Mr. Cavo or anyone else

Professional Mariner Forum
21

[QUOTE=Johnny Canal;140842]you clearly didn’t get the point of my post / rant.

i don’t know how to lay on the scathing sarcasm any thicker.[/QUOTE]

Yeah looks like I took it wrong for sure, sorry I don’t usually look for the smart ass egotistical point of view in everything I read right out the gate.

Some of us have not been in the oilfield or any other position to need this BS piece of paper and have not been notified by our employers of any such need either. I for one was working a foreign vessel for the last 11 years for the same company and have not heard of it until I started looking to make myself marketable to switch my career to the oilfield work boats. Through researching what I thought I needed, (safe gulf, rigger, RFPNW, BST, etc.) I had this pop up as something I may as well apply for as it appeared to be only a company letter and proof of the time for the issuance. I referred to not only the threads but more importantly the Policy Letters and felt that I followed them as directed. I have been successful in adding most everything noted except this one.

I don’t care that you feel almighty that you have had your VSO for 9+ years, good on you, just trying to put my experiences with the process out there to help others that may be trying to use the same letter that has been recently posted here for us to supposedly have our companies sign and be able to receive the damn sticker so we can be up to date. And hopefully find out what the proper “verbiage” should be in the content of said company or Master’s signed letter.

I’m a do’er not a procrastinator, and furthermore I’ve been an EMPLOYED professional mariner for 37+ years. I came off my job of many years and within a totally different field of sailing after I had made my mind up in January to start working towards my goal of retiring closer to home on the Oil Patch work boats, went and got my BST in April, had my RFPNW done, came home two weeks ago (3 tomm.) did Radar/original, SafeGulf, MRO, Rigger first two weeks home and hired on tuesday with the first job offered (crew boat) to make the transition in order to achieve my goals. Do not generalize me sir, save that for people you know.

So back atcha!, lay your belittling shit on all you want.

22

I see what you’re saying but how does that change anything about having to apply before march of 2014 in order to qualify under those requirements?

23

[QUOTE=roundabout;140804]Would this email for “RECONSIDERATION” automatically take it to appeal or only elevate it above the current evaluator? I would rather try and get another letter than start an appeal at this time in other words.

as I read Policy Letter No. 12-06, since my seatime towards VPDSD was before March 2014 and have the recent time required also my letter on a company letter head signed by the owner of the vessel should qualify me for VPDSD. I used the exact wording as was successfully used by others here and was emailed by NMC for more info requested. When I called this morning to NMC I was advised my letter no longer sufficed & to see, CFR 33- 104.220, which contained no pertinent info on this. I do not see another NVIC (Policy Letter) on changes, could you advise to an updated policy letter pertaining to this application please.

also question the “verbiage” of the highlighted area of this NVIC 02-14 concerning transitions and grandfathering:

Any clarity would be a great help?

Thanks

      • Updated - - -

Just asked Mr. Cavo if this took it to appeal, somehow missed your post here. May well be worth it since I’m not in a hurry on this one for a change.[/QUOTE]

Sorry for the late and short response, I’m on vacation until August and not checking in too often. I’m responding from a pub in Wales waiting for dinner to arrive.

Reconsideration is the first level of appeal. You can’t appeal to hq until you have been through the reconsideration process.

Not sure what the question is on the highlighted language. Began service… Is explained in the grandfathering NVIC, generally it means that if you got one day of the service needed for what you apply for, you began the service on that date. Sounds like your VPDSD time meets that.

By the way, I have been trying to get NMC to stop using “verbiage” I am not sure they know that it means confusing and verbose (I was in Stratford upon Avon yesterday, so I will quote Shakespeare to define it. “You speak an infinite amount of nothing.”

24

[QUOTE=jdcavo;140859]Sorry for the late and short response, I’m on vacation until August and not checking in too often. I’m responding from a pub in Wales waiting for dinner to arrive.

Reconsideration is the first level of appeal. You can’t appeal to hq until you have been through the reconsideration process.

Not sure what the question is on the highlighted language. Began service… Is explained in the grandfathering NVIC, generally it means that if you got one day of the service needed for what you apply for, you began the service on that date. Sounds like your VPDSD time meets that.

By the way, I have been trying to get NMC to stop using “verbiage” I am not sure they know that it means confusing and verbose (I was in Stratford upon Avon yesterday, so I will quote Shakespeare to define it. “You speak an infinite amount of nothing.”[/QUOTE]

Thanks for the response and the good laugh! The “verbiage” in the highlights is kinda of, well, confusing and verbose and was exactly what I was wondering about. In Policy Letter 12-06 I thought it was fairly clear. Thanks again and enjoy your vacation, great time to be there indeed.

