The push is on to get mariners ready for the transition to the latest Standards of Training, Certification and Watchkeeping (STCW) requirements.
The U.S. Coast Guard issued its final rule adopting the Manila Amendments for American mariners in December 2013. March 24 was the end of the 90-day phase-in period. Now all new mariners must be certified under the new requirements, and mariners with pre-existing endorsements will begin transitioning.
On Feb. 11, the Coast Guard held a public meeting as part of a press to bring the industry up to speed. According to officials who spoke at the meeting and in interviews with Professional Mariner, one of the main areas of concern from mariners seems to be how their particular endorsements will be affected.
Most pre-existing endorsements will stay in effect until their expiration date and will be renewed under the new requirements. The deadline for this is Jan. 1, 2017, with the transition period for national endorsements extending until March 24, 2019.
“We understand and are fully aware there is a lot of anxiety on the future implementation on STCW requirements to the domestic fleet and we can assure you that the Coast Guard will continue to approach different sectors of the industry,” Mayte Medina, chief of the Coast Guard’s Marine Personnel and Qualifications Division, said at the February meeting.
Additional public meetings will be held, she said.
New documentation, including 26 Navigation and Vessel Inspection Circulars (NVICs), will be published, Medina and other Coast Guard officials said. These NVICs, nine of which already have been published, will include specific guidance for mariners, shipowners and training course operators. A key NVIC for many mariners will be the grandfathering NVIC, officials said.
Many questions at the February meeting involved mariners with concerns about how their particular endorsements would transition under the new requirements. Luke Harden, chief of the Coast Guard’s Mariner Credentialing Program Policy Division, pointed to the NVIC on grandfathering.
“For those who are concerned about changes, we’ve worked on tools to explain those changes and how they impact you,” Harden told Professional Mariner. “For instance, the grandfathering NVIC should answer a great deal of these questions.”
Harden said the Coast Guard is trying to emphasize a quick transition and make it as smooth as possible.
“We’re trying to keep things moving,” Harden said. “The grandfathering provisions are such that, even though we realize there are some additional requirements for some, we’re trying to take a pragmatic approach to those requirements. And we’re trying to be clear (in the NVICs) about this is what you need and these are the gaps between the current rules.”
The remaining NVICs will be released in groups, with the first batch covering STCW deck endorsements, followed by a second batch dealing with STCW engineering endorsements. The third and final batch will address any remaining general issues. Officials declined to say exactly when the NVICs will be released. Prior to each publication there will be opportunities for public comment and notification of final publication will be made on the National Maritime Center (NMC) listserv.
At the February meeting, Coast Guard officials encouraged anyone with concerns — whether they are mariners, shipowners or course providers — to visit the NMC website to check an expanding list of frequently asked questions on STCW. This will be the main source of information for clarifications on the requirements, Harden told Professional Mariner after the meeting.
At the February meeting, and in follow-up interviews, Coast Guard officials focused on the issuance of medical certificates as the most immediate and widely applicable issue for mariners. As of Jan. 24, STCW rules for medical certificates are in place, requiring mariners to have a valid medical certificate. Nearly all of the roughly 55,000 American mariners with STCW endorsements will be issued new medical certificates.
As of the March 24 effective date for the final rule, the Coast Guard said it had issued 56,360 medical certificates.
Mariners who lose their medical certificates can try to submit a photocopy of their original certificate, but there is no guarantee that Port State Control authorities would accept them. Mariners should try to obtain a duplicate copy by submitting an application to the NMC and include an affidavit stating the circumstances of how they lost their certificate, Harden said.
Officials fielded several questions about the new requirements for approved training courses. They said NVICs and online documentation at the NMC website would help course providers navigate most details. During the live session, Medina said the Coast Guard tried to address concerns that were raised over emphasis on on-the-job training. Several commenters complained the emphasis would degrade the quality of training and create extra work for officers on ship.
“So, in this final rule, the Coast Guard provides a more appropriate balance between on-the-job training and formal training,” she said.
Re-evaluations of which courses would require approved training were also conducted, Medina said.
“We took a lot of care in identifying those areas that would require approved training,” she said. “Some of those areas are black and white from the convention, which are approved training, however some of those areas were a little more gray.”
The Coast Guard attempted to pick and choose which areas might demand formal training, but there have been attempts to build flexibility into how training can be done. While certain areas require formal training, the details of the process are flexible in many cases, she said.
“Where it says that (it’s required), that’s actually the training that must be done … but we did not specify that it has to be done (by) distance learning, or sitting in the classroom,” she said. “Both are things that the course providers or owners who want to develop the training can actually get into.”
