Some very good points… However, having had experience on both “sides of the fence” (or Boundary Line if you please!) I don’t fully agree. Mind you- these are PERSONAL opinions which I keep entirely separate from any work related decisions; one MUST have integrity.
I believe the whole problem with the current regulatory structure is that here are far too many endorsement areas. The system is bogged down when one considers the sheer numbers of Licenses (yes- I still call them that) issued for 100T and under is mind boggling- they should be removed from the licensing scheme and changed to an Operator type permit- the requirements would become more stringent when those “operators” carry passengers for hire. Responsibility for evaluation, examination and issuance would be left to third party BONDED and approved third party concerns approved by the flag state.
Of course the new reg changes with regard to subchapter M will require many “brown water” personnel to obtain ratings and licenses- where they had not before. I would tend to recommend a full cut off line of demarcation at 500 tons- that there would be separate and distinct professional, training, examination requirements from those of higher tonnage. In order to move into the area above the tonnage limitation- one would ACTUALLY have to serve in a lower capacity aboard unlimited tonnage vessels for a period of time over one year. This would be for deck and engine. The knowledge and subject base would be considerably less in the below 500T areas than deep sea…
Additionally, I would make it MANDATORY for ALL mariners serving aboard vessels above 200T or those carrying passengers to obtain Basic Training- then I would revamp the various rating table subject requirements and remove the entire safety and environmental examination subjects… A caveat to this would be that as one progresses up the ladder in the unlimited tonnage areas- safety and environmental subjects would reappear in the examination requirements- becoming increasingly more “involved” as one progresses higher up the ladder- but remove redundant training for the ratings…
Lastly- there needs to be a salient and sensible way to ensure that QA’s are undertaking assessments the way they are supposed to- not “pencil-whipping” for their buds- there must be development of a verification method to ensure total compliance with the regs- and make the penalties for “pencil-whipping” assessors- harsh enough to stop this practice… Also- there should be in depth, involved PRACTICAL ASSESSMENTS for ALL ratings and endorsements in the above 500T areas- deck plate level- on vessel only assessments- with random verification from flag state; I believe there are not enough PRACTICAL requirements to our licensing structure…
In closing- Not to seem offensive to our Brown Water Brothers and Sisters… the next part came personally to me from one of the “legends” in the OSV world- Horace Solar… a great man, a great engineer, a great manager and director- over lunch one day ( at Big Al’s in Houma) I asked him about skills, duties and general competency in the “limited license world”- he stated to me without any hesitation- that he thought that at that time, that the Captains and Mates were far superior in ship handling- but were generally unsuitable to sail aboard large deep sea vessels unless they sailed in far lower capacities for at least a year, about the engineers- he was way harsher- he called the average OSV “Chief” as being “Oil Change Chiefs” who would need considerable underway deep sea time to move over to the unlimited world… Some of this has probably changed a bit in these recent years- and not to fret- I often refer to the Deep Sea ROS Chiefs as “Shower Power Chiefs”!
Regarding licenses, I assume you are referring to the elimination of the exception for towing vessels in the oil and mineral industry under which they were not required to be licensed. That had nothing to do with Subchapter M. It was largely unknown until a Master shot and killed a deckhand. He could not be taken to suspension and revocation immediately because that requires a mariner to have been operating under the authority of the credential to be revoked. Since none was required on the vessel, his license could not be revoked absent a conviction for the homicide. The statute exempting those vessels from licensing was amended/withdrawn in 2010.
Not really JD, I think that the Towing requirements are fine (of course as you know being an Engineer I am not fully conversant in Deck subjects…)
As you’re probably aware, I believe that everything in the OCS and O/M Industry which moves anything from a US Port should be US Flag- Jones Act. I believe that is what will happen in the long term; therefore the Inspection and Credentialing should be to the highest attainable standard suitable for the service regulated.
How unfortunate regarding the Master/Deckhand incident- didn’t know about that one- My point of the whole “rant” is that there are too many different licensed endorsements- there must be some way to establish boundaries in order to “lighten the load” on the system as a whole and streamline the system.
