I had heard that this was coming. I am assuming they would accept NI credential for any endorsement they may come up with.
This is excellent news. This absurd farce of allowing a foreign private club to control who is qualified to work in the US must end. The Nautical Institute has proven that its not up to the task, and there is no practical way to hold the NI accountable. In spite of its many shortcomings, the USCG will be a much more effective, responsive, and accountable DP regulator.
Hopefully, the only way to obtain authorization to be a DP Operator in the US will be as an endorsement to a USCG license. And hopefully, this will also mean the end of USCG waivers allowing foreign DP Operators to work in the US.
psquiggs - Good post. A bit of reading there. Comment period will end on Feb. 26, 2015.
Nothing is going to change. Read their recommendations below. It will simply be required now to have credentialed DPOs by the USCG instead of just by the clients underwriters. Pay attention to the part where it says they do not deem “licensing” necessary. Governments issue “license”. The NI simply gives you a competency certificate. Now you are just going to be required to submit for an additional endorsement (with application fee of course).
“In March 2012, we tasked the Merchant Personnel Advisory Committee (MERPAC) with reviewing the safe operation of dynamically positioned vessels operating on the U.S. OCS. MERPAC provided its recommendations in September 2012 (available in the docket by following the instructions in the “Viewing comments and documents” section above).
We considered the recommendations from both advisory committees in developing the training, manning, and watchkeeping standards in this NPRM. Both committees supported the three key recommendations summarized as follows:
Recommendation 1. DPOs should be credentialed but not necessarily “licensed.” If the DPO is not a licensed officer, a licensed officer of the navigation watch shall be provided, if required.
Recommendation 2. Minimum training should meet the standards found in the International Marine Contractors Association’s “The Training and Experience of Key DP Personnel” (International Marine Contractors Association (IMCA) M 117, Rev. 1, February 2006); and IMO Maritime Safety Committee Circular 738, “Guidelines for Dynamic Positioning System (DP) Operator Training” (MSC/Circ.738/Rev. 1, July 2006). In addition to meeting these training standards, further training and/or competency assessments should be required to ensure the proper performance of duties, and should be the responsibility of companies based on the DP system, vessel type, and service/activities.
Recommendation 3. Operational measures, including DP system and crew competency requirements, manning, and watch protocols should be based on risk assessments performed under a Safety Management System (SMS).
We agree with the first recommendation that the DPO must be a credentialed mariner, but need not be licensed. The DPO can also be the officer in charge of a navigational watch, provided the DP system and the navigational equipment are collocated, and the person is a qualified DPO who also holds the appropriate mate or officer endorsement.
We fully agree with the second recommendation.
Regarding the third recommendation, we agree with the adoption of operational measures, including the risk-based approach to DP system and crew competency requirements. Additionally, we partially agree with the recommendation that manning and watch protocols be risk based. Because a vessel operating under DP is considered to be underway, MODUs and other vessels using DP must comply with existing laws, regulations, and international requirements on manning and watchkeeping. However, the process to determine watchkeeping and manning protocols should account for the capabilities and limitations of each DP system and the nature of the operations of the vessel, including MODUs. Manning and watch protocols incorporating a risk-based approach would improve the safety of navigation on the U.S. OCS.”
[QUOTE=rigdvr;149019]Nothing is going to change. Read their recommendations below. It will simply be required now to have credentialed DPOs by the USCG instead of just by the clients underwriters. Pay attention to the part where it says they do not deem “licensing” necessary. Governments issue “license”. The NI simply gives you a competency certificate. Now you are just going to be required to submit for an additional endorsement (with application fee of course). [/QUOTE]
Since the Coast Guard doesn’t currently regulate DP, any current “requirement” to hold NI certifications comes from industry, i.e. owners and clients. They can still ask for this certification as a way of meeting relevant parts of the proposed rule or in addition to it.
Those us who would prefer to see DP certifications as a license issued by the USCG had better start commenting and writing to Congressmen.
We need a politically accountable US entity handling this, not a foreign private club that can change the rules anytime they feel like it.
I haven’t really read it word for word but I’m seeking like…many many years before anything changes if it does. Think subchapter m!
Anyone have the text of proposed 33 cfr 140.315 regarding DPO requirements? Iphone searches yield nothing.
