Modernizing USCG Exams

Professional Mariner Forum
61

Yes and no.

Usually it’s an operator error, you can buy and download the charts, and at least on Wartsila they might not show up unless you install the licenses separately, It’s not exactly intuitive and has fooled me in the past.

These chart provider programs like One Ocean are pretty robust, it’s like 90% offline. But if you can’t get updates, I don’t think you can get new charts, but I’ve had this work in pre-starlink era, so it’s not the most data hungry, especially when you’re only looking for one port. I mean if the antenna gets blown off the roof completely, When we’re In port I’ll just hotspot the computer from my phone and not tell anyone.

But yeah, worst case scenario you’ve lost internet and your only option is to deviate to Puerto Cabello and you don’t have the charts for it, you’re out of luck. Chances are you’d be out of luck if you were on paper too.

But in the US, I keep a personal backup of the ENCs which can be loaded into an ECDIS or ECS with no license, because they are free, and while they might not be up to date they’re probably close enough for an emergency. I Also keep Open CPN and a GPS for my tablet just in case everything does go to hell, because I for one would like to get home.

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62

Text of the bill is now online.

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63

As noted in this thread everyone has their own perspective as to a possible need to amend 46 U.S. Code § 7510 to Modernize Coast Guard’s Merchant Mariner Credentialing System.

However, does anyone really think that the introduction of another amended piece of legislation will correct the multiple layers and issues within the current credentialing system at the National Maritime Center (NMC)?

My general observation and concern is that without in-depth compliance oversight and aggressive enforcement system for non-compliance accountability, there is no motivation for a change at the federal, corporate, or operational level within the maritime industry.

A partial foundation for my position begins with the overview of the National Maritime Center by DHS Office of the Inspection General, OIG-24-08, December 18, 2023, Final Report for the period July 2022 to March 2023.

USCG National Maritime Center’s Oversight of Merchant Mariner Training and Examinations

Each regulatory non-conformity identified OIG-24-08 pertaining to certain credentialing fraud or unqualified mariners who can subvert credentialing rules reflects a breach of the validity of those qualified mariners serving in specific shipboard roles and duties as described in 46 CFR Parts 11,12,13, 15 and the overall Maritime Credentialing process.

If the Maritime Credentialing process has been compromised at the examination level then one can only expect a ripple effect throughout the entire marine industry thus creating systemic issues as described in MSIB 01-22 Ensuring the Validity of Merchant Mariner Credentials and Endorsements and with 46 CFR 15.401 Employment and Service within Restrictions of Credential.

The above scenarios described in OIG-24-08 should lead to corporate and shipboard management questioning every crew member’s fundamental marine knowledge, skills and the validity of the National and International license or endorsement qualification they hold.

Especially at the support and operational levels where some endorsed National Able Seafarer – AB Unlimited cannot perform the professional competencies helmsman and the related commands or where certain mates that cannot demonstrate or perform bridge task competencies as outlined in 46 CFR 11.910 Table 2 for their professional licensure.

My observation seems to follows statements made in this thread and other threads regarding a mariner holding a license or endorsements that can not provide assurance of professional competencies required for the position.

A natural response to ensure professional competencies would be to engage, evaluate and subject crew members to demonstrate the normal hands-on shipboard competencies. Along with the demonstrations I recommend that these OJT shipboard professional requirements be incorporated into the company mariner record keeping in accordance with 46 CFR § 15.1107 Maintenance of merchant mariners’ records by owner or operator.

The process of utilizing document requirements outlined above would be consistent with objective evidence outlined in 46 USC 32Management of Vessels and 33 CFR 96. A sign-off procedure was first described in NVIC 5-97 Guidance on Coast Guard Accepted Training Record Books and follow on in the STCW Code and USCG STCW NVICs.

64

Wouldn’t it be easier and better to adopt IMO STCW 2010 Regulations (with November 2016 Amendment) as the full and only credentials required by US seafarers, whether serving in foreign or domestic trade and type of vessel?
Are there any need for more specific types of certificates, other than as defined here?:

  • List of Certificates or Documentary Evidence Required Under the STCW Convention

The list also references the relevant regulations and the requirements for endorsement, registration and revalidation.

