I am trying to help a friend get some answers and clarify what is an extremely gray area regarding the issuance of VI-1 BST endorsment for QMEDs.
Before testing for the QMED-oiler, he took his BST course as required by CFRs. Received the approval to test letter, passed his test and was issued his MMC as an Oiler.
They did not include the STCW endorsement of VI-1 for Basic safety competence. He followed up on this and was refused, he even reapplied a second time, still denied.
NMC is stating that QMEDs must hold RFPEW ( III/4 ) in order to be issued BST ( VI/1 ). NMC even admitted that an AB is allowed to hold the VI/1 endorsement WITHOUT RFPNW, I actually know of several that this applies to. Why when the CFRs read almost identically for the AB and QMED in regards to these two STCW endorsements, would the QMED be denied and the AB be granted VI/1 ???
I hope that someone else who has gone through this can shed some light, Most of my experience is on the deck side of things, and this make no sense because the QMED is almost like the AB of the engine dept. in ratings. Why is there a difference according to the NMC?
Maybe Mr. Cavo can help me here, or anyone else with similar problems. We have read through the CFRs and my understanding of them says the NMC is wrong here.
46 CFR subpart 12.15-3 (d) and (e) are the QMED parts that NMC is snagging him on. He is not asking for III/4 at all (e), only VI/1 (d).
46 CFR subpart 12.05-3 (b) and (c ) are the AB requirements that read almost identically, YET the NMC says an AB can be issued VI/1 …WTF?
Both of the parts read almost exactly the same except the AB refers to RFPNW and QMED refers to RFPEW.
It seems pretty black and white to me. 46 CFR subpart 12.15-3(e) says that you must have III/4 to be issued an STCW endorsement.
Just because the call screener at NMC said an AB can get STCW without RFPNW does not make it true. The NMC is a crapshoot, every time you ask the same question you will get different answers.
An appeal must reference law or regulation and show pretty blatantly how the NMC was wrong. If there is any wiggle room I suspect they will always come down against the mariner. To appeal based on “I was told” or another mariner got it so I should too will lose 100% if the time.
(e) An STCW endorsement will be issued or renewed only when the candidate for endorsement as a qualified member of the engine department meets the standards of competence set out in STCW Regulation III/4 and Section A-III/4 of the STCW Code (incorporated by reference, see §12.01–3), [B]if the candidate will be serving as a rating forming part of a watch in a manned engine-room, or designated to perform duties in a periodically unmanned engine-room[/B], on a seagoing ship driven by main propulsion machinery of 750 kW [1,000 hp] propulsion power or more.
This is where I guess I am misinterpreting this cfr…I am reading it as you have to qualify for A-III/4 IF you will be serving as RFPEW…
Any QMEDs been through this ? Only experience I have with this is with ABs and they can get the BST endorsement w/o RFPNW…
[QUOTE=Conspearasea;55110]I am trying to help a friend get some answers and clarify what is an extremely gray area regarding the issuance of VI-1 BST endorsment for QMEDs. …
They did not include the STCW endorsement of VI-1 for Basic safety competence. He followed up on this and was refused, he even reapplied a second time, still denied.[/QUOTE]
RFPEW is not required to hold QMED. They are separate endorsements and not qualifying for RFPEW cannot be a reason to deny QMED. But, although BST is a requirement for all STCW endorsements, it is not itself an endorsement. If one does not qualify for RFPEW, and holds no other STCW endorsements, than no STCW document can be issued. As has been explained elsewhere in gCaptain, we do not issue STCW documents/endorsements for BST (alone).
[QUOTE=Conspearasea;55110]NMC is stating that QMEDs must hold RFPEW ( III/4 ) in order to be issued BST ( VI/1 ). [/QUOTE]
NMC is correct.
[QUOTE=Conspearasea;55110]…Why when the CFRs read almost identically for the AB and QMED in regards to these two STCW endorsements, would the QMED be denied and the AB be granted VI/1 ???[/QUOTE]
QMED was not denied, you said he was issued QMED-Oiler. RFPEW was denied, and thus there is nothing on which to note his completion of BST.
[QUOTE=Conspearasea;55110]…Before testing for the QMED-oiler, he took his BST course as required by CFRs[/QUOTE]
The CFR does not require BST for QMED. The portions you cite say you can’t get RFPEW without BST. They say nothing about RFPEW being required for QMED. That your freind was issued Oiler without RFPEW is evidence of this.
[QUOTE=Conspearasea;55110]…I am seeing an appeal in his future[/QUOTE]
Every mariner has the right to appeal a decision of the NMC.
Thanks for clearing this up mr. Cavo. I guess since the Abs I know have lifeboat, that’s the endorsement that allows STCW to be issued and thus listing BST for the A.B.
Will courses such as MAMA RFPEW, 5 day courses give him what he needs?
[QUOTE=Conspearasea;55183]Thanks for clearing this up mr. Cavo. I guess since the Abs I know have lifeboat, that’s the endorsement that allows STCW to be issued and thus listing BST for the A.B.
Will courses such as MAMA RFPEW, 5 day courses give him what he needs?
Wish the NMC had put it this clearly for him.
Thanks again.[/QUOTE]
Proficiency in Survival Craft/Lifeboatman is probably the difference, I should have thought of that.
If he has all of the RFPEW sea time (he should if he’s a QMED) he only needs the assessments. He can do these on a vessel, he doesn’t need a course. If he takes a course, make sure it’s approved for the assessments. I can’t answer about specific couyrses as I am not at NMC and don’t have this information, and it’s no longr on NMC’s web page. Ask the school for a copy of their most recent approval from the NMC, ask for the letter, not the certificate (the certificate won’t have this information).