In the wake of the Conception tragedy and NTSB recommendations the CG is seeking input:
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An SMS needs some kind of enforcement regime to be even slightly effective. I realize that advocating SMS audits isn’t going to make me popular here, but if the level of scrutiny is set at zero, the level of compliance follows suit.
Since 2009, the somewhat unregulated class of passenger craft in Norway (<24m/12pax) has been subject to mandatory SMS. However, the law only states that an SMS must be implemented, not what it should encompass, and there is no kind of follow-up from the authorities. In my experience, the operators don’t even know what it is, and when I explain, they respond along the lines of: “Oh that bullshit? I just copied something off the internet.”
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There is also a self-fulfilling prophecy thing going on. Start with a belief that it’s all bullshit when asked to create a SMS mariners and managers will create a system that is in fact all bullshit.
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The IMO adopted an ISM Code >25 years ago to the effect that all ships trading internationally should have an international safety management (ISM) system (in writing) describing all work aboard, which is the responsibility of the ship owner at shore. It is part of SOLAS. The ISM system must be certified. It is quite easy. All crew members have a job description what they do in the system aboard and if they are not happy about it, they can complain about it all the way to the ship owner on shore. The Master of the ship must follow the ISM and cannot decide anything himself against the ISM system aboard. Of course national shipping is different. Any country can decide its own local rules.
All mega container ships today have an ISM system. I assume the watch keeping officer on the bridge must look out and slow down or change course to avoid impacting a big wave at night in severe weather to avoid suddenly losing 1000+ TEUs overboard, when the others are asleep.
O, that way madness lies ; - Shakespeare
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Or routines and procedures aboard! If in doubt, call the owner ashore!
rev 1.0
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Typical bureaucratic bullshit.
SMS for under-crewed, poorly inspected, small vessels is overly-complicated bullshit that will be merely be pencil whipped and ignored. It has virtually no real value.
It does shift more blame from the cheapskate owner to the powerless Captain. Owners will love it. Captains will think: this sucks, but it’s unlikely anything will ever happen to me.
If anyone is actually interested in doing something to improve small vessel safety, there are three effective places to start: (1) better design and construction standards; (2) much more competent and thorough USCG inspections; and most importantly, (3) MORE CREW.
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Granting licenses to guys whose totality of time at sea consists of making the same short trip on the same boat year after year is part of the problem. It’s the nature of some of these small operators who promote their deckhands to the wheelhouse. They repeat the same procedures and habits, both good and bad, their predecessors teach them. I don’t see how you can change that. The narrow bandwith they operate in is not of much interest to seasoned mariners.
The obvious answer to that is more mandatory educational requirements, more STCW, and more overcomplicated Euroification of everything.
Or to the contrary, maybe we should deregulate by expanding the Uninspected “6-packs” to “12-packs” or “24 packs.”
We have something like 50,000 deaths a year in car accidents, hundreds in sports accidents, and probably only about 100 a year in boating accidents. Maybe our fixation on small boat accidents is misplaced.
I don’t think so. Most of us on this forum boarding a tour boat would automatically note egress routes and know how to react to a fire or flooding incident without conscious thought. The average landlubber is in an unfamiliar environment with no such awareness. In an emergency, they are lost without assistance from the crew.
Do we make the typical two hour boat tour $100 per head, $500 for a couple and three kids, so it’s safer, on a newer, non-fiberglass, boat with more crew, but so few people can afford it?
Or do we stay with $35 boat rides that most can afford, but accept that it will be less safe?
Compared to other common risks, like riding a motorcycle, commercial tour boating is extremely safe.
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Yes, weighing the cost benefit with the level of safety is part of the equation.
It’s about time, since Congress directed the Coast Guard to develop regulations for this in the 2010 Coast Guard Authorization Act. Though all things considered, an 11 year turnaround is still fast on the government scale. I would guess that it could be implemented in a similar way to the rollout of ISPS/MTSA for small passenger vessels, where a company could develop their own Vessel Security Plan or choose to use the PVA’s Alternative Security Plan. I think many of the small companies would rather customize some sort of Alternative SMS for their operations rather than build out their own SMS from scratch.
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If the owners of the SS Minnow had a SMS in place we would have never gotten Gilligan’s Island.
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I saw on the news that Mary Ann died recently. She made it through the shipwreck and lived another 50 years.
The SS MINNOW’s SMS was obviously good enough.
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A formal SMS is really nothing more than what a well run vessel has been doing all along.
For us in the end it amounted to changing the IAW (In Accordance With) log entries from a CFR number to a procedure number. For all the hair pulling and teeth gnashing it’s actually easier.
There are a lot more cars on the roads than small boats on the water.
If you only look at those small boats that offer tours for payment, or more specifically, those professional tours that offer overnight stay aboard small boats you are looking at far fewer boats. (And accidents??)
BTW; I don’t think SMS on all professional tour boats in US waters would make all that much difference, especially if it is not followed up with mandatory training and regular rigid inspections to verify compliance. A few more lists to pencil whip is not going to make ANY difference IMHO.
I have seen too many so called SMS Manuals that is obviously just copied from other boats, or even “stolen” from the net. Only the name of the boat is changed
Sometime I have found SMS Manuals that describe equipment that is not found on board, or refering to tasks that the boat could not possibly perform.
Admittedly this has not been on US boats, but on small tugs and OSVs operating in S.E.Asia.
I think a formal SMS has potential to be useful even for small boat operators. I’ve worked for a company with an extremely robust SMS, and I’ve worked for a huge corporation with an embarrassingly thin one. The thin one would have been more useful if it didn’t exist at all.
But to be able to simply point to a policy document when a question arrises is quite helpful. Not just from a practical standpoint but also from a management standpoint. It’s easy enough to tell the 3rd “look, we can certainly submit a suggested improvement to the office, but right now this is our official policy so you will follow it.” Sure they can be written with grey areas, and I bet establishing an SMS from scratch will take some time, but when done correctly it is simple to update annually and track revisions and reasons.
As for enforcement, we all hate audits. But a one- or two-day annual or semi-annual audit is really all it really took to force us to read the documents every once in a while. The key is making sure the “auditor” is consistent across the fleet. It gets a little hairy in larger operations when multiple auditors have their own interpretations. But that really shouldn’t be an issue for a small operator. And a small operator should necessarily have significantly fewer policies anyway.
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I boarded a skiff in Costa Rica that was going to run offshore about two miles from the beach and immediately requested a lifejacket for everyone onboard. They had to go by a “buddy’s” boat to get enough for all of us.
Mariners think about this stuff because we know how quickly it can all go south.