Regulations* Type of certificate and brief description Endorsement attesting recognition of a certificate 1 Registration required 2 Revalidation of certificate 3
II/1, II/2, II/3, III/1, III/2, III/3, III/6, IV/2, VII/2 Certificate of Competency - For masters, officers and GMDSS radio operators Yes Yes Yes
II/4, III/4, VII/2 Certificate of Proficiency - For ratings duly certified to be a part of a Navigational or engine-room watch No Yes No
II/5, III/5, III/7, VII/2 Certificate of Proficiency - For ratings duly certified as Able Seafarer Deck, Able Seafarer Engine or electro-technical rating No Yes No
V/1-1, V/1-2 Certificate of Proficiency or endorsement to a Certificate of Competency - For masters and officers on oil, chemical or liquefied gas tankers Yes Yes Yes
V/1-1, V/1-2 Certificate of Proficiency - For ratings on oil, chemical or liquefied gas tankers No Yes No
V/2 Documentary evidence - Training for masters, officers, ratings and other personnel serving on passenger ships No No No4
V/3** Certificate of Proficiency - training for masters, officers, ratings and other personnel on ships subject to the IGF Code No Yes Yes8
V/4** Certificate of Proficiency - for masters and officers on ships operating in polar waters No Yes Yes
VI/1 Certificate of Proficiency5 - Basic training No Yes Yes6
VI/2 Certificate of Proficiency5 - Survival craft, rescue boats and fast rescue boats No Yes Yes6
VI/3 Certificate of Proficiency5 -Advanced fire fighting No Yes Yes6
VI/4 Certificate of Proficiency5 -Medical first aid and Medical Care No Yes No
VI/5 Certificate of Proficiency - Ship security officer No Yes No
VI/6 Certificate of Proficiency7 - Security Awareness training or security training for seafarers with designated security duties No Yes No

STCW Table B-I/2 PDF

*See STCW regulations here
****V/3 & V/4 is a Part B amendment of November 2016**I

Source: https://www.edumaritime.net/stcw-code/stcw-table-b-i-2-list-of-certificates

PS> At the same time adopt the GT/NT system for ALL vessels. That would simplify the whole process and avoid complication when a US-flag vessel visit foreign ports.

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65

Point taken. Once all the conversations are over; I believe what you purpose will be the standard.

The blending of Domestic and International regulations are slowly being implemented. The example is the slow creeping of Safety Management Systems voluntarily into domestic regulations. 46 USC 32, 33 CFR 96, and 46 CFR 138 TSMS.

The question for the adoption of the STCW code into domestic regulations will not be the shipboard assessments but the resistance to the cost of the required courses for each professional level.

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66

The concept of adopting the IMO STCW licensing scheme and migrating to International tonnage makes very good sense.

However, there are a number of political and practical hurdles.

There are something like 50,000 USCG credential holders. The vast majority of these are local “home trade” only credentials for vessels under 100 GRT.

The USCG is incapable of handling its existing workload, much less adapting to a major change like this without utter chaos, massive delays and total collapse.

US vessel owners have invested $$$ billions in the current US “Regulatory Tonnage” system with all its absurd exceptions to any form of sane tonnage measurements and requirements. It’s a beast that is the product of lobbying and campaign contributions.

As it is now, there is a “shortage” of mariners willing to work for current wages and working conditions, and accept living a drug free life with drug testing.

The great majority of US credential holders, especially Inland mariners, “small” passenger vessel mariners, and tugboat mariners do not have STCW endorsements.

The only practical way to make a change to STCW type CoCs would be to “grandfather” all existing mariners into STCW credentials without the need to take the courses, take exams, do assessments, or actually meet STCW standards.

Although I have misgivings about grandfathering tens of thousands of mariners into STCW, I could live with it.

Next, all US vessels under 1600 GRT / 3000 GT would need to become dual tonnage. Keep the existing “regulatory tonnage” for inspection and manning requirements, but use international convention tonnage for mariner licensing.

