STCW - New Notice of Proposed Rulemaking

[I][quote=Cal;21338]Not necessarily a big surprise, but when even REC’s don’t follow these how is the mariner supposed to know which ones to pay attention to?[/quote][/I]

The mariner can read the approal of the course they take. Every course approval given for the past ten years has had the same restrictions on sea time credit as are in the policy letter. For example:

[I]Any applicant who has successfully completed your XX-hour Animal Husbandry course will receive XX days sea service credit towards a near coastal or oceans license restricted to service upon vessels of not more than 200 gross registered tons or any license restricted to service upon Great Lakes or inland waters. This sea service credit may not exceed limits specified by law and may not be used to satisfy any recency requirements or requirements for service on specific routes or types of vessels.[/I]

Do you have specific examples of RECs not following the clear and unambiguous course approvals?

Were is this ANIMAL HUSBANDRY course and how much does it cost???:eek::eek::D:D

[quote=jdcavo;21421]The mariner can read the approal of the course they take. Every course approval given for the past ten years has had the same restrictions on sea time credit as are in the policy letter.

Do you have specific examples of RECs not following the clear and unambiguous course approvals?[/quote]

I wasn’t speaking specifically to restrictions on sea time credit but in general the NVIC’s and Policy Letters. Policy Letter 08-03 cleared up confusion over whether or not the Mariner needed to retake BST classes. Yet the New York and Hawaii REC’s (that I know of) required the mariner to retake BST if it had been 5 years since they had completed the courses.

Many of the course approvals [B]ARE[/B] “clear and unambiguous”, however, for some reason it still doesn’t prevent confusion. I recently completed a program that encompassed a number of other courses. Myself and another student submitted the program completion certificate. Another student submitted the program completion certificate and all of the individual course completion certificates. The application for the student that submitted just the program completion certificate sailed through the NMC, he’s already tested and has his license. The other student had the individual certificates scrutinized and the school had to become involved to clear up the confusion.

I checked the status of my application the other day and found this:

“The Coast Guard requires the following additional information from you: Advanced Fire Fighting Certificate, and Training Certificate(s).”

However if you look at the course approval description it states, “4) Satisfy the Basic and Advanced Fire Fighting training requirements of 46 CFR 11.205(d)(2) and 11.401(g)(1) for a license; the Advanced Fire Fighting training requirements of Section AVI/3 and Table A-VI/3 of the STCW Code; and the Fire Fighting training requirements of 46 CFR 13.201(e), 13.301(e), 13.401(d) or 13.501(e) for any tankerman endorsement.”

Now I’ll go ahead and provide them with whatever they request (provided I have the ability to do so), but why the delay to request something that is already covered? Why the inconsistency?

Please don’t take my comments as being over critical. I think consolidation to the NMC was a good idea, it has a way to go yet but I think they’ve done wonderful so far. When you consider the fact that my current application for a license cleared medical in 2 weeks and my application for AB 4 years ago took 12 months, consider me ecstatic!!!

[QUOTE=injunear;21398]I was discussing the new proposals for 1st asst with several engineers. As we got to “Organizing and preparing for shipyard”, subject E “[B]Pareto’s Rule[/B]” raised a flag.[/QUOTE]

Wikipedia:
“The Pareto principle (also known as the 80-20 rule, the law of the vital few, and the principle of factor sparsity) states that, for many events, roughly 80% of the effects come from 20% of the causes.”

Sweet, new term for me to use! I love it! Sorry, injunear, if I should have already known it, but I’m just a boat driver. :slight_smile:

Save your money. I’m sure Capt.Lee will help you out for a 6 pack of Bud.

If a requirement is specified in the program approval, you should not have to submit additional documentation, just evidence that you completed the entire program.

There is the way things should be and then there are the way things are. I submitted evidence that I completed the entire program with my application. Just emailed the Advanced Fire Fighting Certificate, asked what additional ones, specifically, and am waiting to hear before I submit them.

I’m wondering if they are going to piecemeal requests for additional information or if they are going to evaluate the entire submission and make complete requests. Time will see.

That table refers to OICNW’s. The proposal reads this:
[FONT=Courier][SIZE=3]
[LEFT]“Extends the flashing light proficiency requirement to those to whom the STCW Convention applies, i.e., all mariners serving on seagoing vessels. See Table AII/[/LEFT]
1 of the STCW Code.”
[FONT=Courier][LEFT]
In 11.401 of the proposal it reads: "

(i) An applicant for his or her first deck officer
endorsement authorizing service on vessels of 200 GRT/500GT or more on ocean or near-coastal waters must pass a practical signaling examination (flashing light). If the original or raise of grade did not require passing a practical signal examination, an applicant for a raise in grade or renewal will[/LEFT]
be required to pass this examination" (Make’s it seem to me like one only has to do it once?!?)

Later in the proposal on the Matrix for what subjects are testable for all the possible endorsements, that matrix indicates that only “AGT” have to test on flashing light. (Just like in the “old days”)

I guess all this helter skelter is what we should be commenting on to the DHS/USCG…
[/FONT][/SIZE][/FONT]

Roger that.

Does anyone have feeling when these new changes will take effect? I am close to an upgrade and am wondering how paranoid I should be. If it is close to summer 2010 I am going to take extreme measures to gather the required sea time. Thanks.

“It’s better, the Devil you know” (or something like that)

I was going to get assessed and test for my 3M, but after reading this it may be wise to wait and see, my 1600 ton master may take me straight to CM. With the tonnage time on an ITB

if the USCG have their way sometime summer 2010…there is a movement to postpone it though…suggest everyone go on the “docket” and “comment” requesting a delay!!

MAKE COMMENT @ Regulations.gov

Thanks Sea Dawg, made my comment. Where are you getting that Summer 2010 info from I’d like to read it myself if possible? Thanks again.

Diesel,
sorry…should possibly clarify further…the way I understand the current USCG time-line on this…comments end 2/16/2010>rules finalizes sometime summer 2010>rules should implement 6-12 months after that??

IMHO…while none of this is “writen in stone”…these proposed changes have been “in the pipe” for sometime…imagine the USCG wants to “get on with it”…don’t imagine they will grant much if any delay??

[B][I]**some good advise for dealing with the USCG that dates back 20 years…get as much as you can…whenever you can…as soon as you can…however you can!![/I][/B]

If they don’t go into in force until 2011 I’ll be good.

Do you call yourself Diesel because you operate at a slower RPM than everyone else?..you will still be good. There is a grandfather clause and more clarity on career paths than there were previously.

Nah, it’s because I am satisfied in less than 2 strokes. :smiley:

Mods please feel free to delete, just trying to get my post count up

[QUOTE=Diesel;23609]Nah, it’s because I am satisfied in less than 2 strokes. :smiley:

Mods please feel free to delete, just trying to get my post count up[/QUOTE]

Ohh…geez. Capt.Lee has a brother and he found his way to gCaptain.

[quote=Diesel;23609]Nah, it’s because I am satisfied in less than 2 strokes. :smiley:

Mods please feel free to delete, just trying to get my post count up[/quote]

So you’re not an EMD guy? Detroit only?