25

[QUOTE=z-drive;140852]I see what you’re saying but how does that change anything about having to apply before march of 2014 in order to qualify under those requirements?[/QUOTE]

This is exactly where I am confused as in NVIC 02-14 this is put like so:

Until March 24, 2014, mariners who commenced approved seagoing service prior to
January 1, 2012

all the while both this NVIC and the new FAQ sheet just put out both point to the NVIC 12-06 as to how this applies which is simply saying if you have 1 day of sea service in the capacity before Jan. 1, 2012 then this is the criteria same as the above quoted NVIC 02-14’s criteria with the exception of this first verbiage. I truly believe the “Until March 24, 2014” should not be a part of this? And was my basis for seeking Mr. Cavo’s input before asking for reconsideration. Although he’s probably had a good pint or two waiting on dinner, I think he was clear on what I need to do and I shall follow up with an email to my evaluator for “RECONSIDERATION” attaching the NVIC 12-06 and the new FAQ sheet that is just posted and dated 7/7/14 and go from there. Hopefully providing him with his or her’s own policy letter and FAQ sheet will make them aware of what the current criteria actually is. Though highly unlikely and more than likely bound for appeal. We shall see.

12-06 is clear:

Alternatively, mariners who
commenced sea service prior to January 1, 2012 may apply for an endorsement under
this policy by providing documentation attesting to one of the following:

26
  1. Until March 24, 2014 (not after), mariners who commenced approved seagoing service prior to
    January 1, 2012, may apply for an endorsement as VPDSD by showing one of the
    following:

The part I’m saying is the “may apply for an endorsement as VPDSD by showing one of the following.” Not arguing here but my take is that it means that IF you applied before march 24 (you didn’t), with the days before 2012 (you do) then you may get it by showing one of the following. You have to meet both requirements, so it appears. I could be entirely wrong and hope your reconsideration is successful but that’s what i take the regulations to mean.

27

I read through the FAQ again, since they haven’t updated it I would think you’d need to hammer them on the issue. How can they hold you to requirements that aren’t published or listed anywhere? The updated “faq” doesn’t cover it. As its written though you shouldn’t qualify as you applied after the cut-off date, but they haven’t seemed to have provided alternative requirements for those applying after.

I’d mention:

  1. Can you please confirm that the deadline for the requirement to obtain the VSPDS
    endorsement has been extended to March 24, 2014?
    Policy Letter 12-06 is still the current guidance on security endorsements until March 24, 2014.
    International requirements to hold the endorsements by January 1, 2014, are still effective. We
    intend to provide updated guidance in a NVIC after March 24, 2014. [B](well where is it NMC?)[/B]

  2. (ADDED 07/07/14) What must the submitted as “documentary evidence of
    meeting the requirements” mentioned in 46 CFR 15.1113©? My company is a USCG
    certified VPDSD course provider and we give the students the required
    certificate/documentation to meet this statement. However, how else can a mariner
    meet the documentation requirement? Can an employing company simply give them
    a piece of letterhead that says “John Smith meets all the requirements set forth in 33
    CFR H 104.225” without physically demonstrating 104.225 (a) - (n), certified by the
    Company Security Officer (CSO)?
    To qualify for an STCW endorsement as VPDSD, a mariner must present satisfactory
    documentary evidence, such as a certificate or letter signed by a company official.

[B]So what the hell was the march 24 date all about then? This is a confusing one.[/B]

I think the advice given asking for a reconsideration is your best bet, otherwise I would put together a very concise document to send to your evaluator. List the exact parts of the NVICs and how they apply/dont apply/how you think they should apply. See what they say. I’ve dealt with an issue or two with an evaliator that way rather than dick around with a reconsideration. Idea is to make it brain-dead simple and clear what your issue is and why it should be handled a certain way. I’d say yeah, I applied after march 24 2014, BUT WHERE THE HELL DOES IT SAY WHAT THE REQUIREMENTS ARE?

Personally…I’d just go take VSO course in this case and come out with a potentially better endorsement in the long run.

That’s all just advice from a tugboat guy, I am obviously no expert, and have been wrong about plenty of things but that seems to be the deal.

28

Pretty good advice z and thanks for your input. Of course it would be nice to do the VSO and get it over with, but since January I’ve spent a bunch on schooling, enough already for a while and since I feel I qualify under NVIC 12-06 and the Grandfather/Transitional part of NVIC 02-14 (and it is free), I think I agree with you and will ask the evaluator to email me a copy of my letter they mailed requesting the info as I am offshore for another 3 weeks and see if I can get a reasonable back and forth with him/her on it before the reconsideration letter. I received my RFPNW just before I came to the vessel last week which was all the assessments signed off on, and under the same NVIC’s (after March 24, 2014) which seems way more entailed, however the damn VPDSD has it’s own separate little language for some stupid reason. Anway, Im sending an email as instructed by NMC to attention evaluator tonight and will be standing by.

Keep you posted on happenings.

