Regulators should simplify medical certificate requirements

It was a cold, clear February day in 2014, and my wife and I were picking up our mail at the local post office. Sorting through the bills, ads and personal letters, an envelope addressed to me from the U.S. Coast Guard National Maritime Center (NMC) caught my eye. Not having to renew my merchant mariner credential (MMC) for a few years, this unexpected letter had me wondering why the NMC was writing me. “Maybe it’s a problem with my recently renewed TWIC (Transportation Worker Identification Credential) card,” I thought. Opening up the envelope after we got back home, I pulled out an official-looking paper titled “U.S. Coast Guard Medical Certificate.”
 
For decades before I began going to sea in the 1980s, U.S. professional mariners could hold a valid z-card (merchant mariner document) without ever having to take a physical exam to keep it current. With the implementation of the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), the Coast Guard established formal physical fitness standards and procedures to obtain, renew and upgrade an MMC — detailing these in Navigation and Vessel Inspection Circular 04-08. In 2010, the International Maritime Organization (IMO) formally approved the Manila Amendments to STCW. One of the changes was a requirement that for the first time in modern maritime history, seafarers worldwide now had to hold a separate medical certificate attesting that they met STCW standards for physical fitness. In response to the IMO rule, on Jan. 24, 2014, the Coast Guard began mailing medical certificates to U.S-credentialed merchant mariners.
 
I had never seen an official Coast Guard medical certificate until that February day when the envelope from the NMC unexpectedly arrived. Right below the title on the card was my name, gender, nationality and date of birth. A statement on the card read: “Mariner is free from any medical condition likely to be aggravated by service at sea, or to render the seafarer unfit for such service, or to endanger the health of other persons on board.” The date of my last physical was listed, and showed that my hearing, eyesight and color vision were within approved ranges and that I had no physical limitations or restrictions. The card’s information was pretty straightforward except for one thing that was strange and unexpected to me: It had three different expiration dates.
 
The first expiration date on my medical certificate was for STCW. In accordance with the requirements set forth by the IMO, STCW medical approvals are good for no more than two years. The second expiration date was for the pilot medical approval, which, like STCW, is good for a maximum of two years. The third expiration date was for my national endorsement. Unlike the other two, that medical approval is good for up to five years. Since medical certificates began arriving in the mail, I have found out that entry-level mariners holding an ordinary seaman, wiper and food handler endorsement typically receive only one expiration date on their medical certificate — for their national endorsement. Entry-level mariners who wish to sail deep-sea and need to have an STCW expiration date placed on their certificate must specifically request it of the NMC, providing a copy of a current basic safety training certificate with their application.
 
Having STCW medical clearances valid for two years and national endorsement medical certifications good for five years has caused confusion and anxiety among mariners ever since the medical certificates began being sent out in 2014. That’s because the way things stand right now, an MMC has to be renewed only every five years, which means that during the five years the MMC is valid a mariner will need to renew his or her STCW medical clearances twice. In addition to the time and expense involved for two additional physicals, the whole procedure of sending in the application for a new medical card, and then waiting weeks or months for the NMC to issue the updated certificate and send it back in the mail makes the process cumbersome and inconvenient. Any delay at the NMC in issuing the updated medical card could result in a lost job opportunity — or even being fired. 

A port engineer I know who works for a large West Coast company told me recently that he had a boat getting ready to crew up overseas. A week before the vessel was scheduled to sail, he found out that the chief engineer’s medical certificate had an expired STCW medical approval, and so he could not make the trip. Another company engineer was tapped as a replacement, but he too was found to have an expired STCW medical approval. Finally, an engineer who had both a valid MMC and a current STCW medical card was located, and he got the job. I heard recently that a similar situation happened at a company I sailed for several years ago. During an inspection conducted at a foreign port, 20 percent of the crew on one of its ships were found to have expired STCW medical approvals on their certificates.

Now that the medical certificates are in their second year of being issued to U.S. mariners, from what I’ve seen a few changes could be made. The only ones who need to have a pilot medical approval/expiration date on their certificate are those with a pilot endorsement. Entry-level mariners meeting current basic training requirements should automatically receive both an STCW and national endorsement medical approval/expiration date on their certificate. It would be better if all medical approvals expired at the same time, with clearances good for five years, not two. Finally, medical certificates could conveniently be included as part of the MMC, listed separately on their own page. These changes would make things less confusing for the mariners and easier for the authorities having to issue all the certificates. At a time when even the IMO admits that the ever-increasing administrative demands placed on seafarers need to be reduced, improving the document and streamlining the process just makes sense.

Till next time, I wish you all smooth sailin.’ 

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 captsweeney@profressionstg.wpengine.com.

By Professional Mariner Staff