Manila - effective date vs. early renewal

Heres what might be a stupid question…

The new renewal requirements for BT, Adv. Fire Fighting, and PSC state that they are required for the first license renewal after 12/31/16. My MMC will expire in March 2017. Normally I’d apply 4-6 months in advance in case of unforeseen problems or delays. If I submit for renewal in October 2016 like I normally would, am I correct in assuming that these renewal requirements wouldn’t apply to me and my license wouldn’t list any restrictions? Or since the actual expiration is after the effective date, the new rules would technically still apply?

I’ve already had the other 12/31/16 restrictions removed, so those shouldn’t be an issue.

Chances are also that my company will send us all to the renewal classes anyhow, but I’m just curious. First time I’ve been part of any major grandfathering/transitional process.

That sounds like a good question. I do not know the USCG answer.

I have been told that Transport Canada during port state control inspections requires certificates issued within five years for those courses.

[QUOTE=wafinator;139587]Heres what might be a stupid question…

The new renewal requirements for BT, Adv. Fire Fighting, and PSC state that they are required for the first license renewal after 12/31/16. My MMC will expire in March 2017. Normally I’d apply 4-6 months in advance in case of unforeseen problems or delays. If I submit for renewal in October 2016 like I normally would, am I correct in assuming that these renewal requirements wouldn’t apply to me and my license wouldn’t list any restrictions? Or since the actual expiration is after the effective date, the new rules would technically still apply?

I’ve already had the other 12/31/16 restrictions removed, so those shouldn’t be an issue.

Chances are also that my company will send us all to the renewal classes anyhow, but I’m just curious. First time I’ve been part of any major grandfathering/transitional process.[/QUOTE]

We haven’t worked out details of when the clock stops on the deadline, but in the past we considered an application that met all requirements for the endorsement applied for that was submitted before the deadline to have been timely even iif it was not processed and issued until after. It’s likely we will do the same with the 2017 and 2019 deadlines for the new rules.

It’s now possible to renew at any time, and since the refresher requirements for BT, PSC, and Advanced FF are for the first renewal after 12/31/2016, the refresher requirements can be delayed by renewing early. I plan to renew my own MMC early for this reason. This only works for the refresher requirements. For the Leadership and Teamworking/Managerial Skills requirement (and for engineers, ERM and electric and electronic control equipment) if you renew early and don’t have it, your STCW endorsements will say they aren’t valid after 12/31/2016, even if the MMC they are in expires at a later date.

Thanks for that Mr. Cavo. Seems like an easy sidestep of the new rules and that’s what made me question it, but I suppose the line must be drawn somewhere. I could see the logic in either scenario.

Right about the other restrictions. I upgraded last year and that 12/31/16 popped up next to my OICNW (along with all the new STCW verbiage). I’ve been warning coworkers with older tickets that they all have the same restriction too, it just had not been printed at the time there MMCs were issued.