Can anyone shed some light on 2010 requirements for mariners with 25, 50, and 100 GRT license who need STCW for near coastal international voyage?
I have NAVIC 3-14 and can see all the requirements for Master NC Less Than 500 GT. Problem is I am talking about folks in the US and British Virgin Islands with US Maters License (25, 50, 100) operating small UPVs and T Boats.
These guys are running 25 foot boats with out boards or similar type boats and are now looking at taking:
Bridge Resource Management
Leadership & Management
Basic and Advanced Fire Fighting
Proficiency in Survival Craft
Basic Training (not limited to vessels under 200 GRT)
OICNW
Prior to the January 1 deadline, folks could take a Limited 3 day Basic Training course and be good. Obviously that does not meet the new standard. It still seems pretty unreasonable for guys with a fire extinguisher and crew of 1 (the master) to have to take BRM, HELM, Advance Fire, etc…
Seems like the rule makers never thought about the hundreds of small boat operators down here.
There is a very old policy letter 6-00 that pretty well address this issue but our local OCMI does not think it is applicable. They say a Master must have II/3 endorsement.
[QUOTE=csusvi;196223]Can anyone shed some light on 2010 requirements for mariners with 25, 50, and 100 GRT license who need STCW for near coastal international voyage?
I have NAVIC 3-14 and can see all the requirements for Master NC Less Than 500 GT. Problem is I am talking about folks in the US and British Virgin Islands with US Maters License (25, 50, 100) operating small UPVs and T Boats.
These guys are running 25 foot boats with out boards or similar type boats and are now looking at taking:
Bridge Resource Management
Leadership & Management
Basic and Advanced Fire Fighting
Proficiency in Survival Craft
Basic Training (not limited to vessels under 200 GRT)
OICNW
Prior to the January 1 deadline, folks could take a Limited 3 day Basic Training course and be good. Obviously that does not meet the new standard. It still seems pretty unreasonable for guys with a fire extinguisher and crew of 1 (the master) to have to take BRM, HELM, Advance Fire, etc…
Seems like the rule makers never thought about the hundreds of small boat operators down here.
There is a very old policy letter 6-00 that pretty well address this issue but our local OCMI does not think it is applicable. They say a Master must have II/3 endorsement.
Any thoughts or suggestions?[/QUOTE]
The OCMI is correct. You need an STCW endorsement for any non-domestic voyage beyond the boundary line, including a voyage that only transits the waters of another country. An endorsement under STCW Regulation II/3 is for near-coastal voyages and vessels of less than 500 GT (200 GRT).
That old policy letter is not applicable. It only explains when an STCW endorsement is required, not what it takes to obtain that endorsement. For STCW regulation II/3, that is specified in 46 CFR 11.317 (for Master) and 46 CFR 11.321 (for OICNW), and also in NVIC 13-14.
Thank you for the reply Mr. Cavo. I always enjoy reading your posts!
I am in agreement with your point about obtaining the endorsement for vessels under 500 GT and how that policy letter speaks to whether a mariner needs the endorsement or not.
Looking at NAVIC 13-14 enclosure 4 (STCW Code), Chapter II Regulation II/3 Paragraph 7 “Exemptions” states " The Administration, if it considers that a ship’s size and the conditions of it’s voyage are such as to render the application of the full requirements of this regulation and the section AII/3 of the STCW Code unreasonable or impracticable, may to that extend exempt the master and the officer in charge of a navigational watch on such a ship or class of ships from some of the requirements, bearing in mind the safety of all ship which may be operating in the same waters."
Is that not applicable to most of the operators down here in the Virgin Islands. These guys (estimated 450) are mostly 25-100 Ton Masters operating mostly UPVs less then a mile from shore. Their routes are both domestic and foreign as we travel between the US and British Virgin Islands. The British Virgin Islands are less then 1 mile from the US Virgin Islands. So while this is definitely a foreign near coastal voyage, it would certainly be worthy of an exemption for either the vessel to be exempt from the requirement or for the operator to have some sort of exemption or limitation on the endorsement for this specific route or class of vessel? This of course then requires that the foreign port state enforcement agrees with such a policy but that part can be dealt with locally.
The local OCMI rightly would need guidance from above if they were to grant such an exemption. Who would be the person to talk to regarding this at the USCG? I have worked with the local inspector who is very helpful and in agreement that this seems crazy given the routes and types of very small boats that we have operating in our area but he doesn’t feel that he is in a position to go up the chain of command to advocate on this topic. He says that needs to come from the industry.
Seems like the BT course in addition to holding an entry level Masters License would be adequate for most of the mariners locally provided they are limited to the previous described routes and or vessels.