I’m trying to add the VSO/SSO endorsement to my STCW certificate in accordance with the new regulations, but its like trying to hit a moving target…
The longer I’m in the maritime business, the less I’m qualified to do-- or so my most recent experience with the USCG would seem to indicate. Today I began the process of gathering my VSO certificates and other documentation to get my STCW certificate endorsed in accordance with new regulation. Licensed officers who are designated Vessel Security Officer must provide evidence of approved VSO training and have their STCW certificate endorsed before July of next year. After reviewing the USCG’s NMC website, I find that none of the three courses that I’ve taken since implementation of MTSA / ISPS are accepted by USCG. One course misses the acceptable date range by 2 months. I hold VSO / SSO certificates from Calhoon MEBA Engineering School and MSC Training Center East as well a PFSO certificate from Seebald Associates— reputable providers who deal with the USCG on an ongoing basis.
A civilian employee at the USCG Boston REC told me after hearing my story that he would have no problem using his discretion to endorse my STCW based on my training, experience and sea time-- however, that discretion is no longer allowed at the REC’s; everything must go through the NMC in West Virgina.
Additionally, now I have worry that I won’t get my license and documents back from NMC in time to return to work in January. My conversation with the staffer who answered the phone at NMC was not encouraging with regard to timeliness of application processing.
How is it that, despite our good faith efforts to be compliant with the ever-shifting regulatory regime, we can be subject to retroactive certification and training requirements that entail expensive, time-consuming and superfluous training? How is it that the courses were deemed acceptable at the time that MTSA and ISPS was being implemented? Why are we at the mercy of a plodding Kafka-esque bureacracy (Think TWIC) that seriously impacts our ability to make a Iiving in an already challenging field? I do NOT want to squander another week of my vacation to take another course on a subject that I could teach for the sake of another certificate to add to my already bulging license portfolio.
I’ve got similar issues with Tankerman PIC LG and DL endorsements as well— any one else with similar experience?
More importantly, does anyone have a solution so that I can continue to pursue my sea-going career without reverting to full-time cadet status?
First, was the course a 2-day Coast Guard approved course?
Second why did you send your License instead of a copy? Did the REC tell you to send your original?
I handed in my application with copies of my license, STCW, & MMD in at the Mandeville REC in early November. Last time I checked my Status they said they were checking out the school I attended for security class. Hopefully I will get my new STCW soon.
If I remember correctly it was a Catch-22 situation in the begining. The first requirement from the USCG was that companies submit company and vessel security plans for approval. Mariners were not required to have a VSO course but inorder for a company to get approval of a plan they needed at least one VSO aboard each vessel. None of the US based schools were jumping at the chance to offer the class and once they did, they still needed to develope course plans and get approval. So companies started sending people to non-uscg approved schools to cover the requirement.
I do find it strange that you took the classes at Calhoon and MSC but, I do know, some of the schools brought in external instructors (ABS was an early provider) to cover the classes. Is “Calhoon” lsited on the certificate? Are any other company names listed?
Personally I saw this comming and was able to hold off my company untill the first approved class arrived. I took it at Cal Mariitme and was the only person in the class, I actually had to beg them not to cancel. When I took it a dozen non-approved classes were going on around the country and I couldn’t figure out why no one else wanted an approved class.
I know of one captain that had the same issue. After much cussing and frustration he finally convinced NMC to just send him his renewal without the VSO endorsement on his STCW.
He submitted his renewal application in March and his license expired NOv 15th. He rotated off the boat Nov 20th and was hoping/praying that his renewal would arrive prior to his scheduled return date. (by the way; he spoke to his evaluator on a weekly basis for at least 4 months).
I have heard so many horror stories about people trying to get licenses from NMC or renew , now I know why so so many people I have talked to are finding other jobs where they dont have to keep a license . Its about time to start writing to our Reps in Congress and the Senate about this bull we have to go thru . May be we need to check into class action and lawsuits .
Norleen Schumer (a person I highly reccomend to anyone needing professional advice on licensing affairs) sent this answer to me via email:
Dear bobk this is in response to your questions of November 28, 2008.
As a former Assistant Chief at an REC believe me when I say, “I understand”. I understand YOUR frustration and I also understand the frustration of the REC’s.
The person at the Boston office, or any REC for that matter, no longer has any control or discretion. The National Maritime Center is the core of the operation. NMC has made the REC’s a “store front” and they can do nothing for you but take your fingerprints; verify your original documents; issue you the Oath (when applicable); do school over sights; give exams; and take your fees.
VSO. I am taking it for granted that you have read the Q & A’s put out on the NMC Website http://www.uscg.mil/nmc/vessel_safety_officer.asp here is one that seems to match your dilemma almost to a “T”. There are many more questions and answers on this website that tell the companies how to get their training approved by the CG.
Is security training provided in the past sufficient to meet the requirements of the new proposed rule making?
All MARAD approved programs, will be accepted as meeting the requirements under this rule. Persons who attended courses that were not approved under the MARAD approval program, or have received company training, or can document VSO experience will be required to take a refresher training.
