Rebuttal to GAO STCW Training Review

GAO Contact: Jennifer Grover, 202-512-7141, groverj@gao.gov
The Government Accountability Office was asked to review Coast Guard and training providers’ implementation of the revised STCW requirements (see http://www.gao.gov/assets/690/682377.pdf). In doing so, the GAO failed to consult with active merchant mariners who are the victims of a bureaucracy which is unrestrained in promulgating unfunded training mandates which do little to improve the seafaring profession. They are largely a waste of time and money.

This mariner is a U.S. licensed master (oceans, any gross tons) who has been going to sea (deep sea and offshore) since 1962. I recently renewed my license and in so doing was required to take a refresher basic training course, an ECDIS course, and a leadership/managerial skills course. None of the evaluations that I was required to provide upon the completion of each of these courses addressed the question of whether I felt that the course improved my professional abilities as a mariner. Had I been asked, I would have answered: mostly NO. I believe the amount of useful new information I acquired in all three courses combined could have been covered in less than one day. That information could have easily been provided in an online computer course.

Captain H. F. Van Der Grinten
Sugar Land, Texas
captainvan@aol.com
281-265-7408

Cc: Robert L. Smith, Dennis L. Bryant, Captain William G. Schubert, Captain Douglas A. Hard

[QUOTE=CaptainVan;195189]GAO Contact: Jennifer Grover, 202-512-7141, groverj@gao.gov
The Government Accountability Office was asked to review Coast Guard and training providers’ implementation of the revised STCW requirements (see http://www.gao.gov/assets/690/682377.pdf). In doing so, the GAO failed to consult with active merchant mariners who are the victims of a bureaucracy which is unrestrained in promulgating unfunded training mandates which do little to improve the seafaring profession. They are largely a waste of time and money.

This mariner is a U.S. licensed master (oceans, any gross tons) who has been going to sea (deep sea and offshore) since 1962. I recently renewed my license and in so doing was required to take a refresher basic training course, an ECDIS course, and a leadership/managerial skills course. None of the evaluations that I was required to provide upon the completion of each of these courses addressed the question of whether I felt that the course improved my professional abilities as a mariner. Had I been asked, I would have answered: mostly NO. I believe the amount of useful new information I acquired in all three courses combined could have been covered in less than one day. That information could have easily been provided in an online computer course.

Captain H. F. Van Der Grinten
Sugar Land, Texas
captainvan@aol.com
281-265-7408

Cc: Robert L. Smith, Dennis L. Bryant, Captain William G. Schubert, Captain Douglas A. Hard[/QUOTE]

While I agree somewhat, the point is moot having taken the courses without harm, and then developed a content opinion afterwards. They’ll add this to the backhole archive. Simply put, if your are not the lowest common denominator for which standards are required, the results are general displeasure despite the fact of the many who would/are benefiting. Why does a 20 year old healthy indivdual need a two year USCG physical exam? I guess he would have an argument for not needing the physical in the first place if healthy, particularly after reading the results.

This is a good topic. I recently took the “gap closing” courses for engineers. The HELM and ERM were interesting to some degree. The technical courses presented, well. Not so sure there was any “gap” that needed closing. We’d had every bit of it some 35 years ago, and even used some of that since in the School of Hard Knocks.

[QUOTE=CaptainVan;195189]the GAO failed to consult with active merchant mariners who are the victims of a bureaucracy which is unrestrained in promulgating unfunded training mandates which do little to improve the seafaring profession. They are largely a waste of time and money.
[/QUOTE]

You sound a little P-O’d but who at? The training institution? The USCG? The GAO? IMO? Every gap closing course I took had an evaluation form that was flexible enough to make any comment I wanted. In theory they must be doing something with that information like using a quality control system on it to improve the courses. And I would further imagine the USCG office that approved the institution for delivering that training would also audit the student feedback at some point.

Your comment could also be sent directly to the USCG office that approved the school, you might have a more direct impact than going to the GAO.

On the other hand having taken the training and submitted your certificates to support your own application for the STCW portion of your document - maybe telling the USCG the course was a waste of time might not be logical. Maybe better to tell them what is wrong with it and how to improve it.

If you don’t like the STCW regulations that have evolved over all these treaties and amendments one might get more results by trying to influence your nations representatives that attend IMO and serve on the various committees. From what little I know about these things it seems that every school presenting a course for USCG approval is building the course according to the same specific STCW regulations paragraph by paragraph, line by line guidance. The USCG seems to then evaluates did this course material meet the requirements by showing that the student has been presented with and can demonstrate (by test) that the required info has been successfully passed on. No extra points for re-organizing the material into logical chunks, or doing a high quality job on materials, or avoiding cut and pasting the requirements into power point and regurgitating it on screen hour after hour.

Having said all that I couldn’t agree more with your overall evaluation. I tried to calm myself down after these courses by telling myself they were version 1.0 and hoped they were really reading the comments being returned. In one case the “leaderhsip and management skills” course I would say was excellently prepared and delivered. However, as long as we work in STCW trades you sort of just have to er, uh, swallow it. I doubt the USCG is funded to develop curriculum and I’m not even sure of the expertise they bring to bear on the review. It’s one thing to check off “did they (the schools) meet paragraph 3.1.2.3 by mentioning the three types of extinguishers”? Yes, right here in the power point slide - check, Next. And it is another thing to evaluate it for quality of materials, presentation, etc. I hope they occasionally attend them, then again that would be useless if the evaluator did not have the basic knowledge of the topic in the first place.

Tough topic and without funding the USCG to have better outreach to the regulated community I don’t see major improvements in the short run.

I should have added that if the purpose of the STCW regulations was to raise the level of competency among all the worlds seafarers well I think that goal was really missed. Even looking at these standards as the bare minimum there are nations that seem to deliver training and certificates without real competency.