USCG) predicted Subchapter M would be released in spring 2016. I put my money on June 20, that being the very last day of spring
Motor AB and Oresundsvarvet AB. G o t a v e r k e n Motor produces main and auxiliary diesel engines of Gotaverken, E r i k s b e r g and B&W design. SMS will also be responsible for marketing of their new Fuel Savings Program of engine modifications which offer substantial reductions in specific fuel
code, it is the responsibility of the company—the owner or any other organization that has assumed responsibility for operation of a ship—to establish an SMS for its vessels. According to section 1.2.2 of the code, the SMS should “assess all identified risks to its ships, personnel and the environment and
M, some of which are members of the AWO, which mandates that all members within a year of joining, be certified on its own U.S. Coast Guard-approved SMS, the Responsible Carrier Program (RCP). While they wait for SubM to wend its way through the regulatory process, operators can get SMS-certified by
the safety of a vessel’s passengers and crew. One of the most effective ways to manage this process is through implementation of a safety management system (SMS). When risks are effectively identified and managed through SMS practices, not only will operations improve, so will outcomes, even when there is an
themselves until 2022 to issue Certificates of Inspection (COIs) to all those vessels. Myth 2: If a company currently has a safety management system (SMS) it does not have to go with the Third Party Towing Safety Management System (TSMS) option. The biggest decision for towing vessel operators will be
to come. Local Partnerships, Strategies ClassNK began planning for the new regulations with inland operators in 2009. The acquisition of Maine-based SMSLLC in March is a continuation of that effort. Since 1996, Safety Management Systems, LLC (SMSLLC) has provided consulting services to maritime, transportatio
via MMS, email or by FTP to a browser or to a customized website. Pictures can be taken on demand when the camera is sent an activation trigger/request by SMS, telephone, email or web browser, in addition to regular pictures take on a timed schedule, or when the optional motion-activated PIR sensor is triggered
annually carry out more than 1,000 surveys and audits in North America. ClassNK just classed its U.S. flag ship. Two recent domestic acquisitions – SMS Consulting and Helm Operations – augment ClassNK’s already impressive portfolio. Helm is a leading provider of manning, maintenance, dispatch, and HSQE
COLUMN SAFETY MANAGEMENT SYSTEMS third-party registration and oversight, typically provided and implementing the SMS can be quite modest, or as by IACS classi? cation societies and registering bodies. This much as $50,000 or more. requires annual of? ce audits and vessel audits. Based on Unless you are
COLUMN SAFETY MANAGEMENT SYSTEMS Dollars & Sense: Making a Pro? t with a Safety Management System (SMS). By Richard J. Paine, Jr. Organizations in the maritime in- held the position that the cost of SMS will eclipse the ultimate dustry act no differently than any other bene
11 INSIGHTS 14 Sean Fernstrum President, R.W. Fernstrum & Company SAFETY 26 Dollars & Sense: Making a Pro? t with a Safety Management System (SMS). By Richard J. Paine, Jr. WORKBOAT COMMUNICATIONS 30 ISO: Affordable & Reliable Workboat Comms Commercial workboats can bene? t from greater
success stories with this full funding, with subchapter M and the advent of software-based as we have been receiving the last several fscal years, but we SMS on the inland waters, hasn’t it? should also consider a similar cost-share change ahead for all The Port of Pittsburgh Commission was unable to f- the
must be laid out in the safety man- standard in cyber security. possibility of ubiquitous access, which fective means of ensuring that per- agement system (SMS) of the vessel and equates to more possible entry points sons seeking access to an IT system the company. Failure to do so constitutes Summary for
reason cited for increased train- ing was new equipment being used and systems be- ing installed (such as LNG and BRM training, or the installation of SMS – which comes with new proce- dures). Meanwhile, for maritime education and training institutions, the increased budget comes from new training opportuniti
business uisite Safety Management The increasing sizes of deep tug to help maneuver to berth. Crowley because there are fewer ship calls given System (SMS), working sea vessels are dictating the is active all along the West Coast (which with ABS. Rick Iolucci, need for highly maneu- has seen calls
