Proposed Rule for Radar Observer Renewal

The Coast Guard has published a Notice of Proposed Rulemaking and is seeking comments on renewal of radar observer endorsements.

The proposed rule would allow mariners who have one year of service on vessels with radar in the previous five years to renew without taking a renewal course. The proposed rule would also eliminate the need to carry or have readily available training certificates to prove the validity of a radar endorsement.

The NPRM and info on submitting comments is available here. Comments must be submitted by July 11, 2018.

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Sounds good to me.

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Is something else going to be subbed in like an ARPA revalidation? I’m sure the schools won’t want to give up something as lucrative as radar renewal.

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I hope they get rid of it.

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The docket with the comments submitted thus far is here.

I think you will find a lot of folks supporting to keep this alive are affiliated with the schools profiting form this re-certification. In my view it is archaic and provides virtually no benefit.

I started googling some of the names of those who have submitted comments that support keeping the re-certification requirements. For example Ken Wahl is an executive with “Sea School”. He didn’t mention that in his comment though…

At least the gentleman from Star Center made clear who he works for.

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This was Ken’s comment:

"Ending RADAR recertification puts everyone at risk of collision-allision. Skills get soft, people forget, skills need to stay sharp. This potential ruling is ludacris in light of recent Navy collisions with merchant ships. If we allow radar skills to dull, we’ll effectively be asking for more collisions potentially. Its minor inconvenience IS worth avoiding allision/collision even if it avoids just one.

This is effectively the same as dropping celestial navigation from the requirements because we have GPS. So if you’ve used GPS during a year out of five, you could eliminate requirement of celestial endorsement. NO! Thats short sighted and only serves to eliminate safety protocol.

I cannot imagine serious thought was given to this potential lapse of safe judgement. ARPA functions can fail making radar refresher training priceless to allow safe voyage planning. Mark my words; If radar refresher training goes away, accidents and collisions WILL increase. The Gov. will find it necessary to backpedal to reinstate it. This is a terrible idea. This training costs very little, and the end result is a matter of life and death in some cases. It’s Just Not Worth the risk to American Merchant Marine Safety.

A recent story surfaced about a commercial boat out of Chicago had to be rescued due to restricted visibility and search party had to be sent out to guide them in. No Way IS eliminating the benefits gained from radar refresher a good idea. To purposefully increase collisions is the furthest thing the US Coast Guard should be standing for.

This is a BAD move. We don’t need USCG putting boaters at risk due to a risky knee jerk reaction to a few calls to eliminate training costs. Some ARE very worthwhile, Radar Refresher is one of them. "

The schools will fight tooth and nail against this. They want to continue to make the easy money off of classes we Mariners are required to take to keep up our license, classes that they can pretty much name their prices for. We must all do our part and submit comments that are in favor of doing away with this requirement.

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Totally agree. Lets not allow the schools to make it seem like hard working professional mariners are in favor of doing this ridiculous re-certification.

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How can anyone argue against such a well thought out argument. That’s all the proof I need to convince me that abandoning radar observer recerts is a BAD BAD idea.

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I just did my recert class 2 weeks ago. I’d like to see it go away, just to make my life easier. However; I have seen where failing this class was a big warning sign that previously great operators were sliding down a steep slope of age related mental degradation. Maybe some of the other new classes we need to take will fill that warning sign void.

It’s good that you would still need to show recentcy of usage. I know some people with mate’s licenses, but sail as AB’s, and never look at the radar anymore. My daughter being one. I know her skills interpolating the information needs refreshing if she had to stand watch as a mate again.

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Do people really fail this course? Can’t you take it as many times as you want and eventually pass? I don’t see this as an effective tool for weeding out people who are “slipping”.

There are definitely better cognitive tests available to catch that sort of thing. Although I wouldn’t be campaigning for making them mandatory either.

https://www.ntsb.gov/Investigations/AccidentReports/Pages/RAR9401.aspx

I really didn’t get much out of this class, it was a knee jerk reaction for inland vessels when a guy nosed up to railroad bridge in fog in Mobile Alabama in 93 (which killed 103 people), and then they required all inland guys/gals to get it. I am all for a refresher if it helps out on the water, I just really don’t think it does. I remember when I first took radar I got all excited I was going to do something practical like learn what all the knobs do. Then it was just 3 offshore plots involving CPA that really were just exercises and busy work. Once again, I’m not saying get rid of it because I understand the other part of the argument. I just think 90% of mariners walk out of that course no better than they were before they entered the building.

Plus, this being a commercial boat, they would have all done the recertification or the full class anyway right? So what good did it do?

To me it is like riding a bike but being that I’ve used it so much over the years that is just nature taking its course. A firm basis in Radar theory should carry you through your career and these recertification classes become moot twenty years into an active career at sea.

Do any other flag states require such additional radar certification? I mean since the original regulation was directly tied to the Andrea Doria and Stockholm collision hasn’t enough time passed that everyone should be well versed on never turning to port in restricted vis?

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Mr. Wahl should be disqualified from commenting based on a conflict of interest. In any case, his use of the word commercial boat and what happened to it is open to interpretation.
I looked up the name because as a marine coordinator I worked with an actor named Ken Wahl years ago. Different guy but I found this high production value video where the Seas School Ken Wahl states that all you need to become a captain is a one week course and 360 trips. Not sea days mind you, but “trips”.

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I am a USCG licensed unlimited Master, but have been working in foreign flag passenger shipping pretty much my whole career, with officers from all over the world, mostly from leading maritime nations. No other country has a similar requirement. When I explain to those that I work with that I have to do this RADAR plotting exercise every 5 years they can’t believe it. I think they think I am making it up. In fact it is always a hassle to get it reimbursed because no one in this industry has heard of such a thing.

When you read the comments posted it’s very very easy to tell who works for the sea schools and who is a professional Mariner.

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Shouldn’t he be disqualified for wearing a Garth Brooks shirt with epaulettes?

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I submitted a comment on the proposed rule making. I hope everyone here takes the time to do so.

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