Navigating through the USCG STCW rules


#1

Good day, I wonder if I could get a little help from someone more familiar with the US coast guard interpretation of the STCW rules.
This year three of my modules have reached their five year expiry date
Lifeboatman PSCRB ( this actually ran out three weeks ago ) Jan 2018
Personal survival expires in May 2018
Advanced FF expires in December 2018
My license ( Chief Ltd oceans ) is good until 2020
The school is saying that if I have not logged 360 days in the last five years then I must sit a USCG open book exam as well as the STCW refreshers
I realise that I may have to take the full lifeboatman again as mine has expired
but open book exam? I would have thought that would be just at the time of license revalidation
Does anybody know the details of these rules
I’m getting different info from different schools
Thank you for any advice
Stephen Heaney


#2

I believe the USCG has extended (or adopted a non-enforcement policy) for these STCW requirements until the next renewal for mariners that renewed before 12-31-16, but I’m not sure. Nor do I know if foreign Port State Control would accept STCW certificates that are, from their STCW viewpoint expired.

Next you need to figure out whether you need a refresher or Revalidation. You need seatime with drills for Revalidation.

I would not trust most of the schools for advice on this. I hear that the SIU school, Piney Point, has a 5 day combo course for refreshing or Revalidation BT, PSC, and Adv. Fire, all at once. I have not heard what it costs. I’m not sure which it is, a refresher or Revalidation course. Probably, other schools will eventually offer something similar. This type of combo course seems like the most sensible way to go.


#3

You and/or the school are mixing up STCW and the license , but they are mostly right.

There are no exams for STCW. The open book exam is to renew a license, and it applies if you don’t have the one year in the last five. See 46 CFR 10.227(e). Note that the refresher course it mentions is for the license renewal only, it is not the same as the STCW refresher courses discussed below. As far as I know, there are no such courses available for renewing a Chief-Limited license.

On STCW, you need a course of some kind. If you do have the one year of service in the past five, you can take a “Revalidation” course. This covers only the things not done in shipboard drills (anything in the water, live fire, etc) If you do not have the one year in five, you need longer “Refresher” courses that cover everything. If you don’t have one year in five, you need refresher courses for basic training, proficiency in survival craft, and lifeboatman. See 46 CFR 11.302, 46 CFR 11.303, and 46 CFR 12.613(b).

If this is the first time you have renewed your STCW endorsement for Chief Engineer since January 1, 2017, you will also need the following courses for STCW, if you haven’t had them before [46 CFR 11.325(b)]:

Engineroom Resource Management
Leadership and Managerial Skills
Management of Electrical and Electronic Control Equipment


#4

Thanks JD and thank you Tug
I figured that the school must have the open book thing wrong
My license is good until 2020
It is just the three stcw courses I need
Advanced ff
PSCRB
and Survival
The SIU school in Maryland offer this as a package , ( thanks Tug ) but…
In order to decide whether I need refresher or revalidation courses it seems to me that first I have to present sea time documentation, but to whom ?
USCG ? or will an accredited school do this for me ?
Best regards and really grateful for these pointers , we are in refit in Holland and I am trying to get my ducks in a row before I come home
Steve


#5

You can make a good estimate yourself. If you have 360 days of service within 5 years of the date you plan to apply, you’re probably good for the “revalidation” courses. The 360 days needs to be on a vessel that has regular drills. An inspected vessel will likely meet that. For uninspected vessels, you may need to have something to show the vessel held regular emergency drills.

To get a firm answer from NMC, you’ll need to apply. If you do that before you take courses, they should respond telling you which you need. You’d then have 90 days to get the courses and send the certificates to NMC. They won’t give you a n answer as to your specific situation without having applied.


#6

Why do you need them now as opposed to in 2020 when you are next due to renew?


#7

I just came back to ask the same thing, I should have seen it this morning. If your MMC expires in 2020, you’re good on all those STCW renewal courses until then. It doesn’t matter when you took the courses, you should be good until you next renew your MMC. Same for those 3 extra courses I mentioned.


#8

I am going by the dates on my individual certificates
I took them all at Falck Alford in Houma in 2013
Then I did the gap closing ( helm, meece etc star center in Dania Florida in 2016
My license is due in 2020
But the stcw certificates are now five years old
What am I missing here ?
Please excuse my ignorance
Steve


#9

The USCG announced a policy that STCW certifications that are in your MMC book —- don’t have to be refreshed or revalidated until you renew your MMC after 12-31-16. So as far as USCG is concerned you are ok until your MMC expires

However, as far as I know, no one knows what might happen if foreign port state control looks at your actual STCW certificates during an inspection and notices that they are more than five years old.


#10

Thanks Tug
Your explanation tells me all I need to know
If we get port state control on board over here before we head home then I guess I’ll be a test case. I’m happy with that .
I’m certainly not going out and doing double sets of stcw courses to please everybody
As far as racking up seatime for my 360 is concerned do you happen to know if my discharge book entries are sufficient for the USCG or do I need headed and signed company letters ?
The help you have both given me in the last few days has been invaluable
Thank you very much
Steve


#11

There is no way to predict what any particular incompetent new hire coal-miner’s daughter masquerading as an evaluator at USCG NMC in the hills of West Virginia might do on any given day.

In the past discharges were respected and that was all that was needed. Maybe that is still true. I don’t know.

Now discharges are less common, and this company letter thing has gotten Nitpicky. They seem to want particular magic words and phrases in the seatime letters. Never underestimate the ability of company HR staff to screw this up.

I think I would just try the discharges and see what happens. If they object that they need a letter with certain magic words, at least you’ll know what words need to be in the letter.

I cannot stress enough the value of a good license consultant. They are in the best position to know the current correct answers to such questions. They are also on a first name basis with the evaluators and speak the same language.


#12

the proof of being in a random drug program letter has gotten nitpicky as well. I had lots of fun having that re-written about 100 times recently.


#13

I’ve given up on the drug test letters. I just go get a new test and send it with any new application.


#14

I ended up adopting the same simple hassle free solution.


#15

I’m not sure what the USCG would think about a foreign discharge book. Maybe @jdcavo can give insight there.


#16

They’re not unheard of. NMC sees them occasionally and as far as I know, doesn’t take issue with them.


#17

That’s good. I wish the USCG would, if not print their own, at least authorize a private entity to print a discharge book and sell it for a reasonable price. I’d pay $15 for a printed, hard bound book that could log a few hundred discharges. Even on a boat working a week on a week off that would last at least 5 years.


#18

Also, how do you think they’d feel about a personal kept discharge book? If one were to buy a hard cover notebook like one of these and fill out the information that’s on a discharge form (sign on, sign off, seaman name and rank, vessel name, official number, gross tonnage, route, master’s name, mariner reference number, signature, and vessel stamp) would the USCG / NMC accept that as proof of service?


#19

Granted, if you’re willing to go through that much trouble you might as well fill out your own discharges and have the captain sign them before you get off.


#20

I’d pay $150 without blinking for a USCG issued Continuous Discharge Book.

I’ve heard of US mariners successful using their foreign Discharge Books to record their US flag vessel seatime.