GAP Closure Training and Licensing Delay Issues


#1

I need SERIOUS suggestions.

I have been working with my Congressman on the GAP Closure Training/Licensing issues through an official Congressional Inquiry.

After reviewing official responses to me in December and January and responses from Congressional Affairs in May to an official Congressional Inquiry the Congressman was particularly suspicious of some potential hiring’s (five) initiated two days prior to a response about personnel shortages at NMC. He was also very concerned about serious differences between answers I received and his office received to the same questions and accompanying documentation both public and official.

I have now been tasked by his office to submit a list of recommendations to solve some of the issues I raised before he goes to Headquarters and meets with senior staff members.

I am extending you the opportunity to get serious solutions you see needed to the forefront through me. I will of course disregard unworkable recommendations.

This is a one-time offer. I need input by tomorrow. I know this is short notice but I have been working on this and other issues for 8 months. Once this is complete there are other Coast Guard issues I will be addressing.


#2

It would be very interesting to see more details about the NMC program and their responses to your inquires and to Congress.


#3

Suggestion 1

Establish an expedited (5 day) application review and credential issuance process for a $500 fee.

Establish an expedited (1 day) application review and credential issuance process for a $1000 fee.

Those of us that actually need our credentials in hand to go to work, and our employers who need to put us to work in order to stay in business, need an expedited program. We are willing to pay for it.


#4

Suggestion 2

Reestablish prompt in-person application reviews and processing by competent evaluators at the RECs.

If not at the RECs, then at the NMC.


#5

It was not just NMC. It was CG-MMC (Merchant Mariner Credential) at headquarters and the Deputy Commandant for Operations, VADM Ray who has since moved to another job or retired. I am hoping this follows him. This has been an eight month project and I have been working alone against entire staffs to get this far.

I don’t feel like typing it out but if you want to talk about it, PM me and I will give you my phone number.

I will tell you that either I or my Congressman was lied to by the Coast Guard which to me forced the Congressman’s hand. I just want the issue brought to a satisfactory resolution. Additionally, since I was “correct” once, there are other issues I intend on presenting internally to the Coast Guard and hope they are more open for self critique instead of having Congress get involved but I always have that card to play among others.

I never intended for it to get to this level but I do my research, I know where some bodies are buried and I am stubborn. Additionally, do not pee on my back tell me it is raining, that is a sure way to raise my ire.


#6

Suggestion 3

The NMC should immediately hire well qualified contractors (former NMC and REC personnel with proven ability) to assist with eliminating the licensing backlog. These contractors should be allowed to work remotely from home, or in offices at the RECs.

Suggestion 4

The USCG should offer one year paid “Fellowships” to Maritime Academy graduates, and to law school graduates to work as evaluators at the NMC. These fellowships should become a stepping stone to further Federal employment.

Suggestion 5

The NMC should immediately hire licensed mariners as contractors, or as employees of contractors, to review and evaluate applications. The work should be structured so that it can be done by unemployed or retired mariners, or by active mariners on their time off.

Suggestion 6

NMC should use specially trained evaluators. There should be specialist evaluators that only review GAP closing applications. There should be evaluators that only review applications from students about to graduate from the academies. There should be evaluators that only review entry level applications. Etc.

Suggestion 7

The licensing system should be drastically simplified with fewer types of licenses and endorsements, and fewer types of exams.

Suggestion 8

The licensing system should be better harmonized with STCW and the policies and practices of other STCW countries, particularly Canada and the U.K.

Suggestion 9

Only I.T.C. GT tonnage should be stated on licenses. The use of GRT tonnage should be eliminated for licensing purposes.

Suggestion 10

The role of seatime on vessels of a particular tonnage, and the supposed importance and quantity of seatime on vessels of particular tonnage should be reduced. Smaller vessel experience is much more valuable than the credit the USCG gives to it, and the other STCW countries already recognize this.


#7

I like the way you think…


#8

They definitely need to streamline the licenses and exams. Keep the US tonnage system for inland boats 100 tons and less and for OUPV NC. (Any boat other than an uninspected passenger vessel going outside the boundary line would require a II/3 onboard.) Any license over 100 GRT be issued in GT exclusively, II/3 (master and mate under 500 GT), 3,000 GT licenses, and unlimited.

Actually require people to get a Chief Mate 3,000 GT before they can get a Master 3,000.

End the 2nd mate Unlimited to Master 3,000 GT giveaway, one year of sea time isn’t nearly enough and they should have to take the complete set of exams.

Anyone getting a Master 3,000 GT or larger, including any Master OSV license, has to take the full set of Chief Mate / Master Unlimited exams.


#9

Changes to licensing requires approval by Congress. There are a lot of special interests in Congress believe it or not. One being OSV licenses surprisingly. I can only effect nuts and bolts this round. We have to get together as a group to affect thje licenses themselves and that is going to stir industry.

To affect licensing, we are going to have to get our ducks in a row and lobby as Mariners. If you are on Facebook, look up Offshore Masters and Mates Association. It is a page I put together to get started on something like this. Eventually I will make it a secure website away froom prying eyes and that requires money.

