Big, big re-writes to the CFRs involving the interpretation of the STCW Code for US Mariners.
Although the document is pretty big, you only have to look as far as the Table of Proposed Changes that begins on page 19 to see that this is going to affect all of us.
SUMMARY: The Coast Guard proposes to amend its regulations to
fully incorporate the International Convention on Standards of
Training, Certification and Watchkeeping for Seafarers, 1978,
as amended (STCW Convention), as well as the Seafarer’s
Training, Certification and Watchkeeping Code (STCW Code) in
the requirements for the credentialing of United States
merchant mariners as found in 46 CFR Parts 10, 11, 12, and 15.
The changes proposed incorporate lessons learned from
implementation of the STCW Convention and STCW Code through
the interim rule and attempt to clarify those regulations that
have generated confusion in the past.
That would be nice…I have one module left on the 3/2M test and don’t want any surprises…you know how they are…I should be finished this Friday…
[FONT=Courier][B]WOW![/B]
[B]I just scanned though this proposal, Lots of goodies in there, Like the months of schools and assesments before 3rd/2nd Mate and then again before CM/Master is referred to as “TEA” “Training, Examination, Assesments”. (Not to be confused with tea-bagging)[/B]
[B]If the proposal is approved, a 3rd Mate will be able to go straight to Master AGT after 3 years of seatime and completion of TEA.[/B]
[B]“This progression would be allowed to assist those mariners who are unable to obtain service time as a chief mate.” Also a Master 1600/3000 will be able to go straight to CMate after TEA, (possibly with tonnage restriction).[/B]
[B](Deck types checkout the graphic on page 198 of the proposal)[/B]
[B]Here’s some other jewels the proposal offers:[/B]
[B]Would add a new endorsement entitled “Survivalman” for individuals serving on vessels without installed lifeboats. (Is a costume required?)[/B]
[B]Clarifies that maritime service from the armed forces must be consistent with the requirements of other mariners, i.e., an individual must first hold an operationallevel credential in order to qualify for a management-level credential. (I guess that means post CO tour Naval/CG officers wont be able to go straight to Master/CM any more and will have to do time as a mate?)[/B]
[B]Removes the requirement for deck officers to obtain a qualification as able seaman. Provides consistency with the STCW Convention that does not require a qualification as able seaman for seagoing deck officers.[/B]
[B]Adds new requirements for chief mate of self-propelled,seagoing vessels of less than 1,600 GRT/3,000 GT.[/B]
[B]Revises the service requirements for an endorsement as mate to allow service on vessels of 75 GRT or more. Increases the number of mariners who would qualify for an endorsement as mate.[/B]
[B]Removes the officer endorsement for master or mate of vessels not more than 500 GRT. This endorsement would no longer be required because it would lower the tonnage requirements for those serving on vessels of not more than 1,600 GRT/3,000 GT.[/B][/FONT]
The proposed regulations can be accessed via the Internet by going to http://edocket.access.gpo.gov/2009/pdf/E9-26821.pdf. The changes proposed incorporate lessons learned from implementation of the STCW Convention and STCW Code through the interim rule and attempt to clarify those regulations that have generated confusion in the past.
Comments and related material must either be submitted to the Coast Guard’s online docket via http://www.regulations.gov on or before February 16, 2010 or reach the Docket Management Facility by that date. Comments sent to the Office of Management and Budget (OMB) on collection of information must reach OMB on or before February 16, 2010.
If you have questions on this notice of proposed rulemaking (NPRM), call or email Mark Gould, Maritime Personnel Qualifications Division, U. S. Coast Guard, telephone 202–372–1409, e-mail Mark.C.Gould@uscg.mil . If you have questions on viewing or submitting material to the docket, call Renee V. Wright, Program Manager, Docket Operations, telephone 202–366–9826.
[I][quote=Capt. Fran;21170]…If you have questions on this notice of proposed rulemaking (NPRM), call or email Mark Gould, Maritime Personnel Qualifications Division, U. S. Coast Guard, telephone 202–372–1409, e-mail [/I][I]Mark.C.Gould@uscg.mil…[/quote[/I][I]][/I]
Note that Mr. Gould is subject to the same restrictioons on commenting on the content of the rule as I noted in my post on this rulemaking, he’s not permitted to discuss the content of the rule (e.g. “does this mean that…”). If you want to discuss or comment on the content, follow the instructoions on commenting to the docket.
