I see that there is an option to request an STCW exemption, but no real guidance on the process. Has anyone done this or know what the process is?
A little background, I help run a 110GT UPV intending to do weekly international voyages from Miami, Florida to the Bahamas. We are never more than 200 miles from US waters but yes enter international waters of the Bahamas. We have a crew of 4-5 with 10 passengers typically. With the current STCW requirements, we are lumped in with vessels of 500GT or less (Regulations II/3 and VI/1-4), and feel strongly that the STCW for Master less than 500GT NC requirements are excessive for our operation (specifically VI/2-4). We do not have Rescue boats (PSCRB class required), we don’t have enough crew to need to know how to assemble fire teams (Advanced fire fighting), and are never too far from the US that we couldn’t bring seriously injured individuals to advanced medical care in the US within a few hours (Medical care provider). All of our captains have taken Basic training (PSSR, PST, BFA/CPR, BFF) and we honestly feel that is sufficient for our operation. None of our captains have any intention of working on another vessel so aren’t worried about the restrictions an exemption would place on our licenses. We’ve all been here for 10-20 years and have no intention of leaving - unless this whole situation forces the owner to close up shop which is a real possibility. However is it possible to seek an exemption for a specific vessel or are exemptions only applied for individuals?
Anyone have any useful guidance on this? Thanks in advance!
Are you going to the Bahamas or just going through the waters of the Bahamas?
If you’re arriving into international ports then you have the issues of dealing with foreign PSC and the USCG can’t waive you out of requirements of the Bahamas.
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What does your local OCMI say.
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We are going TO the bahamas and we do have the approval and support of the senior deputy port controller of the bahamas. We are inspected annually in the bahamas for our foreign charter license and he’s prepared to write us a letter of support to submit to the sector Miami prevention department on our behalf.
Or have the company pay for the classes needed.
The USVI and Southern California Fishing Assoc. have lobbied the USCG for exemptions to travel to the BVI and Mexico (respectively) with some exceptions to STCW II/3 requirements. Both have been granted some degree of relief from the requirements.
You can find policy letters in the NMC site outlining both USVI and Southern California policy. They address what you are looking to do.
Having said that, this was an uphill climb and it happened over years not months to get headquarters to allow the changes. Local MSDs were supportive in both cases, but the folks higher up the food chain in DC were less so with mostly good reason.
The fact that Bahama authority may be willing to green light it is good. The biggest reason (I think) policy folks oppose this is PSC doesn’t have to agree with USCG policies in their countries. That may have been a factor in the USVI case, since BVI was pretty much already exempting their mariners from the same parts of the requirements.
Jim Cavo who is a frequent contributor here was a part of the policy changes for the USVI and Cali. He may be the best person here to weigh in.