A safety management system (SMS) is a formal, documented system for owners and operators to ensure that rules and procedures related to safe operations are in place. A properly implemented SMS is an effective tool for safety oversight; it is designed to reduce human error, create a culture of safety at all organization levels, and reduce the risk of maritime casualties. Yet many operators either do not have one in place or have an ineffective one.
The goal of an SMS is to provide safe working practices for ship operation; continuously assess and identify risks to the vessel, personnel and the environment; and establish appropriate safeguards to those risks. Regardless of the size of the company, an SMS ensures standardized and unambiguous procedures for each crewmember during both routine and emergency operations—an SMS accounts for a vessel’s characteristics, operations, and nature of service.
An SMS should:
- establish policies for safety and environmental protection;
- set instructions and procedures to ensure the safe operation of vessels and the protection of the environment;
- define levels of authority and lines of communication between, and amongst, shore and shipboard personnel;
- define procedures for reporting accidents and non-conformities;
- specify procedures to prepare for and respond to emergency situations; and
- include procedures for internal audits and management reviews.
The Coast Guard requires U.S.-flagged vessels engaged in oceangoing international service to have an SMS, but there is no such requirement for the domestic passenger vessel fleet. This lack of regulation exposes potential safety gaps in the thousands of vessels transiting our inland waterways and off the coast.
The NTSB has long advocated for the implementation of SMSs: we first issued a recommendation to the Coast Guard for SMS related to ferries in 2005 (M-05-06) following our investigation of the contact (allision) of the passenger ferry Andrew J. Barberi with a maintenance pier in New York. Then, in 2012, after the Andrew J. Barberi contacted a terminal, we issued Safety Recommendation M-12-3 to the Coast Guard (which superseded Safety Recommendation M-05-06) to require operators of ALL U.S.-flagged passenger vessels to implement SMS. We reiterated the recommendation in 2018, following the fire aboard the Island Lady, and again in 2020 in response to the fire aboard the Conception. The recommendation is currently classified as Open—Unacceptable Response.
In 2020, the Coast Guard published Marine Safety Information Bulletin (MSIB) 03-20 to recommend voluntarily implementing SMS; in 2021, they put out an advance notice of proposed rulemaking (ANPRM) on passenger vessel SMS. The Coast Guard is still working on completing the notice of proposed rulemaking (NPRM). While voluntarily implementing an SMS is a step in the right direction, to ensure widespread adoption, the NTSB urges the Coast Guard to require it.
Since 2010, the NTSB has issued reports on 33 passenger vessel accidents that resulted in a total of 196 injuries and 56 fatalities. Those accidents include:
- In 2010, the passenger ferry Andrew J. Barberi contacted a terminal, resulting in 50 injuries; 3 of those injuries were serious.
- In 2013, the passenger ferry Seastreak Wall Street struck a pier, resulting in 80 injuries; 4 of those injuries were serious.
- In 2018, the small passenger vessel Island Lady caught fire, resulting in 15 injuries and one fatality.
- In 2019, a fire erupted on the small passenger vessel Conception, resulting in 34 fatalities.
The NTSB continues to believe that an SMS is an essential tool for enhancing safety on board all US passenger vessels and that the Coast Guard is the appropriate authority to ensure implementation and enforcement of such a system. While many US operators have already developed an SMS, we also continue to encourage vessel owners and operators not to wait for USCG requirements and to voluntarily develop an SMS to reduce risk in their fleets and save lives—plus, it’s just good business sense.
The Coast Guard has guidance for international small passenger vessels, inspected under 46 CFR Subchapter T, to obtain the required certificates to operate between the U.S. Virgin Islands and British Islands. Owners and operators of small passenger vessels, regardless of whether they are subject to regulatory requirements, can use the guidance to develop an SMS that:
- provides for safe practices in ship operation;
- establishes safeguards against identified risks; and
- documents personnel responsible for safety and pollution prevention policies, functional safety and operational requirements, and recordkeeping and reporting responsibilities.
