[B]I have attached a copy of my letter to my Senator on this matter which will have FAR REACHING impact on the Licensed Mariner community. PLEASE HELP by contacting your congressperson on this matter. [/B]
[B]************************ [/B]
[B]Senator Olympia Snowe February 17, 2010 [/B]
[B]154 Russell Senate Office Building [/B]
[B]Washington, DC 20510 [/B]
[B]RE: [/B]
[B]NPRM: Implementation of the 1995 Amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 [/B]
[B]Dear Senator Snowe: [/B]
[B]The USCG is considering sweeping changes concerning the licensing of merchant mariners. These changes are far reaching and will impact the ability of many mariners including myself to earn a living as Officers, Engineers and Merchant Seaman on U. S. Flagged vessels. [/B]
[B]The rational of the USCG for these sweeping changes is for the United States to comply with the requirements of the above referenced international agreement of which the United States is a signatory. I do not believe that the congress was fully informed of the consequences to our merchant mariners of ratifying this agreement. [/B]
[B]The U.S. maritime fleet is comprised of many vessels performing diverse functions in conditions and under work rules that are unlike what is done in other countries. As a result, the international regulations being imposed upon us will result in the inability of many mariners to progress in their careers through hard work, study and merit. [/B]
[B]I respectfully request your assistance in causing the USCG to “re-think” their approach to these mariner license changes and to modify their proposed regulations in a manner that will more closely reflect the needs and career paths of our country’s Merchant Officers, Engineers and Seamen. [/B]
[B]I would personally be willing to serve on any “study group”, testify to congress or work with the USCG to improve the outcome of their proposed regulations. [/B]
[B]Sincerely, [/B]
[B]Capt. Michael E. Kiernan [/B]
[B]Attachments: Copy of my comments on the Proposed Rulemaking. (2 files) [/B]
[quote=CaptMike04530;27255][B]I have attached a copy of my letter to my Senator on this matter which will have FAR REACHING impact on the Licensed Mariner community. PLEASE HELP by contacting your congressperson on this matter. [/B]
[B]************************ [/B]
[B]Senator Olympia Snowe February 17, 2010 [/B]
[B]154 Russell Senate Office Building [/B]
[B]Washington, DC 20510 [/B]
[B]RE: [/B]
[B]NPRM: Implementation of the 1995 Amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 [/B]
[B]Dear Senator Snowe: [/B]
[B]The USCG is considering sweeping changes concerning the licensing of merchant mariners. These changes are far reaching and will impact the ability of many mariners including myself to earn a living as Officers, Engineers and Merchant Seaman on U. S. Flagged vessels. [/B]
[B]The rational of the USCG for these sweeping changes is for the United States to comply with the requirements of the above referenced international agreement of which the United States is a signatory. I do not believe that the congress was fully informed of the consequences to our merchant mariners of ratifying this agreement. [/B]
[B]The U.S. maritime fleet is comprised of many vessels performing diverse functions in conditions and under work rules that are unlike what is done in other countries. As a result, the international regulations being imposed upon us will result in the inability of many mariners to progress in their careers through hard work, study and merit. [/B]
[B]I respectfully request your assistance in causing the USCG to “re-think” their approach to these mariner license changes and to modify their proposed regulations in a manner that will more closely reflect the needs and career paths of our country’s Merchant Officers, Engineers and Seamen. [/B]
[B]I would personally be willing to serve on any “study group”, testify to congress or work with the USCG to improve the outcome of their proposed regulations. [/B]
[B]Sincerely, [/B]
[B]Capt. Michael E. Kiernan [/B]
[B]Attachments: Copy of my comments on the Proposed Rulemaking. (2 files) [/B][/quote]
Can you post a copy of your comments?
Thank you for your post Captain,I also feel that Mariners in general should get more involved and actively participate in the direction that our industry is going.I commend you for your initiative,and I am interested in your opinion about the changes.
As you know the full implementation of the STCW 95 has been pending for the last 15 years,so this has been a long time coming.
As we all know this will require more classes and expense for Mariners to upgrade, but I am interested if you find any specific objections to the rule changes other than that.I’m really not trying to stir the pot,but genuinely interested in what you feel the farther reaching implications to this might be.
Some of you have requested copies of my comments to the USCG rulemaking process on this matter. Since gcaptain has file size limits, I cannot upload here. However, I am listing BELOW the LINKS to my google docs files so that you can view my comments and other relevent information on this important matter.
I hope that this information will give my fellow licensed mariners the background necessary to CONTACT YOUR MEMBERS OF GONGRESS and ask that this proposed rule be “re-thought” by the USCG in order to reflect more accurately the actual working conditions faced by todays active Mariner.
Please feel free to comment or call on me directly to discuss this important matter further.
Capt Leigh - You will note that I have added some LINKS to this thread for further clarification on this matter.
In short, the proposed rule is inherently in conflict with the day to day working life lead by U.S. Licensed mariners. The rules are designed for the USCG to operate a “one size fits all” licensing scheme that will disenfranchise most of the active mariners from further advancement in their careers. The premise of the scheme is a 4 officer wheel house, when most U.S. Licensed mariners are working and gain their experience in a 2 officer wheelhouse.
This is just ONE key deficiency of this rulemaking.
Captain Mike,thanks for your response,and the links to your comments.
I found your arguments valid and responses well thought out,some of which had not occurred to me regarding the Canadian transits.
I had heard that the full implementation was soon to go into affect,and scrambled to get my 500 ton masters ticket also.
That was 2006.
I think your most valid point was the fact that the comment period was far too short.
I suspect that that and the timing of the NPRM was not an oversight,and was completely intentional on the part of the powers that be,to eliminate any sort of organized opposition to the changes,especially on the part of the maritime companies.
Unfortunately the fact that this has been pending for virtually fifteen years will not help your position,and I suspect after the comments are reviewed this will be in force very quickly.
It will undoubtedly drive up the wages of Mariners who meet the criteria,or are grandfathered in,and eventually the maritime companies will be forced to subsidize training or bring it in house as Edison Chouest does.
Well, I have never worked on a civilian vessel, though I was a sonar tech on a nuclear submarine. I have been interested in becoming a Merchant Mariner, Ordinary Seaman, for a while. How do these changes impact me?
I don’t have that much money right now (I’ve been stuck in the same minimum wage job for 3 years now!!! very frustrating, hence the interest in going to sea).
I may sign up for Military Sealift Command at this point…I’m not sure if that is an at-will job or if you have to “enlist” for a certain period of time, like the USN.
Brian,
Down the road there are more and more schools costing more and more money. MSC IS at will. Get your TWIC, entry lever MMC (OS/Wpr/SD (FH)) and apply to them. They have advancement programs and they pay for the training. They have an entry level position open now. Get what ya can from them and move up or move on if you’re so inclined http://www.sealiftcommand.com/wp-content/uploads/2010/02/Supply-Utilityman-JOA10-848-02EX-_3_1.pdf
Cheers, QMC(SS)