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Another foot is falling in the lengthy process of implementing changes in US Coast Guard licencing regulations to comply with international standards first set forth in STCW convention of 1978 and its subsequent amendments. The agency in November issued a set of proposed rules that, if implemented, would affect most seeking new licences or upgrading an existing licence, especially captains and engineers.
“The Coast Guard proposes to amend its regulations to fully incorporate the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended (STCW Convention), as well as the Seafarer’s Training, Certification and Watchkeeping Code (STCW Code) in the requirements for the credentialing of United States merchant mariners,” says the 90-page document known as a Notice of Proposed Rulemaking (NPRM).
Many of the proposed changes are arcane but several will have a direct bearing on deck officers and engineers. The proposal with the most significant potential impact involves the elimination of the popular 500 gross register ton (grt) master’s licence. The current tonnage breaks that would apply to most motoryacht captains are 200grt, 500grt and 1,600grt. The Coast Guard’s rationale for proposing the eliminating the 500grt endorsement is that the training requirements between the 500 and 1,600 are mostly equivalent. Mariners currently holding 500grt endorsements will be allowed to renew them. Problems may arise, however, for those attempting to upgrade from 200 or 500 to 1,600.
If implemented as proposed, the new regulations would require 200grt (500gt) masters wishing to upgrade their licences to 1,600grt (3,000gt) to be qualified as a mate and as an OICNW (officer in charge of a navigation watch) on seagoing vessels of 200grt (500gt) or more, and have either a) 24 months of seagoing service as an officer, of which 12 months must have been as chief mate, and at least six months of which must have been on vessels of 150grt (375gt) or more; or b) 36 months of service as OICNW on self-propelled, seagoing vessels, of which at least six months must have been on vessels of 150grt (375gt) or more. The applicant must also complete approved training that provides him or her with the knowledge, understanding and proficiency required by the STCW Code, and must complete the assessments of professional skills in the areas as required.
Such requirements would be an obvious concern for captains seeking to increase their salaries or who work for yacht owners who are making a leap in size.
“It’s going to be rough for a lot of people in the next couple of years,” says Amy Beavers, managing director and academic principal of Maritime Professional Training in Fort Lauderdale.
According to Beavers, the interim mate OICNW level (known under UK MCA as OOW) will require nearly 26 weeks of its own training and assessments, in addition to the training and examinations that will later be required for the upgrade to master. The British MCA licencing system is already set up in a similar way, but the US has been slow to comply with the STCW.
Others who could feel a strong impact from the new regulations are engineers. A shortage of skilled labour in the field and lax enforcement of existing regulations has resulted in some engineers not upgrading their credentials or not getting them at all. The regulations would require vessels with powerplants of 750kW and above that sail internationally to have a licenced engineer. The months of training required to obtain or upgrade a licence likely would burden the individuals, as well as further stress the labour pool.
As is typical with the US Federal regulatory process, a comment period has been put in place for anyone wishing to sound off on the proposals. The deadline for public comments is on or before 16 February. A public hearing on the topic was held 20 January in Washington, DC. Four other public meetings were held earlier in Miami, New York, New Orleans and Seattle. No timetable is set for implementation but the agency will review public input before making its final decisions.
“I would highly recommend to your readers they at least look through this to see if it impacts their individual licence,” says Mark C Gould, project manager for the STCW NPRM.
The public comment period allows the Coast Guard to obtain first-hand input from those who would be affected. “We can modify [the regulations] based on the comments we get,” says Rachel Wallace, attorney advisor with the Coast Guard’s Office of Regulations.
Since existing licences will be honoured, Beavers suggests current licence holders apply for upgrades and complete their training now. She also urges mariners to make their sentiments known through the comment process.
The complete proposed rules document can be found here at http://edocket.access.gpo.gov/2009/pdf/E9-26821.pdf. To comment online, go to regulations.gov. In the “Document Type” drop-down menu, select “Proposed Rules” and insert “USCG–2004–17914” as the keyword.
Kenny Wooton
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