Thanks again…

29

[QUOTE=z-drive;140566]The single biggest thing that gets me is that if they need more information, you don’t know what they need until you get a letter in the mail. Why not just have this info online or in an email?.[/QUOTE]

That also has bugged me. Why can’t they email their request for information as well as send a paper letter?

30

Here goes a long reply.

Lets start with 46 CFR:

§12.625 Requirements to qualify for an STCW endorsement as vessel personnel with designated security duties.

(a) An applicant for an STCW endorsement as vessel personnel with designated security duties must—

(1) Present satisfactory documentary evidence, such as a certificate or letter signed by a company official, or a certificate of completion from a Coast Guard-accepted or Coast Guard-approved course, of meeting the requirements in 33 CFR 104.220;

(2) Meet the physical examination requirements in 46 CFR Part 10, subpart C; and

(3) Meet the safety and suitability requirements and the National Driver Registry review requirements in §10.209(e) of this subchapter, unless the applicant has met these requirements within the previous 5 years in connection with another endorsement.

(b) Until March 24, 2014, seafarers will be able to apply for an endorsement as vessel personnel with designated security duties by—

(1) Having completed approved seagoing service with designated security duties, for a period of at least 6 months in total during the preceding 3 years;

(2) Having performed security functions considered to be equivalent to the seagoing service required in paragraph (b)(1) of this section; or

(3) Successfully completing Coast Guard-accepted or Coast Guard-approved training.

Followed by 33 CFR:

§104.220 Company or vessel personnel with security duties.

Company and vessel personnel responsible for security duties must maintain a TWIC, and must have knowledge, through training or equivalent job experience, in the following, as appropriate:

(a) Knowledge of current security threats and patterns;

(b) Recognition and detection of dangerous substances and devices;

© Recognition of characteristics and behavioral patterns of persons who are likely to threaten security;

(d) Techniques used to circumvent security measures;

(e) Crowd management and control techniques;

(f) Security related communications;

(g) Knowledge of emergency procedures and contingency plans;

(h) Operation of security equipment and systems;

(i) Testing and calibration of security equipment and systems, and their maintenance while at sea;

(j) Inspection, control, and monitoring techniques;

(k) Relevant provisions of the Vessel Security Plan (VSP);

(l) Methods of physical screening of persons, personal effects, baggage, cargo, and vessel stores; and

(m) The meaning and the consequential requirements of the different Maritime Security (MARSEC) Levels.

(n) Relevant aspects of the TWIC program and how to carry them out.

Therefore, I would surmise that a letter simply saying that you have served onboard with designated security duties will no longer suffice and since they haven’t given any way of proving you meet the competencies listed in 33 CFR other than a course you may be SOL. [Hopefully they come out with assessments the master can sign off for people.]

If you are still in contact with your old company you can take a flier and have the CSO write a letter on company letterhead saying something like:

“John Doe has worked on our vessels from xx/xxxx to xx/xxxx and undergone onboard training, drills, and exercises that meet or exceed all the requirements in 33 CFR 104.220.”

or "John Doe has worked on our vessels from xx/xxxx to xx/xxxx and been trained in and proven competent in the following:

(a) Knowledge of current security threats and patterns;

(b) Recognition and detection of dangerous substances and devices;

© Recognition of characteristics and behavioral patterns of persons who are likely to threaten security;

(d) Techniques used to circumvent security measures;

(e) Crowd management and control techniques;

(f) Security related communications;

(g) Knowledge of emergency procedures and contingency plans;

(h) Operation of security equipment and systems;

(i) Testing and calibration of security equipment and systems, and their maintenance while at sea;

(j) Inspection, control, and monitoring techniques;

(k) Relevant provisions of the Vessel Security Plan (VSP);

(l) Methods of physical screening of persons, personal effects, baggage, cargo, and vessel stores; and

(m) The meaning and the consequential requirements of the different Maritime Security (MARSEC) Levels.

(n) Relevant aspects of the TWIC program and how to carry them out."

Either of those or a combination of both might be enough. Your best bet is to just take VSO though, you will need it eventually anyway.

31

I Posts this a while back but here it is again…

All you need for the endorsement is a letter, signed by the captain, with the Official number and ships stamp.

It should read,
Re: (Name) (MMC #) letter of documentary evidence for stcw endorsement as Vessel Personnel with Designated Security Duties. (VPDSD)

In accordance with Policy Letter USCG-CG CVC Policy letter No. 12-06 (5)(f)(2) this individual has seagoing service on this vessel. This individual has had designated security duties in the vessel security plan and / or noted on our vessel security station bill for a period of (insert total) months from (sign on date to off date).

Signed by the Master with his MMC number and ships stamp. STCW endorsement is free. Sent mine in a week and half ago and just got it back.

Of course, as pointed out earlier in the thread, if you already have VSO, they’ll add it for you without the letter. If you don’t have time to take VSO, this is the way to go.

