On January 15, 2021, the U.S. Coast Guard issued an Advanced Notice of Proposed Rulemaking (ANPRM)
for Safety Management System (SMS) requirements in the domestic passenger vessel industry (Docket
No. USCG-2020-0123). This requirement will have the largest implications on the domestic passenger
vessel industry since the revisions of 46 CFR Subchapter T & K in the mid-90s. However, the question
remains, is it necessary?
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