I am effective but I work on stuff like this against paid staffs who are paid to stop me so it takes time. Additionally, I can not lobby in DC and will never hand out cash to a god damn public servant as campaign donation when the son of a bitch works for me anyway. It kind of defeats the purpose.


#10

What would keeping GRT for Inland licenses instead of issuing all licenses in GT accomplish? Nothing, but more unnecessary complication and confusion.

US vessels can continue to be regulated and inspected under GRT. It does not matter if the same mariners that operate those same GRT vessels have their licenses issued with tonnage limits in GT.

The result should be just three categories of licenses: (1) up to 500 GT (equivalent to our present 100 GRT); (2) up to 3000 GT (equivalent to our present 1600 GRT); and (3) Unlimited. Of course, there maybe some circumstances under which some mariners should have some further tonnage restrictions, but those circumstances should be rare, not routine.

The vast majority of the thousands of licenses that NMC now issues, and the thousands of requests for upgrades, that are overwhelming the NMC, are for licenses under 100 GRT (500 GT). This is where simplification is most needed. It’s easy, just issue all of these license as 500 GT.

Why have half a dozen different types of AB that all have the same exam, but require numerous requests for upgrades. Two levels based on seatime and STCW training are enough.


#11

It’s more accurately equivalent to our present day 200 both in vessel size and Sea service required. (It’s actually silghtly bigger than most 200 GRT vessels.)

So end the giveaway AB OSV (and AB fishing?) and you only have 3. It’s really not that big of a deal. Processing an AB upgrade sould only take 5 minutes, including all the typing and everything.


#12

I think it goes like this. Evaluator reviews AB application, he has the contractor staff email applicant that he needs a course certificate for BT , and sets application in a different pile. Mariner emails course certificate the next day. It reaches the evaluator a week later. Two weeks later Evaluator reviews application file. Next Evaluator has the staff email that if applicant wants Lifeboatman, he must send in a PSC certificate, repeat, repeat, repeat. Months later Evaluator notifies applicant that he needs 10 more days of seatime. A month later, Evaluator informs applicant that the seatime letter he submitted fails to include certain “magic words” about participation in drills, or drug tests, or something. Repeat, repeat, repeat. After about four to six months of this bumbling, the applicant is approved to test for AB. Applicant passes the AB test and the MMC is issued, but a clerical error left out something. AB contacts NMC to get it fixed. Two months later it finally gets fixed. At least I think this is pretty typical of what happens too often happens to an application at NMC.


#13

here’s an idea. For those submitting sea letters on company letterhead, uscg could provide a detailed template so the boobs in the office only have to fill in the blanks and don’t have to worry about forgetting magic words/phrases.


#14

Better yet we could return carrying Seamen’s Books, like everywhere else in the world.

US statues and regulations still describe the process for using Seamen’s “Continuous Discharge Books” and there is even a CG form number for them, but I’ve never seen one and cannot even find an example of the form.

This company letter thing is a curse.


#15

Agreed on both counts. Stop-gap on that would be requiring the proper vessel issued discharge forms instead of the company letters.

Let’s face it, at least on the OSVs, the assistants in the companies are filling double and triple duty with the downsizings, eliminating seatime letter generation would be one less thing for them to deal with.

I’ve gotten used to getting my Vanuatu book stamped and signed, be nice to have my seatime in my possession all the time instead of some file.


#16

This is already how it’s supposed to be. Anyone getting master AGT that has a Master OSV without taking exams has a bad evaluator.

This brings us to questioning how the NMC is choosing who is qualified to evaluate. The NMC should SERIOUSLY consider a better training program to get these evaluators up to speed. Also, at some point stop changing all the rules so everyone can get used to them.


#17

Here’s my 2 cents. If a Medical Review is required, it should be done by a MD and a letter from the applicant’s own Doctor should be accepted as proof of what’s needed.


#18

Any doctor or nurse practitioner can complete the required physical. I just had my medical renewed. My own doctor and eye doctor did the exams and I had the new certificate in hand less than a week after being submitted. I think the backlog is more on the credentials side and GAP closing review side as opposed to the medical side.


#19

Yes. At one time the medicals were the backlog, but they have hired some doctors, and have the medical review system running smoothly. The medicals are fast now, unless you have some condition that they consider to be a problem.

My friend mentioned “restless leg syndrome” and his medical card was refused. It took omonths of specialists, tests, and explanations to get the medical approved.

I do not use my own doctor who might mention that Ive had some prior minor problem. I use the same big occupational medical chains that the employers use for the pre-employment physicals. They all have a file on me, and if I’ve had a recent physical at the right medical chain, the employer sometimes does not bother with the preemployment physical.


#20

You misunderstood. I’m saying there should be one common set of Master’s exams that everyone takes. Make Master 1,600/3,000 and Master OSV all take the Master Unlimited exams just like the lower level mates all take the 2nd Mate exams.