USCG: UPDATE CVC-WI-003(2) USCG Oversight of Safety Management Systems
On June 5, 2020, the Office of Commercial Vessel Compliance published an update to CVC-WI-003(2). The document outlines the procedures for Coast Guard personnel to use in evaluating potential non-conformities and corrective action options. It covers the definition of “clear grounds” and steps for an “expanded exam.”
Purpose. This work instruction sets forth guidance for assessing the effectiveness of a company’s Safety Management System (SMS) on U.S. flag vessels through the following processes: • Evaluation of materiel deficiencies for potential SMS process failures; • Evaluation of SMS documentation (certificates, logs, maintenance records, etc.); • Compliance options following objective evidence of an SMS failure; and • Coast Guard oversight of SMS activities performed by Recognized Organizations (RO) and Third Party Organizations (TPO).
Action. Marine Inspectors (MI) and Investigating Officers (IO) that complete vessel inspections, examinations, or casualty investigations on U.S. flag vessels subject to the International Safety Management (ISM) Code as implemented by Title 33 CFR Part 96, including those vessels which comply on a voluntary basis (e.g. Military Sealift Command), should adhere to the guidance herein. For the purposes of this work instruction, a SMS, as defined under the ISM Code, is synonymous with a TSMS required under 46 CFR Part 138.1