As a practical matter, a feasible approach would be to make no changes for Inland vessels, or for most vessels under 100 GRT. This would make most US vessels and the great majority of US mariners exempt from STCW.

Applying the new international tonnage scheme only to new vessels would unduly discourage the replacement of 50 year old junk with new vessels. We need to encourage modern new vessels, not discourage them.

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67

you mean 100% reliant on gps which is so easy to spoof and you wont know if not using another form of navigation?

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68

How many times you been spoofed and needed cel nav to get home?

69

luckily the ocean is full of cell towers so that works,lol

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There are Multi-GNSS receivers available on the market.
If you are spoofed on the GPS frequency, switch to another system.

PS> Of course there are also multi-frequency spoofing:
https://rntfnd.org/2018/06/19/easily-spoofing-them-all-at-once-inside-gnss/

71

its not how many sats you can see its the weak signal hence why its so easy to spoof

72

You are right, it doesn’t matter how many satellites is available on one system, but how many systems you are able to receive signals from and on different frequency.

BTW; It is not only spoofing that you have to consider, but also if the system(s) you rely on can suddenly be shut down, (for security reasons, or whatever)

PS> I go back long enough to remember when GPS signals were scrambled for civilian users.

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73

Yup, and all it takes is effectively a flip of a switch to put that error (or more) back in the system.

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74

I always thought it was akin to moving lighthouses around on rails to make a visual bearing inaccurate. With GPS and RTK or DGPS lettuces can be planted accurately to within a centimetre and what’s more important they can be harvested automatically.

75

until that gets spoofed and we starve

76

The tolerances are such that CME will do that.

77

I am not making the argument that the use of paper charts should be continued, With the exception of a few edge cases ENCs are clearly far better then paper charts.

Plotting sheets and charts can both be improvised on-board so that fact that they are not carried is not necessarily good evidence of the reliability of ENCs and also related to the discussion of the continued relevance of terrestrial navigation skills.

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78

Back long before we had any agony of choice between ENC and paper charts, I was Ch.Off. on a ship waiting on order in Shimonoseki, Japan, (1968)
Then we were told to proceed to Lae, PNG and on to Sydney, NSW to enter into a time charter for Karlander New Guinea Line (KNGL)

We had no charts for the route, or for the waters of PNG and none were available locally. A Greek ship gave us a chart of the entire Pacific Ocean (IIRC: BA 5000)
We also managed to get an Australian chart that covered the area from Manus Island to Lae. No plotting charts were available either, but we had the set of BA charts we had used for the voyage from Singapore to Japan.

The solution chosen by the Master was to take the shortest route and use the China Sea charts as plotting charts, changing the Longitude to suite.
Islands and reefs found on the Pacific Ocean chart along the route was drawn as large square on the relevant SCS charts, with good margin for error.

We made it to Lea, where we could buy charts for the rest of the voyage to Sydney, via Brisbane.

PS> We reaching Sydney within hours from the ETA given on departure Japan.
(No SSB, so limited communications on the voyage)

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79

It’s great for watching a solar eclipse…

80

This makes sense.
My guess is the vast, vast majority of USCG licences are OUPV six-packs. You can’t swing a stick in a Florida bar without hitting 10 of them. I don’t know much about SCTW, but see little need for them to be SCTW compliant, under the constraints of their license (6 passengers, uninspected vessels). Changes to their testing could be handled separately.
Grandfathering SCTW compliance makes sense for mariners with a TOAR.
Which leaves passenger ships and shipping. Making the jump from 100T Master to 500 or higher is next to impossible. Two different training and experience tracks.
Tonnage… wow. Companies I work for have 2 deck Subchapter T boats of 63 tons, and Subchapter K boats of 4 decks and double the passengers at 51 tons. Insane. This definitely was done to allow cheaper crews on boats that are not fundamentally different from many Subchapter H boats (over 100T).
If redesigning testing and training, it help to be based on Subchapter boats rather than tonnage.