funding. a not-for-pro? t basis – and are thus not compelled to satisfy the expectations of outside shareholders – they are alive to the S M A , , SMSUB RRIVES AND WITH IT need to maintain equity among all members of the club, and As the domestic inland sector evolves in the subchapter tend to avoid
in the mid-1990’s was precipitated by many things. Today, these very same vessels have been put under the subchapter M regime, and most are adapting SMS as a culture in the process. Moreover, and without a doubt, the environmental record of this sector has improved 99% since the 1970’s. As all of
ATB REVIEW better speed and endurance in rougher operated with very much of a blue a safe operation. The only way to be seas (than, as compared to a standard water SMS system, well prior to the pro
GSM services for passen- try barrier for shipping companies look- sea demand modern essentials such as provide its quality Sealink services on ger voice, SMS and data connectivity: ing to implement new communications access to the Internet – there needs to the latter’s ? eet of four cruise vessels, “The
Guard is Folan wound up his Day One remarks wards the ? nish line, with almost 75% of it done. One member of the audience NOT why you should have a SMS. Fear by reassuring those in attendance that of all operators choosing the TSMS op- put it best when he deadpanned (tongue usually gets you compliance
THE SHIPYARDS • Repair & Conversion, New Construction, Investment Photos: Left UK-based ship repairer the SMS Group, which focuses on mechanical engineering, started 2019 focused on several major re? t wins. Photo: SMS Group The future USS Thomas Hudner (DDG 116) returns after completing acceptance
companies go through internal and external audits of of the world. For workboat operators in domestic waters, their marine safety management systems (SMS). that’s especially important in light of the new subchapter Designed for work boats and barges, the Rescue Davit M rules that now spec
SAFETY Credit: Hornblower Looking (& Planning) Ahead Coast Guard is NOT why you should have a SMS. Fear The SMS has been around a long time. Subchapter M is usually gets you compliance at best, concealment at worst; now heralding the advent of similar changes for the inland falling far short of the
SAFETY The fear of getting bitten by the U.S. Coast Guard is NOT why you should have a SMS. Fear usually gets you compliance at best, con- cealment at worst; falling far short of the target for which we all should be aiming … For all its merits, however, we should all keep our eyes open for the pervasive
well. Indeed, the passenger vessel sector is one of the most tightly regulated of any on this side of the pond. The advent of Safety Management Systems (SMS), something championed by both the Coast Guard and the Passenger Vessel Association (PVA), therefore is arguably coming at just the right time. At
2019 Inland River Cruising Busting Out: new routes, new vessels, new players Ferries Forward Tampa Bay: take two Training & Education Safety, Simulation, SMS & Survey
business real-time messaging format, instead of into tasks, who is assigned to what and helping their team get more done. Key via a separate email or SMS text sys- con? rmation that it has been completed. points include: tem. It delivers the ability for everyone • Real-Time Job Updates: As work • Of
device, including Android and iOS devices. SkyRouter’s key attributes include real-time tracking and mapping worldwide 24/7, global two-way email and SMS mes- saging, dynamic alerts, automatic report generation, and customizable geofencing. With SkyRouter as the command center, a comprehensive range
, the ship’s log, As previously stated, the current ver- lows individual states and Native Ameri- In addition, the VGP program has pa- in existing ISM/SMS plans or other ad- sion of the VGP program expires in De- can tribes to establish additional water perwork aspects that will require special ditional
nearly $10M ditional dollars if they have not been living and breathing due to the closures at Lock 52. Reference the most recent the AWO RCP or another SMS. joint study between the National Waterways Foundation Inland operators depend heavily on the maintenance and the U. S. Maritime Administration
nel assigned to provide captains with ef- independent of your organization or with using this technology are not going Merely having an SMS is not suf? cient fective guidance and procedures. Robust class society, of your entire safety man- to go away. Unfortunately that is the risk to prevent catastroph
of the sponsibility for operation of a ship—to respond to them.” not in compliance. It is good that the MARINE ELECTRIC in 1983. Several establish an SMS for its vessels. Accord- Also; risks that a cyber event poses to mari- statements and ? ndings in the NTSB Re- ing to section 1.2.2 of the code, the