I commend the Coast Guard on their over-due effort. After reading most of the rule change, which I have no problem with at all. Actually, it hit on several points I did not see coming. I can only say…hurry the hell up…it’s not like 1997 was three month ago.
My opinion is not to comment to speed up the process…
I read most of this today. If 12" of text listing all the topics for Chief Mate schools adds up to ten weeks of training, how many weeks of training will the 36" of text listing all the 1a/e training equate (on page 59409)?
How long will take for a policy similar to 04-02 comes out that lists all the classes? Then we have to wait for courses to get approved and be offered, and companies have to budget for this much training well in advance. I hope this doesn’t become a mess like it was with Chief Mates eight years ago.
Oooooh, they have a new acronym, (QSS) quality standard systems. Also it states that under 11.401, as I read it, the new proposal [U]will not [/U] count course time be used as sea-time. Sorry for all those who like to go to the simulator for sea time. Won’t be happ’nin.
QSS has been mentioned as a part of STCW all along, maybe just new in the CFR.
I read 11.401 quite differently, here’ it is:
“(j) Training and shoreside employment may not be
accepted as equivalent to sea service under the STCW
Convention, [U]except as part of an approved training program[/U].
However, it may be allowed for specific domestic officer
endorsements.[U] Sea service equivalency may be substituted for
sea service required to qualify for an endorsement as second
mate.”
[/U]Elsewhere in the proposal it does stae that “recency” cannot be earned on a simulator.
also states that the [U]approved training programs[/U] list is maintained by NMC. (If the approved course contains simulator time why wouldn’t still count?)
If we’re having fun figuring this thang out, just think of the party the evaluator weenies at NMC are going to have!
Cheers!
[I][quote=rjbpilot;21314]Oooooh, they have a new acronym, (QSS) quality standard systems. Also it states that under 11.401, as I read it, the new proposal [U]will not [/U] count course time be used as sea-time. Sorry for all those who like to go to the simulator for sea time. Won’t be happ’nin.[/quote][/I]
[B]What lies behind the wisdom of removing the requirement of Deck officers to obtain the qualification of Able Seaman? Because they neglected to put it into the STCW code and don’t want to have to change the “new” code? This really has some issues. I don’t want to be “negative”, but I fail to see how that would be beneficial. I think they should change the STCW to be consistent with the “old” way.[/B]
[B]I did not consult Table A-II/1, but 11.401 extends the flashing light proficiency requirements to include [U]all[/U] mariners who serve on seagoing vessels. What the…Does that mean the engine and stewards department? :eek:[/B]
[QUOTE=rjbpilot;21344][B]What lies behind the wisdom of removing the requirement of Deck officers to obtain the qualification of Able Seaman? Because they neglected to put it into the STCW code and don’t want to have to change the “new” code? This really has some issues. I don’t want to be “negative”, but I fail to see how that would be beneficial. I think they should change the STCW to be consistent with the “old” way.[/B]
[B]I did not consult Table A-II/1, but 11.401 extends the flashing light proficiency requirements to include [U]all[/U] mariners who serve on seagoing vessels. What the…Does that mean the engine and stewards department? :eek:[/B][/QUOTE]
The old way? Several of the Unlimited Masters that I have worked with did not even get their AB until STCW. Kinda funny reading a company news letter that states UPGRADES - Unlimited Master to AB.
There are still AB requirements, as there always have been for certain licenses from what I read.
I was discussing the new proposals for 1st asst with several engineers. As we got to “Organizing and preparing for shipyard”, subject E “Pareto’s Rule” raised a flag.
One Chief postulated if this rule must be used, then of 80% of the new requirements, only 20% are relevant. And 80% of that 20, only 20% would effect keeping the lights on, the wheels turning, and the bilges dry. I don’t think he’s too far off the mark.
[I][quote=Jeffrox;21322]…also states that the [U]approved training programs[/U] list is maintained by NMC. (If the approved course contains simulator time why wouldn’t still count[/quote][/I]
The short answer is that the don’t, which is why it’s not new. Every course approval for sea time credit given in the past ten years is very specific on what it can be used for, the restrictions are clearly spelled out and match those in the policy letter.