A Government Accountability Office (GAO) report into the U.S. Coast Guard’s oversight of safety management systems found that some shipboard emergencies may not be adequately addressed. But it is too soon to say if this is likely to pose a problem as many vessel operators are still in the process of revising their plans.
In October 2015, the U.S cargo vessel EL FARO sank after encountering heavy seas and winds from Hurricane Joaquin, killing all 33 crew members. Subsequent investigations cited deficiencies in the vessel’s safety management systems (SMS) plans as a factor that may have contributed to the vessel’s sinking. Some in Congress have raised questions about the effectiveness of vessel SMS plans and the Coast Guard’s oversight of third parties responsible for ensuring vessels comply with international standards and federal regulations.
The Coast Guard verifies that domestic commercial vessels comply with SMS requirements through activities that include conducting annual inspections of applicable U.S.-flagged vessels. In practice, the Coast Guard delegates primary vessel SMS compliance activities to third party entities, called Recognized Organizations (ROs).
Among their responsibilities, ROs coordinate with vessel operators to review SMS plans, issue applicable vessel certificates, and conduct SMS compliance audits at the company level and aboard each vessel. Because the Coast Guard relies on ROs to perform SMS certification services on its behalf, it has initiated a series of efforts to enhance its oversight of ROs since 2018. The efforts include:
- establishing a new group within the Coast Guard to monitor ROs,
- developing new SMS-related guidance and work instructions,
- increasing direct observations of ROs performing SMS audits,
- developing key performance indicators for assessing ROs, and
- requesting internal investigations for certain RO deficiencies.
GAO says while these are positive steps, it is too soon to assess the effectiveness of these efforts.
Each of the 12 domestic vessel SMS plans GAO reviewed include potential shipboard emergencies and applicable response procedures to address them. Four of the 12 SMS plans are large documents spanning hundreds of pages that incorporate various component manuals. For example, one vessel operator provided a comprehensive SMS plan document of nearly 600 pages that includes six different procedural manuals covering the following issues: Management, Vessel, Safety, Environmental, Cargo Operations, and Emergency Response. For the other eight SMS plans GAO reviewed, the vessel operators provided either a stand-alone manual specifically addressing shipboard emergency preparedness and response procedures, or individual chapters and excerpts that included this information.
None of the plans address all 21 potential shipboard emergencies included in 2018 Coast Guard guidance. However, these 21 potential emergencies are not required to be included in SMS plans; rather, they are suggested as part of the 2018 guidance.
Ultimately, GAO found that the SMS plans may not address all potential shipboard emergencies because not all emergency scenarios are applicable for each type of vessel or geographical operating area. Also, vessel operators may still be in the process of revising their SMS plans to include additional emergency scenarios and applicable response procedures.
