Accordingly, on April 8 2020, the issued their report GAO-20-459 “Vessel Safety: The Coast Guard Conducts Recurrent Inspections and Has Issued Guidance to Address Emergency Preparedness.

In the report, the Coast Guard verified that domestic commercial vessels comply with safety management system (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 activities of the coast guard include:

  1. establishing a new group within the Coast Guard to monitor ROs
  2. developing new SMS-related guidance and work instructions
  3. increasing direct observations of ROs performing SMS audits
  4. developing key performance indicators for assessing ROs
  5. requesting internal investigations for certain RO deficiencies.

Following the report, the coast guard now reminds mariners to use CVC-WI-004(1): U.S. Flag Interpretations on the ISM Code when assessing the risks in accordance with ISM Code 1.2.2.2. This Administration guidance provides a list of 21 Emergency Procedures to take into consideration for your vessels. This is not an allinclusive list and companies are encouraged to evaluate risks unique to their specific operations. It may be that a particular risk is not applicable to the company’s operations, but a company should be prepared to discuss or provide documents that outline the reasons for not addressing a particular risk element in their Safety Management System.