From: ASTA Ship Operations and Safety Committee
Re: Critical changes to licensing
The USCG has solicited comments on the proposed rulemaking to fully implement the STCW Code (International Convention on Standards of Training, Certification and Watchkeeping for Seafarers Code and Convention.) The ruling includes a number of clarifications and changes in 46 CFR Parts 10, 11, 12 and 15. The deadline for the comment period is February 16, 2010 with a planned implementation of the new ruling in July 2010.
Many of these proposed changes will seriously affect current and future mariners, especially within our industry. The USCG is proposing increased sea time and increased tonnage requirements to qualify both assessments and sea-time in several endorsements/licenses. This will make it extremely difficult for mariners who commonly sail on vessels under 100 tons to advance to higher licenses and will also limit many mariners to near-coastal domestic voyages.
All concerned mariners/program operators/vessel owners should submit a comment to the USCG (see USCG instructions below) listing their concerns regarding the proposed changes. We have been told very clearly that the only way to have our message heard in Washington is to have as many ASTA members as possible submit comments. The proposed changes are 90 pages (open link to read in its entirety) and the synopsis of important changes that we include below is by no means complete. The Shipâ€™s Operations and Safety Committee has been reviewing this proposal for a long and every time it is reviewed, a new item is discovered that may adversely affect a portion of our industry. Please keep in mind that the real effect of many of the proposed changes may not be felt for some years. It is important that you take the time to comment on this ruling!
For those who are just becoming aware of this ruling and need more information, please find attached ASTAâ€™s comments that were delivered by Capt. Jonathan Kabak at a public comment session in Washington, DC on Jan. 20th.
Among the changes proposed by the USCG:
– Elimination of new issuances of and upgrades to Mate or Master 500GRT Near Coastal, International, or Oceans, and Master 200GRT Oceans.
Existing credentials will be renewed.
– New rules will require 150GRT sea-time to obtain a 1600GRT Master. A 1600GRT Master will become the lowest denomination of Ocean license available.