I wasn’t aware that Mr Solar is now considered a legend. He was a smart man & did a fine job. I’m no big defender of GoM OSV engineers but I do fancy myself a reputable basher of Tidewater Marine operational & management policies. Mr. Solar worked for Tidewater Marine for 55 years & for many of those years it could be said the Chiefs were only filter changers because a filter wrench was the only tool provided by the company on many of the smaller, domestic OSV’s. I know because I worked for them for 10 years (25% of that time as C/E on the 2nd vessel named after Mr. Solar) & at the beginning of my tenor engineers were required to bring their own tools under 1 1/8". Tidewaters vessels were the simplest OSV’s ever built & not much was expected of the employees, office or from the clients that hired TDW boats. I’ve been on TDW boats that didn’t even have a crescent wrench or multi meter on board. Fast forward 20 years & I can tell you some of the DP2 & DP3 OSV’s are the most complicated pieces of machines on the planet. My family & I visited Kennedy Space Center in June, seen the Space Shuttle Atlantis & I was blown away by how simple that technology was compared to modern ship electronics. After working as 1AE on a fully automated DP3 construction vessel I know I could have been an engineer on a space shuttle because everything was toggle switches, open or close, thats it. 1990’s Tidewater OSV analogies are irrelevant in this conversation. I suspect a healthy double digit percentage of OSV engineers now are academy educated mariners who can easily work ashore anywhere they wanted.
When I sat for Master of Freight & Towing Oceans the only thing that was multiple choice was rules of the road, all else was essay questions. The examiner knew what he was doing. He did check my work and ask questions.
When I sat for First Class Pilot it was the same thing.
Those publications are in my haunted closet along with my old rock and roll 33 rpm records. That was a decent bookstore. And a good investment. Why did I know you were aware? Your pals went to the same place at the end of that strip mall. Getting closer to the mystery sir. Deepest respect Chief.
I’m not sure of the exact number, but I’d venture a guess that around 50% of the maritime grads don’t take an ABET degree path, and yes, they’d be better served doing a 2yr program like the old MEBA school. But status and snobbery requires all academies only offer a 4yr program (even though the less rigorous degrees should only be 2 years long). And, many of the grads would struggle greatly to pass the FE exam, and unlikely to pass the PE…but many won’t be allowed to take these in most states because they don’t have an ABET degree.
Moving on to original topic: The credential and skill testing system used for mariners is a complete joke. Not once does a license holder have to take a practical test. Ship drivers get licenses to drive ships without proving their skill. Engineers get licenses to operate without proving to an examiner they can operate. A worthless multiple choice exam that a monkey can eventually pass is considered good enough.
Compare this to the FAA and issuing of licenses to aircraft pilots. (for one thing, FAA licenses never expire*). But at every level of earning an FAA license, the candidate must GET IN THE DAMN PLANE AND FLY WITH AN EXAMINER!
And every two years a private pilot must do a flight review with an instructor. And the airline dudes usually have to go do simulator training every six months.
Yet mariners have zero practical examinations, zero recurrent training, and huge disparity in professionalism.
NOTE I would never expect the USCG to be able to administer a practical test system. But somehow, the FAA has managed to do a fairly OK job at it over the years (minus the occasional horror story).
True. The FAA does a better job but even then I have some concerns when boarding some of the smaller carriers. A few looked too young to have much experience. I have seen some of them grabbing food in airport restaurants and wondered if they burped each other before take off.
They may not have much experience or wisdom, but they at least passed a few tests where they had to FLY A FUCKING AIRPLANE lol. The military puts pilots with even less seat time in charge of fast and/or big planes.
Airline operations, even regional jets, is extremely procedural. These procedures are why it is statistically so safe in the USA. Go to Asia or Mid East, etc and the numbers aren’t so good.
I don’t ever see ship operations becoming as procedural as aviation. We take bullshit classes about bridge/ER resource management, but it’s just mental masturbation. I think John Konrad has some papers talking about making maritime operations more like aviation, but it will never happen. The players are too dumb, arrogant, close minded, and full of “muh tradition”.
I’m not a pilot but it is my understanding a candidate trying to get a FAA license has to own a plane, rent a plane, work for a company that owns a plane or have a buddy to borrow a plane from to take a flight exam. No way in hell can a 2nd mate show up at a REC with a rented ship to drive a USCG examiner around in a bay somewhere to demonstrate they’re suitable to upgrade to Chief Mate. I’m not showing up at a REC with a diesel engine on the back of a flat bed truck to take apart & reassemble to renew my license either. All the problems you described are addressed & solved with seatime requirements, approved USCG academies, approved USCG schools/courses & approved USCG onboard Qualified Assessors.
You guys trying to reinvent the wheel are hilarious. You’re now tied with @Slick_cam1 with his idea of having oral exams where the examiner & candidate are separated by a sheet using voice synthesizers for the funniest.