That blade cuts both ways. How many Unlimited Masters out there got them taking almost no STCW classes. As far as people signing their own assessments come on, I think it’s pretty obvious why the CG won’t allow that. I think the CG is righting the greater wrong here. Somebody is bound to get pissed. Why should someone have to take a class which they could rightfully and better learn onboard the vessel ($800 for magnetic and gyrocompass). The exam is still an equalizer.
I’m afraid a few bad apples will get their buddies to sign their assessments (without doing any if them), learn exactly enough to pass the exams with the lowest possible score than get hired as a hawsepipe mate and promptly run their ship aground.
I had to slap myself at that point because I think I understand what the school kiddies feel like when they look at hawsepipers.
In any case we know there will be bad apples. I just hope they don’t make companies too afraid to hire from the hawse.
I still believe the new policy letter is basically “in writing” of what most mariners where complying with for a long time, minus specification of the OSV Mate in 07-11. 01-02 was a very bad policy letter. Not because it was bad in the sense of its application when it was drafted by Captain Fink, when Stew Walker was still at NMC directing REC evaluators, but because it left too much up for interpretation with the test of time when they were gone, especially section 11. The new policy letter spells out exactly what myself, Captain Lee, and many others had to do over 5-7 years ago, but it’s application changed at some point under a new Commanding Officer from my personal observation.
I think this policy letter is a good one, just way too late, and Captain_A’s reaction is certainly a valid one.
[QUOTE=anchorman;52198]I still believe the new policy letter is basically “in writing” of what most mariners where complying with for a long time, minus specification of the OSV Mate in 07-11. 01-02 was a very bad policy letter. Not because it was bad in the sense of its application when it was drafted by Captain Fink, when Stew Walker was still at NMC directing REC evaluators, but because it left too much up for interpretation with the test of time when they were gone, especially section 11. The new policy letter spells out exactly what myself, Captain Lee, and many others had to do over 5-7 years ago, but it’s application changed at some point under a new Commanding Officer from my personal observation.
I think this policy letter is a good one, just way too late, and Captain_A’s reaction is certainly a valid one.[/QUOTE]
I think it is a good policy too. It’s just patently unfair to those who had to deal with the “pay to play” paradigm.
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[QUOTE=jdcavo;52171]That is what Regulation II/2 of STCW calls for: “[e]very candidate for certification [as chief mate/master] shall… meet the requirements of for certification as officer in charge of a navigational watch on ships of 500 gross tonnage or more.”[/QUOTE]
Okay, so since I already hold 1600gt/3000itc Master Oceans with II/2 on my STCW Authorities, I still need to get II/1 in order to upgrade (retro-grade?)…But I can sign the AB’s off for their OICNW assessments without II/1.
And that’s because I never sat for any Mate’s ticket after 2002.
Just want to be clear, I feel like I’ve fallen down the rabbit hole. Where can I find the assessment sheet for this one, under the magic mushroom?
Should I be concerned my II/2 authority will be invalidated on my next renewal?
Ugh!
[QUOTE=DeckApe;52194]I’m afraid a few bad apples will get their buddies to sign their assessments (without doing any if them), learn exactly enough to pass the exams with the lowest possible score than get hired as a hawsepipe mate and promptly run their ship aground.
I had to slap myself at that point because I think I understand what the school kiddies feel like when they look at hawsepipers.
In any case we know there will be bad apples. I just hope they don’t make companies too afraid to hire from the hawse.[/QUOTE]
The alternative being a guaranteed to pass class where they hand you your assessments on a silver platter…for a price? I have never seen anyone fail an STCW class. And who the F turns any new Mate loose with the vessel anyway, an OICNW license is just a license to learn in my opinion. At least with this method you have to prove you can do something in the real world not a “Simulator.”
[QUOTE=anchorman;52198]I still believe the new policy letter is basically “in writing” of what most mariners where complying with for a long time, minus specification of the OSV Mate in 07-11. 01-02 was a very bad policy letter. Not because it was bad in the sense of its application when it was drafted by Captain Fink, when Stew Walker was still at NMC directing REC evaluators, but because it left too much up for interpretation with the test of time when they were gone, especially section 11. The new policy letter spells out exactly what myself, Captain Lee, and many others had to do over 5-7 years ago, but it’s application changed at some point under a new Commanding Officer from my personal observation.
