The following is the latest update from Norleen Schumer at www.maritimelicensing.com
I have been reading and trying to digest the November 17th Federal Register, not an easy task at best, as I am sure you have noticed. Back in April of last year, I sent out an e-mail concerning a statement that NMC wanted placed on all sea service letters from Towing companies stating that:
In accordance with 46 CFR 10.209, ©(6)(ii), this mariner has completed ongoing participation in training and drills during the validity of the license being renewed.
Well now, in the new E-46 CFR, 10.209 (General Application Procedures) no longer reads like this. Now, you must look under 10.227 (Requirements for Renewal) where you will find two different ways of saying the above in your letters of sea service.
(A) In accordance with 46 CFR 10.227 (d)(8)(D)(vi)(A), this mariner has completed ongoing participation in training and drills during the validity of the license or MMC being renewed.
(B) In accordance with 46 CFR 10.227 (d)(8)(d)(vi)(B), this mariner has completed ongoing participation in training and drills during the validity of the license or MMC being renewed.
I have not received any word from NMC on how best to accomplish writing this up. But, I would probably say to you that the best way to cover your bases and your employees is to incorporate both of these statements in your letters of sea service if they are applicable of course. Please note that neither mention anything about providing anything other than these two items. Under the “old” 46 CFR 10.209 it was not stated either, but NMC wanted to see a completed TOAR at the time of renewal if the mariner did not meet 46 CFR 10.209 ©(6)(ii).
I don’t know if this information is helpful to you, but I just thought I would pass on, just one small item of interest. Please read E-46 CFR 10.209 and 10.227 for yourself just to make sure I have all my ducks in a row.
Thanks for everything and if I didn’t say so before, Happy New Year to each of you.
Norleen L. Schumer