Cheers

32

Except that that only worked if you applied before march 24, 2014, hence the whole point of the last 20 posts trying to decipher what the new requirements are. And also note all of the others who had difficulty getting various letters accepted by the NMC.

33

[QUOTE=z-drive;141041]Except that that only worked if you applied before march 24, 2014, hence the whole point of the last 20 posts trying to decipher what the new requirements are. And also note all of the others who had difficulty getting various letters accepted by the NMC.[/QUOTE]

He said he just applied a week and ahalf ago… which is after march 2014… so it appears at least one person there accepted it… not sure that helps though because then it is just luck of the draw right? Then again, how in the heck did he get something approved that quickly… seems awfully fast based on other license threads here.

34

[QUOTE=Saltgrain;141049]He said he just applied a week and ahalf ago… which is after march 2014… so it appears at least one person there accepted it… not sure that helps though because then it is just luck of the draw right? Then again, how in the heck did he get something approved that quickly… seems awfully fast based on other license threads here.[/QUOTE]

When you apply is irrelevant, as long as it is before 12/31/2016 for STCW and 3/24/2019 for domestic. It’s when your sea time started, not when you apply.

35

My apologies. I neglected to edit the last part of the post. I first posted that in another forum in an attempt to help other mariners who were having difficulty. HOWEVER, I handed a copy of my letter to three engineers on my rig two months ago and all three of them were approved and received the endorsement.

36

[QUOTE=SoCalSalt;141036]I Posts this a while back but here it is again…

All you need for the endorsement is a letter, signed by the captain, with the Official number and ships stamp.

It should read,
Re: (Name) (MMC #) letter of documentary evidence for stcw endorsement as Vessel Personnel with Designated Security Duties. (VPDSD)

In accordance with Policy Letter USCG-CG CVC Policy letter No. 12-06 (5)(f)(2) this individual has seagoing service on this vessel. This individual has had designated security duties in the vessel security plan and / or noted on our vessel security station bill for a period of (insert total) months from (sign on date to off date).

Signed by the Master with his MMC number and ships stamp. STCW endorsement is free. Sent mine in a week and half ago and just got it back.

Of course, as pointed out earlier in the thread, if you already have VSO, they’ll add it for you without the letter. If you don’t have time to take VSO, this is the way to go.

Cheers[/QUOTE]

SoCalSalt, I used your letter and instructions to the “T” as you had just had luck with it. I obviously didn’t. I am going to get another letter from the company and as Capt. Phoenix suggests put all of the requirements from CFR 33 104.222 in the letter to see if it will meet this particular evaluator’s “verbiage” requirements.

I sent an email on monday to my evaluator requesting a copy of the letter be emailed to me as I was offshore for another 28 days. I have just received the letter today.

This was the content of my letter:

LIST OF ITEMS REQUIRED TO COMPLETE THE EVALUATION PROCESS
Please return the following items to the National Maritime Center within 90-days of the
above date:, July 10, 2014

TRAINING CERTIFICATES
To qualify for an STCW endorsement as Vessel Personnel with Designated Security Duties
(VPDSD), you must provide proof of qualification such as: satisfactory documentary
evidence such as a certificate or letter signed by a company official or certificate of
completion from a Coast Guard approved course that meets the requirements of 33 CFR
104.220. Please note that the service option of former Policy Letter 12-06 cannot be used.
References: 46 CFR 12.625; 33 CFR 104.220

37

I guess 02-14 supersedes 12-06. She referenced 12-06 as “former Policy Letter.” Sounds to me like you will have to go to school.

38

[QUOTE=jdcavo;141077]When you apply is irrelevant, as long as it is before 12/31/2016 for STCW and 3/24/2019 for domestic. It’s when your sea time started, not when you apply.[/QUOTE]

If that’s the case then why does both the policy letter and 46 CFR give a deadline of 24 March 2014 for applying with nothing but a letter saying you have had designated security duties for at least six months?

39

OK, so had the ex employer draft and sign another letter for me. Also enclosed were sea service letters for each vessel signed by Master & owner of company along with vessels’ registration docs.

will see if this works:

40

just received an email yesterday: “Your application has completed the evaluation process and is approved for issuance.”

of course the “Credential State Flow Diagram” (constipated as usual) doesn’t even show this step nor does the link have any updated info for me yet, I will still assume that the next email to come is your credential has been printed/mailed. So with a stupid little change in the company letter, I was able to make the nincompoop evaluator realize that he was wasting my time, his time and holding up the process again. I did not ask for “reconsideration” in my first rebuttal, only submitted a new company letter. Obviously there are some questions as to what where to refer for these endorsements. Unless you go take a class, which seems to be what everyone wants one to do. Screw that, I’ll take the time home and no dinero out of my pocket method every chance I get.