I think this policy letter is a good one, just way too late, and Captain_A’s reaction is certainly a valid one.[/QUOTE]
I didn’t think of it like that, but you’re right on with that observation… this new policy letter basically spells out the intent of what 01-02 was supposed to be. But thinking about it, you got hosed because your first license was originally 1600 Mate. You shouldn’t have had to retest!
[QUOTE=Diesel;52208]The alternative being a guaranteed to pass class where they hand you your assessments on a silver platter…for a price? I have never seen anyone fail an STCW class. And who the F turns any new Mate loose with the vessel anyway, an OICNW license is just a license to learn in my opinion. At least with this method you have to prove you can do something in the real world not a “Simulator.”[/QUOTE]
I have personally failed more than one student, and refused to sign assessments for many, simulator or not. Not all schools are certificate factories. Trust me.
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While I didn’t absorb the financial costs of the courses, my family and I definitely felt the impact of time lost. While I’m certainly not happy about it, I wouldn’t want to prevent it or repeal it. I’m too busy making sure co-workers stuck with 200 ton licenses that have the knowledge and experience but didn’t have the money for the courses know about this and get the upgrade as quickly as they can. In addition I’m studying for Celestial Navigation and learning to use a Sextant, something I was putting off until I had the money for the course that I no longer need to take. It was never a case of not having the drive or ability to study on my own, it was rather that it didn’t matter, I was still going to have to plant my butt in the damn chair regardless. Which I look forward to having to explain again without basis because the rules have changed. “Why don’t you just study and take the test, that’s the way I did it!”
While there is, in my opinion, a very valid basis for a class action lawsuit. I think my time may be better spent getting whatever else I can get accomplished before they change the rules on me again. Rumor had it, that Chief Cavo put to rest, that they were resurrecting an NPRM for potential implementation. While it may not be coming as it was expected, they still have to accomplish full implementation of STCW. I don’t think anyone saw this one coming, I doubt we’ll see the next one until it’s too late.
[QUOTE=Capt_Anonymous;52185]…While you’re at it, file a FOIA request to determine how many people appealed 01-02, and of those how many prevailed and were given OICNW without having to complete the requirements of 01-02…[/QUOTE]
Notwithstanding that this is an interrogatory and FOIA does not compel the answering of questions, I’ll save you the trouble. There were (approx.) seven such appeals in the past two years that have reached CG HQ. There may be more that were decided at the first appeal level at the NMC, based on the HQ appeal decisions. Also, the appeal decisions established precedent that may have been applied to others without having to resort to appeals. In all seven appeals on this issue decided at HQ, the mariner prevailed. In the near future, redacted copies of appeals will be available on the internet, we are working out issues related to the secure redacting of personal/privacy information.
[QUOTE=Capt_Anonymous;52185] …Sneaky bastards, releasing this horseshit on a holiday weekend.[/QUOTE]
The timing was unfortunate, it smells bad. But did it really matter? Mariners don’t get holidays off, unless it falls during their off rotation. And if it does, those guys probably have better things to do than read the Federal Register. More important, the Coast Guard had no control over the specific timing. The policy letter left CG HQ weeks before and the rest of the time was due to review by other agencies, coordinating with the Federal Register, etc. In fact, the letter was made public via a leak a week earlier, see http://www.brymar-consulting.com/wp-content/uploads/2011/06/NEWS110624.pdf There was also more than one mention of favorable appeal decisions and rumors of a forthcoming policy letter here in gCaptain. Not everything is part of a grand conspiracy, some stuff just happens. And, if we were trying to keep it a secret, would I have started this discussion by announcing the policy for people who don’t read the Federal Register on a daily basis?
[QUOTE=Capt_Anonymous;52185] …Arrogant bastards, legislating via policy letter instead of going through a process of codifying the policy… [/QUOTE]
The old policy letter was regulating by policy, it imposed requirements in excess of those in regulation. That was the holding of the appeals mentioned above, and the reason for the new policy.
[QUOTE=Capt_Anonymous;52185]… How nice not to have to collect and collate public comments that they ignore anyhow…[/QUOTE]
See http://www.regulations.gov/#!documentDetail;D=USCG-2004-17914-0177. Putting our last proposed rulemaking on hold was, in part, due to comments about it: [I]“[/I][I]In response to feedback we have received… the Coast Guard is reviewing the approach outlined in the NPRM. As such, we are considering publishing a Supplemental NPRM (SNPRM) as a next step. The SNPRM would describe any proposed changes from the NPRM, and seek comments from the public on those proposed changes."[/I]
[QUOTE=Capt_Anonymous;52185]… How unfair to those who worked and toiled and even watched their marriages dissolve over the time and expenses required to get something that OVERNIGHT just got a whole fucking lot easier and less expensive. .[/QUOTE]
So instead of taking corrective action we should continue and inflict the same on others? If it’s wrong it needs to be fixed. Sooner might have been better, but is doing nothing better?