[QUOTE=z-drive;149051]Anyone have the text of proposed 33 cfr 140.315 regarding DPO requirements? Iphone searches yield nothing.[/QUOTE]
It’s in the proposed rule. Apparently it is amongst those words you haven’t read yet. It’s about 3/4 of the way down.
[QUOTE=rigdvr;149019]It will simply be required now to have credentialed DPOs by the USCG instead of just by the clients underwriters. Pay attention to the part where it says they do not deem “licensing” necessary. Governments issue “license”. The NI simply gives you a competency certificate.[/QUOTE]
In Coast Guard speak a “credentialed mariner” is an AB/QMED as opposed to a “licensed mariner” who holds a Mate/Master license.
See quoted text below:
“Both the DPO and DPOQ must be mariners holding credentials as a rating forming part of the navigational watch, able seafarer-deck, operational-level deck officer, chief mate, master, a rating forming part of the engineering watch, able seafarer-engine, operational-level engineer officer, second engineer, or chief engineer, and must have completed the applicable DP system training set out in proposed 33 CFR 140.315.”
Though they do appear to accept the NI certificate as proof of training, they also allow other forms of proof. See below…
Proposed changes to 33 CFR:
§ 140.315 DP system training requirements.FONT=athelas-1 The Dynamic Positioning Operator (DPO) must receive training and practical experience in the operation of the dynamic positioning (DP) system and its components. The content of training and experience must include all provisions of paragraph (b) of this section, and the following:
(1) The DP system components, including the control station, power generation and management, propulsion units, position reference systems, heading reference systems, environmental reference systems, and external force reference systems, such as hawser tension gauges.
(2) The range of routine DP operations, as well as the handling of DP faults, failures, incidents, and emergencies, to ensure that operations are continued or terminated safely.
(3) The type and purpose of documentation associated with DP operations, such as operational manuals, Failure Modes and Effects Analysis (FMEAs), and capability plots.
(b) To be qualified to operate a DP system, the Dynamic Positioning Operator, Qualified (DPOQ) must have—
(1) Completed training that provides an introduction to the functions and use of a DP system;
(2) Completed 30 days of DP system training on board a vessel equipped with a DP system, including training on the design, components, related and integrated shipboard systems, system redundancy alarms, and warnings for that specific vessel’s DP system;
(3) Demonstrated thorough knowledge of the DP system operating manual for the specific vessel on which the DPOQ will serve, including procedures for shifting the DP system between all normal operational modes and emergency procedures. A DPOQ who will serve on a vessel engaging in Critical Outer Continental Shelf (OCS) Activities must also demonstrate thorough knowledge of the industrial mission, including the Critical Activity Mode of Operations, and either the Activity Specific Operating Criteria or Well Specific Operating Criteria as defined in 46 CFR 62.10-1.
(4) Demonstrated a fundamental understanding of the specific DP system’s FMEA and its implications; and
(5) Demonstrated familiarity with the vessel’s specific DP system, including participating in a walkthrough of the design and mechanical features with the DPO, to include at a minimum—
(i) Power generation;
(ii) Power distribution;
(iii) Thruster units and associated equipment;
(iv) Power management/logic; and
(v) DP system control interfaces and related electronics and computer functions.
© DPOs and DPOQs must carry the original copy of their DP system record of training or be able to provide such a copy to a requesting authority within 48 hours of the request.
(d) The Coast Guard will accept company letters, course completion certificates from a training institution, letters or course completion certificates from the DP system manufacturer, or certification from an industry-accepted organization as proof of DP system training.
(e) The owner or operator of a U.S.-documented seagoing vessel using a DP system to maintain station must maintain a copy of each DPO and DPOQ training record in accordance with 46 CFR 15.1107.
(f) All onboard DP system training must be documented in each mariner’s record of training in accordance with 46 CFR 15.1107.
(g) The master, officers in charge of a navigational watch, and DPOs must be familiar with the characteristics of the vessel and the specific equipment fitted on it prior to operating the equipment as required in 46 CFR 15.405. This[FONT=inherit]familiarization must include reading the DP system equipment and operations manual, DP system incident reports, FMEAs, and any documented history of the DP system. The familiarization must be documented.[/FONT]