You can restore the endorsement at any time by taking the course. But, at present, you will need to apply to NMC and get it added back into your MMC. Current regulations require you to hold the endorsement (have it in your MMC) to be valid for a vessel required to have radar observers. See 46 CFR 15.815.The ruklemaking to change renewal requirements on hold during the shutdown of the DHS and Coast Guard. Most if not all of the personnel involved are furloughed.
The validity opf your radar observer endorsement ends five years from the date of the course certificate (the last day of the course you took). See 46 CFR 11.480(e):
A radar observer endorsement issued under this section is valid for 5 years from the date of issuance of the certificate of training from a course approved by the Coast Guard.
No idea where the last day of the month thing came from, it’s nonsense. The approvals that NMC gives to schools for their courses end on the last day of a month, but that’s irrelevant to the validity of your radar observer endorsement.
Anticipating another question, no word or status on the proposed rulemaking to allow sea service to count for renewals of radar observer. Progress was stopped during the shutdown of the Federal government.
I am incredibly confused by a similar situation. My radar certificate expires in March of this year. My MMC expires in 2021. I took a radar refresher a week ago in accordance with my radar certificates expiration date. When I tried to file it with the local REC I was told that I did not need to renew my radar observer certificate until my MMC expires in 2021. This does not seem correct, I was under the impression that my radar cert expires based on a date five years from my course certificate, and that I had to renew it and send in an application to the coast guard saying so. Which is it? Do I renew based on the course certificate date, or based on my MMC expiration date?
As I understand it, and this is probably wrong, since they removed the radar date from our licenses years ago, you have to show proof of taking an approved recertification course within 5 years. This means they are only interested in you being “within window” when they issue you a new license or ask for the certificate during a COI. The whole thing just needs to be done away with.
This type of snafu is typical of NMC. NMC is a failed program. It should be closed down.
Congress has ordered the USCG to eliminate the Radar renewal requirement. To accomplish this the USCG has to comply with the Federal Rulemaking process to change the CFRs. This requires a process that takes some time.
In the meantime, reasonable people might expect the USCG to issue a NAVIC saying something like: “since Congress has ordered us to eliminate the Radar renewal requirement, and we are in the process of doing so, as a matter of policy we are suspending enforcement of the Radar renewal requirement pending completion of the rulemaking process to eliminate it.
You’re partially right. The endorsement is good for 5 years from the date of the last course. But you only need to give it to NMC/REC when you are renewing the MMC. In the interim, you use the certificate to show you are up to date. See 46 CFR 15.815(d): Each person who is required to hold a radar endorsement must have his or her certificate of training readily available to demonstrate that the endorsement is still valid.
It might help to remember what the situation was before the MMC. Until 2008, your radar observer endorsement had an expiration date that was different from the one on your license. So you had to submit an application, pay the fees, get the drug test, etc. to renew radar even though the license it was attached to wasn’t going to expire for years. The regs at that time were changed to take the expiration date of radar off the license, but to keep the time between refresher training at 5 years. So you need to carry, or make available on short notice, your training certificate to show that no more than 5 years has passed since you last took the course.
Under regs that were proposed a few months ago, sea service can be used to maintain the endorsement (no course) and you would only need to show you are up to date when the MMC is issued, after that, as long as the endorsement is in your MMC, you are good. You wouldn’t need to show you are up to date until the next time you renew or upgrade.
They haven’t stopped, they appear to have made a mistake. Contact them and tell them the problem. If you’re right, they should send you a sticker with it to add to your MMC.
Also, even under the proposed regulations, you are still going to need the endorsement in your MMC. It will still have to be renewed.
Give it a feckin’ rest. We all get it, you don’t like NMC. In this case, radar observer regulations have nothing to do with NMC (and you know that). NMC doesn’t make regulations or policy. The comment about an interim policy is valid, but dragging your tired prattle about NMC into it is just a ridiculous Pavlovian response that adds nothing to this discussion. Try to resist just once.
Also, you will probably notice that I acknowledged a mistake by NMC immediately above. No need to start your screed about NMC again.
Unfortunately, under the current climate it is extremely difficult to issue policy documents that are contrary to a regulation–even when the policy is more lenient than the regulation. I won’t bore everyone with the details but it is much less likely now to have ‘interim’ policies issued than before. There is little that can be done about it.