[QUOTE=captbbrucato;52205]Okay, so since I already hold 1600gt/3000itc Master Oceans with II/2 on my STCW Authorities, I still need to get II/1 in order to upgrade (retro-grade?)…But I can sign the AB’s off for their OICNW assessments without II/1. And that’s because I never sat for any Mate’s ticket after 2002. Just want to be clear, I feel like I’ve fallen down the rabbit hole. Where can I find the assessment sheet for this one, under the magic mushroom? Should I be concerned my II/2 authority will be invalidated on my next renewal? Ugh![/QUOTE]
You’re intermixing the requirements for a license exam with STCW. The only significance of whether or not you were issued a mate license after 2/1/02 is whether or not you take a license exam. Master 1600 to 3rd Mate has always required an exam. If the Mate 500/1600, 3rd Mate, and 2nd Mate exams were not combined, you’d still have to take an exam to go to 3rd Mate. I think this issue can now be summarized by this: http://cdn.faniq.com/images/blog/40dfb1c912e11d9071b704038a77d740.gif
But your point about signing assessments but having to do them to go to 3rd Mate is valid. Not so much because of the need to demonstrate competency but more over the issue of who can do the assessmnts for you. Your mate may not have the one year of experience required to be an assessor, and more important, the Master-Mate relationship does not suppoort a unbiased, impartial assessment process. That you need to do the assessments is morte easily explained and defended, you are grandfathered to your current license(s), the grandfathering was solely to allow mariners to continue in their present capacities. And it would be impractical and perhaps unreasonable to only allow assessments to be done by Masters who had themselves been assessed for and been issued OICNW (a chicken or the egg issue as to who will be the first assessors). You raise good questions that warrant consideration.
Thanks, Mr Cavo. Who killed that horse? What a shame.
[QUOTE=jdcavo;52237]
Notwithstanding that this is an interrogatory and FOIA does not compel the answering of questions, I’ll save you the trouble. There were (approx.) seven such appeals in the past two years that have reached CG HQ. There may be more that were decided at the first appeal level at the NMC, based on the HQ appeal decisions. Also, the appeal decisions established precedent that may have been applied to others without having to resort to appeals. In all seven appeals on this issue decided at HQ, the mariner prevailed. In the near future, redacted copies of appeals will be available on the internet, we are working out issues related to the secure redacting of personal/privacy information.
The timing was unfortunate, it smells bad. But did it really matter? Mariners don’t get holidays off, unless it falls during their off rotation. And if it does, those guys probably have better things to do than read the Federal Register. More important, the Coast Guard had no control over the specific timing. The policy letter left CG HQ weeks before and the rest of the time was due to review by other agencies, coordinating with the Federal Register, etc. In fact, the letter was made public via a leak a week earlier, see http://www.brymar-consulting.com/wp-content/uploads/2011/06/NEWS110624.pdf There was also more than one mention of favorable appeal decisions and rumors of a forthcoming policy letter here in gCaptain. Not everything is part of a grand conspiracy, some stuff just happens. And, if we were trying to keep it a secret, would I have started this discussion by announcing the policy for people who don’t read the Federal Register on a daily basis?
The old policy letter was regulating by policy, it imposed requirements in excess of those in regulation. That was the holding of the appeals mentioned above, and the reason for the new policy.
See http://www.regulations.gov/#!documentDetail;D=USCG-2004-17914-0177. Putting our last proposed rulemaking on hold was, in part, due to comments about it: [I]“[/I][I]In response to feedback we have received… the Coast Guard is reviewing the approach outlined in the NPRM. As such, we are considering publishing a Supplemental NPRM (SNPRM) as a next step. The SNPRM would describe any proposed changes from the NPRM, and seek comments from the public on those proposed changes."[/I]
So instead of taking corrective action we should continue and inflict the same on others? If it’s wrong it needs to be fixed. Sooner might have been better, but is doing nothing better? [/QUOTE]
[QUOTE=jdcavo;52237]
Notwithstanding that this is an interrogatory and FOIA does not compel the answering of questions, I’ll save you the trouble. There were (approx.) seven such appeals in the past two years that have reached CG HQ. There may be more that were decided at the first appeal level at the NMC, based on the HQ appeal decisions. Also, the appeal decisions established precedent that may have been applied to others without having to resort to appeals. In all seven appeals on this issue decided at HQ, the mariner prevailed. In the near future, redacted copies of appeals will be available on the internet, we are working out issues related to the secure redacting of personal/privacy information.
