Excuse my ignorance in the subject but I am trying to get a clear answer for a friend of mine on the requirements to upgrade from 2nd Mate to Chief Mate. I have the 04-02 policy letter from the NMC and the requirements list Assessments only for the upgrade. Nowhere on the checklist do I see courses listed. My question is, would a 2nd going to C/M need to complete all nine courses ( Adv: Stability-Meteorology-Cargo Handling etc ) to upgrade even if the mariner has the assessments signed off for those particular classes? My friend has all the assessments signed off for the upgrade minus Stability and Ship handling. The assessments in his possession have been signed off sailing at sea, by an unlimited master who has read and been signed off on the " Assessors Manuel For Conducting Assessments "
We are really trying to get a clear answer as to “Yes” the mariner will still need the courses even if you have the assessments signed off…Or… “No” the mariner doesn’t need the courses since they already have the assessments signed off. Either way my buddy will take the courses if need be, its just tough to move forward if you don’t have the correct information. I look forward to hearing from anyone who has had experience in this upgrade recently. Thank you in advance. Sounder
I’m not 100% percent sure, but I believe he must take the classes. Page 1-2 of policy letter 04-02, section 6 is the training and assessments of skills part.
“Accordingly, every applicant for a license and STCW certificate must participate in structured, approved or accepted training.”
It also restates that on page 1-A (Masters and CM checklist)
Also, i don’t think its totally possible to get all the assessments signed off at sea (docking, Collision, grounding, embarking a pilot) seems they have to be done in a simulator.
Your friend does NOT have to take the classes. “Accepted training” IS having an on board approved assessor sign your control sheets. Classes are USCG approved, streamlined and faster, but costly. Training facilities would have you believe you MUST take the classes, obviously, thats what they sell.
[QUOTE=rjbpilot;58471]“Accepted training” IS having an on board approved assessor sign your control sheets. [/QUOTE]
Not correct. Accepted training is training that a Coast Guard approved “Quality Standards System” organization has accepted on behalf of the Coast Guard. More simply, it’s approved training, but the approval comes from an organizations the Coast Guard has authorized to give approvals. Right now, there are two QSS organization, ABS and DNV. Vessel Security Officer is currently the only available accepted training . This is because the Coast Guard will not approve VSO courses, they must be QSS accepted. Other types of courses can be accepted, but the QSS organizations charge substantial fees for their service and for course approvals, the Coast Guard does it for free. So no one has used the QSS option except for VSO, where it’s the only option.
Recent appeal decisions have held that the courses in NMC Policy Leter 04-02 can not be required as they “regulate by policy.” They exceed the requirements in the CFR.
Mr. Cavo, will the sign offs my friend has, be accepted as “accepted training” in the eyes of the Coast Guard if the assessments have been signed off by the master who is a on board approved assessor? What is the reasoning for getting the assessments done at sea if you still need to take the classes? Again I apologize for my ignorance in the matter, but I’m trying to figure out what my friend needs to do in order to move forward. Thank you all for the reply’s.
It’s been several years since I’ve completed the upgrades myself, but at that time all classes except Celestial Navigation were required. This is what I was told by my union school; I can’t necessarily point you to any actual regulation that says so. I also can’t confirm that Celestial still only requires the control sheets to be completed.
I fully understand the courses are a real pain, but it must be done. Hopefully your friend belongs to a union and thus the classes are free. Otherwise they get REAL spendy real fast. Also, especially if your friend has an academy education, the classes can be very mind-numbing. I felt like the only classes that were actually worth my time were Stability and Shiphandling. But enough complaining…
One point your friend should know is, no matter where he chooses to take the upgrade courses, he really ought to take ALL the classes at the same place. Different schools allocate the control sheets differently among the courses and it’s possible he could miss some sheets if he takes classes at different schools. Also, it should be noted that it’s not necessary to take all the classes in one shot, though there are a couple classes that need to be completed within one year of each other (but they’re normally offered back-to-back and probably should be taken as such, since the second class is functionally a continuation of the first).
[QUOTE=Sounder1;58479]Mr. Cavo, will the sign offs my friend has, be accepted as “accepted training” in the eyes of the Coast Guard if the assessments have been signed off by the master who is a on board approved assessor? What is the reasoning for getting the assessments done at sea if you still need to take the classes? Again I apologize for my ignorance in the matter, but I’m trying to figure out what my friend needs to do in order to move forward. Thank you all for the reply’s.[/QUOTE]
Simple. Compete all assessments, then apply for upgrade. If some of the assessment are lacking, maybe the courses can fill the gap. Make sure the course covers those particular assessments though.
Read Cavo’s quote below…
“Recent appeal decisions have held that the courses in NMC Policy Leter 04-02 can not be required as they “regulate by policy.” They exceed the requirements in the CFR.”
I would not take any courses that are mandated by policy letters only, but some may still have to. Like those on drill ships that stay on-location for extended periods, it would be hard, if not impossible to complete required assessments. Schools still have their place with some.
Whatever happens, it needs to happen fast. The Coast Guard has published several STCW regulatory changes, held public comment periods on the Federal Register, and they can implement these changes tomorrow (who knows), which in effect will add the courses in regulation.
[QUOTE=jdcavo;58475]Recent appeal decisions have held that the courses in NMC Policy Leter 04-02 can not be required as they “regulate by policy.” They exceed the requirements in the CFR.[/QUOTE]
I thought the only courses that the NMC no longer claims are necessary are the ones for 3M/2M?
[QUOTE=anchorman;58520]Whatever happens, it needs to happen fast. The Coast Guard has published several STCW regulatory changes, held public comment periods on the Federal Register, and they can implement these changes tomorrow (who knows), which in effect will add the courses in regulation.[/QUOTE]
So they are planning to require the courses by regulation?
In the end, my advice would be to just take the classes. I understand it sucks to take vacation time (usually away from the family, though some schools will permit you to bring family), but I do know that if you take the courses at an approved school and have the certificates (and the control sheets) you are definitely safer. These days you don’t want to give the NMC any reason to deny your application–even if you’re right it’s often like arguing with a brick wall, except the brick wall at least has a tangible purpose.
[QUOTE=awulfclark;58529]In the end, my advice would be to just take the classes. I understand it sucks to take vacation time (usually away from the family, though some schools will permit you to bring family), but I do know that if you take the courses at an approved school and have the certificates (and the control sheets) you are definitely safer. These days you don’t want to give the NMC any reason to deny your application–even if you’re right it’s often like arguing with a brick wall, except the brick wall at least has a tangible purpose.[/QUOTE]
Why fold to the tune of $30,000 and take classes that are not required on a preconceived notion that NMC will deny an application without even applying in the first place? Really? I never heard of such. Several mariners are getting approved to test without the courses. There is a reason for that. The Coast Guard has made a ruling and it seems that NMC is applying that decision to applications.
You make a solid point. I sometimes forget that a good portion of mariners are on the hook out of pocket. OK, if you are part of a union and get the school free, or if your company will pay, then great, go for it. Anyway, the idea that the NMC is approving mariners without the actual courses is news to me–and if they hold to that, great. But definitely check ahead of time.
[QUOTE=rjbpilot;58596]If an applicant submits control sheets signed off by an approved on board assessor, the USCG will “accept” them in lieu of classes. Correct?[/QUOTE]
Not correct. Training is not assessment. Assessment is not training. They are separate requirements. The assessments will meet the requirement to complete assessments.