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.
Norleen Schumer