The timing was unfortunate, it smells bad. But did it really matter? Mariners don’t get holidays off, unless it falls during their off rotation. And if it does, those guys probably have better things to do than read the Federal Register. More important, the Coast Guard had no control over the specific timing. The policy letter left CG HQ weeks before and the rest of the time was due to review by other agencies, coordinating with the Federal Register, etc. In fact, the letter was made public via a leak a week earlier, see http://www.brymar-consulting.com/wp-content/uploads/2011/06/NEWS110624.pdf There was also more than one mention of favorable appeal decisions and rumors of a forthcoming policy letter here in gCaptain. Not everything is part of a grand conspiracy, some stuff just happens. And, if we were trying to keep it a secret, would I have started this discussion by announcing the policy for people who don’t read the Federal Register on a daily basis?
The old policy letter was regulating by policy, it imposed requirements in excess of those in regulation. That was the holding of the appeals mentioned above, and the reason for the new policy.
See http://www.regulations.gov/#!documentDetail;D=USCG-2004-17914-0177. Putting our last proposed rulemaking on hold was, in part, due to comments about it: [I]“[/I][I]In response to feedback we have received… the Coast Guard is reviewing the approach outlined in the NPRM. As such, we are considering publishing a Supplemental NPRM (SNPRM) as a next step. The SNPRM would describe any proposed changes from the NPRM, and seek comments from the public on those proposed changes."[/I]
So instead of taking corrective action we should continue and inflict the same on others? If it’s wrong it needs to be fixed. Sooner might have been better, but is doing nothing better? [/QUOTE]
Of course not. Inaction is anathema to a thinking person. Which begs the question of organizational thought and process. You guys couldn’t have reached out to the stakeholders even a tiny bit for input on this issue?
I’m not a conspiracy theorist, I reacted based on my perception of the timing of the event. I’ve been at sea and without the luxury of leaks, unofficial hints, gCaptain scuttlebutt, etc. I know that the landlocked world relies on such things as a rule, but us sailors are somewhat hobbled in that regard. Plus, and I do digress, we’re just too damn tired after 45 days of six and six to keep up with the rested community of nine-to-fivers. Maybe Subchapter M will level the playing field in that arena, but I’m not holding my breath.
I’m in contempt, generally, of the USCG, save for SAR and VTS, as it is the poster child for dysfunctional organizational behavior. I would like to make it clear that you, good sir, have my respect for your active engagement in dialogue with us filthy hoi poloi, to the point you’ve been slapped by your overlords at times. Thank you for being here and for persevering. Adversaries can, and must, communicate if there is any hope of a better tomorrow.
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[QUOTE=Navy SWO;51946]Previously I needed about 20 classes and now I only need about 5??? Wow that sounds like good news, can’t wait to learn more.
I hope someplace comes out with an “A-Z” study guide that would enable me to learn all the stuff that I would have learned in those classes I no longer need to take so that I can pass the test…
I know that Murphy’s is a great test prep but is there an online course that I can take to actually teach me all I’ll need to know to pass the test (and be an effective Mate…)
If not then I certainly hope somebody comes out with a compreshensive online course, I’ll sign up for sure.[/QUOTE]
PMI just posted this video. I called her and she said that they are going to be producing comprehensive workbooks that go with their new training and assessment program. No word yet on when it will be ready to go, but she sounded like it could be in the next couple of months. Training won’t be online, though.
I did not know that PMI is a girl. Cool.
[QUOTE=dougpine;52251]I did not know that PMI is a girl. Cool.[/QUOTE]
I thought that was PMS?
(I couldn’t resist, however, I’m going to run and hide now before Capt Fran gets me!)
[QUOTE=DeckApe;52194]I’m afraid a few bad apples will get their buddies to sign their assessments (without doing any if them), learn exactly enough to pass the exams with the lowest possible score than get hired as a hawsepipe mate and promptly run their ship aground.
I had to slap myself at that point because I think I understand what the school kiddies feel like when they look at hawsepipers.