On the CG website at http://www.uscg.mil/STCW/Index.htm you can find a list (5 pages) of currently approved VSO training courses, I do not however, seem to see any of these courses listed as “Refresher training”. I currently have a question into the NMC specifically asking if there are any “VSO Refresher Training” Courses.
You ask if there is a solution. At this time, the only solution is to follow the current rules set forth by the NMC. I can only suggest to you, that perhaps getting your State Senators, Representatives and Congressmen involved may help.
As of 12/9/08 there are 5 approved refresher courses, a list is attached below. We have not updated our web page as there is a dispute with the contractor who provides web support.
The organization that approved the courses for MARAD (DNV) has the authority to retroactively approve courses. I suggest contacting whoever you took your courses from and urge them to ask DNV for retroactive approval. ABS has the same authority.
James D. Cavo
USCG National Maritime Center
Chief, Mariner Training & Assessment Division
James D.Cavo@uscg.mil
Thanks to all for the helpful comments and insights. Thanks also to this forum for the opportunity to vent a little…once I got over my initial indignation and stopped whining, I called Calhoon and had them fax me a letter of retroactive approval for the VSO course I took back in August of 2005. Armed with that and my best bureaucrat pleasing calm and placid demeanor, I brought all my relevant docs into the Boston REC and was promptly issued a newly-endorsed STCW certificate. To the credit of the folks at the Boston REC, they really go above and beyond to service the professional mariner. Although the new protocol requires them to forward all applications to the NMC, they still try their best to exercise what little discretion they have left. In my case, it resulted in having my STCW certificate issued on the spot, rather than having to wait a week or two (or more, as indicated by some posts).
Just a few things to note for anyone else who hasn’t yet gotten the endorsement-- as noted by Mr Cavo above, the NMC website hasn’t been updated. There is no checklist of documents or application instructions for this endorsement on the website. That would have been helpful, as I had to run out to a nearby CVS to get passport photos($7.99 with my CVS “Extra care” card!) This was kind of comical, considering that I had to pay $8 dollars to have a drugstore clerk take my picture with a digital camera— but the jumbo Snicker’s bar I ate while waiting for the pictures to print probably helped improve my disposition.
Also note that standard practice requires submission of your completed application package to the NMC via the REC, so be aware that you may not walk out with the endorsement the day you submit the app.
When all is said and done, the endorsement itself is kind of a letdown: just the upper case notation "VESSEL SECURITY OFFICER " in the left - hand “CAPACITY” column. I’m done-- for now – next battle will be to get my Tankerman-PIC LG and DL endorsements restored — that will be my New Year’s resolution!
I just recieved this follow-up from Norleen Schumer. She’s really (as always) gone out of her way on this, so I encourage anyone who is having persistent licensing problems to visit her website and give her a call.
I received a number of emails and phone calls from industry members seeking clarification on the application of the VSO training and certification requirements to towing vessels less than 200 GRT, in 46 CFR 15.103(e) and (f). After reviewing all of the regulations and discussing it with the various offices I offer the following interpretations to the three possible scenarios that the Coast Guard will be considering with regard to implementation of the VSO requirements:
Persons serving as VSO on vessels of less than 200 GRT (other than passenger vessels subject to subchapter H of title 46 CFR) engaged in domestic voyages between ports in the contiguous United States (does not include Alaska or Hawaii) that operate inside the boundary line are not required to carry a VSO certificate.
Persons serving as VSO on vessels of less than 200 GRT (other than passenger vessels subject to subchapter H of title 46 CFR) engaged in domestic voyages between ports in the contiguous United States (does not include Alaska or Hawaii) that operate beyond the boundary line, but within near coastal waters (as defined in 46 CFR 10.103 – within 200 miles of the coast of the United States), will be required to meet the certification requirements for VSO. These persons will be issued an STCW VSO endorsement with a near coastal limitation, but will not be required to undergo any additional training in order to receive the endorsement. Affected mariners may request the endorsement from the National Maritime Center and need not show proof of having completed a Coast Guard-accepted training course in order to receive it.
Persons serving as VSO on vessels of less than 200 GRT (other than passenger vessels subject to subchapter H of title 46 CFR) engaged in domestic voyages (between US ports) that go beyond the boundary line and either 1) travel outside U.S. near coastal waters as defined in 46 CFR 10.103 (i.e., beyond 200 miles offshore) or 2) enter the waters of another Administration will be required to meet the training and certification requirements for VSO. These persons will be issued an STCW VSO endorsement with no limitations. Affected mariners may request the endorsement from the National Maritime Center and need to show proof of having completed a Coast Guard-accepted training course in order to receive it.
We recognize that this interpretation is somewhat different from the one we originally provided in response to questions submitted by AWO. However, after reviewing these scenarios and all of the underlying STCW regulations applicable, we believe this interpretation accurately reflects the requirements of STCW. Please feel free to contact me if you have any further questions.