One man's experience with Coast Guard's new medical rules

In 2003 the 310-foot, 6,000-passenger capacity Staten Island Ferry Andrew J. Barberi crashed into a pier at full speed, killing 11 passengers. As the National Transportation Safety Board investigation of the incident moved forward, the medical fitness of the captain and assistant captain became a focal point of the inquiry — including their use of prescription medications. This investigation, largely focused on these two officer's physical and medical competence, ultimately spurred the U.S. Coast Guard to develop a wide-ranging set of medical standards that now apply to all 69,000 American merchant mariners. These requirements are found in Navigation and Vessel Inspection Circular (NVIC) 04-08.

Voluminous at 75 pages long, NVIC 04-08 sets specific standards which define what the Coast Guard considers "physically competent" to obtain a merchant mariner credential. For example, listed are 201 medical conditions, ranging from cancer and sleep apnea to poor eyesight and high blood pressure, any one of which can cause a delay or the outright denial of the issuing of a new document. Physical agility standards, for the first time since World War II, are part of the requirements. Plus, unlike in years past, even after a medical practitioner certifies competency, a review/approval by medical evaluators at the National Maritime Center (NMC) is required.

In September 2010 the time for my license renewal had come. I made an appointment for my physical at a clinic in Seattle — a three-hour drive from my home. Then I downloaded all nine pages of the revised Merchant Mariner Credential Medical Evaluation Report (CG-719 K) from the NMC website, and as directed, proceeded to fill them out in preparation for my exam.

Page one and two contained instructions for filling out the paperwork, and for the doctor or medical practitioner about how to conduct the exam. The next page asked for my personal/contact info, and contained the release authorizing that my medical records could be sent to the Coast Guard. Page four requires all prescription and non-prescription medications to be listed. Because I don't take any medications, I decided to put down my daily multivitamins and fish oil capsules. A list of 86 different illnesses, injuries and medical procedures on page five had me marking yes or no as to whether or not I had ever had any of them. Any yes answer could have required an additional medical review and the delay or denial of my credential. My previously broken nose and finger, basal cell carcinoma on my nose, and having my tonsils out as a kid had to be listed. Thank goodness, they were not issues requiring more review. The next pages, six and seven, contained all the physical exam info to be filled in by the nurse or doctor, things like blood pressure, height, weight and an eye test.

Thirteen agility standards that a mariner with a Body Mass Index (BMI) under 40 may be asked to do, and someone with a BMI over 40 must be asked to demonstrate for the medical practitioner were listed on page eight. The tests include being able to drag a 50-foot fire hose, lift and carry a 40-pound weight, squeeze through a 24-inch opening, and don a survival suit — all things any merchant mariner could realistically have to do at sea. On the last page of the exam report form the doctor or medical practitioner gives a recommendation that you either pass the physical exam and are competent, you fail the exam, or a further medical review is required. My doctor pronounced me physically competent. It was then required that I send all nine pages of the completed exam form to the Coast Guard. A few days later I received approval from my medical evaluator at the NMC, and continued the process of renewing my credential.

In my opinion, some of the changes in the standards set forth in NVIC 04-08 are positive because they create a level of consistency that did not exist before. For example, in the past each doctor would have his or her own opinion about what “high blood pressure” was. One mariner would pass a physical while another with the same readings would fail the exam. By specifically defining “medical competence,” NVIC 04-08 has largely eliminated past ambiguities and inconsistencies. In my case, knowing ahead of time that a Body Mass Index above 40 meant an additional review and extra testing pushed me to join a gym and start doing yoga to lose some weight before my exam.

One complaint I've heard is that the medical standards established by NVIC 04-08 were developed with little input from U.S. merchant mariners. In an attempt to open a dialogue and address this issue, when President Obama signed the Coast Guard Reauthorization Act of 2010, it included a provision for the establishment of a Merchant Marine Medical Advisory Committee consisting of four mariners and 10 medical professionals. So far I have seen no information on who has been selected or where/when the committee will meet. Hopefully this new committee will give us a chance to have our opinions about the revised medical standards heard — especially regarding their implementation and enforcement.

The Andrew J. Barberi incident was a terrible tragedy, and among other things, ultimately resulted in 75 pages of new medical standards for all U.S. mariners. It is interesting to note that although the report of the accident also listed fatigue as a contributing factor, not one page of any new comprehensive work hour rules to mitigate fatigue have been officially forthcoming. This despite the fact that according to Coast Guard studies, fatigue accounts for 33 percent of all shipboard injuries and 16 percent of all vessel accidents.

From my perspective as a merchant marine officer, fatigue is as much of a health and safety issue as physical competence is. That's why I think new official work hour rules for U.S. merchant mariners should be developed and enforced by the Coast Guard with the same fervor as the medical requirements in NVIC 04-08.

Till next time, I wish you all smooth sailing.

Kelly Sweeney holds the licenses of master (oceans, any gross tons) and master of towing vessels (oceans), and regularly sails on a wide variety of commercial vessels. He lives on an island near Seattle. You can contact him at

By Professional Mariner Staff