In any case we know there will be bad apples. I just hope they don’t make companies too afraid to hire from the hawse.[/QUOTE]
Imagine the disgust of the academy grads now towards the hawse. At least with the classes there was some sort of a herd thinning aparatus in place. Jethro don’t even need to learn to cypher now, he can just focus on being a double nought spy until his license arrives in the mail. Granny will be so proud of Captain Bodine.
I took all the classes and I always felt that they were what you made of them. You could get plenty of information and make it a positive learning experience [I]if you wanted to[/I]. There will always be those that will spend more time trying to find a way to get over on the system than just doing what was required, and what was required was not that hard. Now, it is a cake walk to get the approval to test letter but they still have to pass the test and that ain’t exactly easy. So Christmas came early this year, I only hope that there will be enough pride in taken in their quest for the license that mariners will learn something along the way and maybe, just maybe, this will remain a profession and not become a trade. Companies will not be afraid to hire from the hawse, they are hiring a license and supply and demand rules that we will have a greater supply so cost, read your paycheck, will dwindle. Just in the few years that I have been out here I have seen people hired that could not have been through [B][I]ANY[/I][/B] sort of rigorous scrutiny other than, if you are with it enough to be able to work the fax machine to get us a copy of the license. And/or if you can scan and email it, well then, you are lead material for sure. Time will tell.
Merry Christmas to all, and to all a goodnight.
[QUOTE=anchorman;52198]…but because it left too much up for interpretation… I think this policy letter is a good one, just way too late, and Captain_A’s reaction is certainly a valid one.[/QUOTE]
I had a couple of different interpretations from the REC and the NMC on the old policy letter a few years ago. I was actually laughed at by the REC when I told them what the NMC told me. I’ve already got everything ready to go. My assessments were already completed before this latest Policy. I’ve had too much going on at home to either go through all the classes or take on the NMC arguing their own policy so my upgrade was shelved. At least now it is pretty straight forward and hopefully interpreted the same by all who are charged with implementing it.
I would like to say thanks to those who did have the determination to take the bull by the horns and fight city hall. Apparently it got through. Saying that I would like to also express my empathy for those who made the sacrifices of all the time & money spent going through the classes. One of those guys is standing not ten feet from me. You can only imagine the look on his face when I told him about the new policy.
Mr. Cavo,
If the Mate OSV, Mate 500GRT, and Mate 1600GRT test became the same on 2/1/02 then they should still have to take the 3rd Mate exam because there are parts on the 3rd Mate exam that is not on the lower level Mates exam (46 CFR 11.910-2). Unless the NMC has been giving the 3rd Mate exam to the lower level Mates since 2/1/02. Further, the 3rd Mate checklist, (46 CFR 11.407) does not indicate anywhere that a Mate OSV, Mate 500GRT, or a Mate 1600GRT qualifies for the 3rd Mate Unlim. license. A 1600 GRT Master qualifies after having held and worked in that capacity license for 1 year. I believe that the assessments allow these lower level mates to not have to be assessed for the 3rd Mate license but they still have to follow the licensing scheme which would require them to achieve time and tonnage before upgrading to 3rd Mate Unlim. Also, if you don’t count the celestial portions of the exams, there are approx. 5 subjects that are on the 3rd Mate exam and not on the 1600GRT Master exam. There are approx. 17 subjects that are on the 3rd Mate exam and not on the 500/1600 Mate exam. Even further more, there are 51 subjects on the 1600GRT Master exam that is not on the 3rd Mate exam (46 CFR 11.910-2). Clearly, these lower level Mates meet the requirements for STCW portion for 3rd Mate Unlim., but do not meet the license requirements set forth by our Code of Federal Regulations. On the flip side, a 1600GRT Master that has held and worked in that capacity for 1 year meets the licensing requirements, but does not meet the STCW requirements until the OICNW assessments (II/1) for vessels over 500GT have been completed, even though the II/2 endorsement for Chief Mates and Master states that the person holding this endorsement meets all requirements for officer in charge of a navigational watch (OICNW). With that being said, a 1600GRT Master should not have to perform the assessments for OICNW because of their experience. Hense, they are already performing the tasks of the assessments on a daily basis. One of the assessments states that the person being assessed understand that they must notify the Master when faced with certain circumstances…who am I going to call…myself??? I hold a 1600GRT Master license and am the relief Master on the vessel of which I am employed. If I am missing something, by all means straighten me out. Thanks in advance!!
That ain’t an upgrade, in my humble opinion.