[quote=water;26793]This is the first time we’ve seen a possible effective date for the rule changes, which is very helpful for mariners scrambling to get their final classes or sea time in to qualify for an upgrade. Several contributors have offered estimates.
Any idea how the newsletter came up with that date?
The NMC has failed to respond to an email with the question about an effective date. I do know that the USCG wants to fast track the changes.[/quote]
No one in the Coast Guard is permitted to respond to these questions outside of a public meeting. Don’t waste the NMC’s time asking. Also, it’s not their decision to “fast track” policy or regulations. Those decisions are made at CG HQ.
[quote=RkyMtn Paul;26808]As far as timing of implementation, does this give any insight? Found on MM&P Weekly Wheelhouse.
[B]FOUNDATION FOR STCW CONVENTION AND CODE REVISION NOW IN PLACE[/B]
The International Maritime Organization Subcommittee on Standards of Training and Watchkeeping (STW) has approved draft amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (the STCW Convention), and its associated Code. The proposed amendments will be submitted for adoption to a diplomatic conference in Manila on June 21-25.
The proposed amendments mark the first major revision of the two instruments since 1995. MITAGS Executive Director Glen Paine participated in the U.S. delegation to the meetings, and MM&P Pilots Vice President George Quick was on the International Transport Workers Federation delegation, which represented the interests of labor.[/quote]
This refers to the new 2010 amendments to STCW. The current proposed rule making is to implement the [U][B]1995[/B][/U] amendments.
[QUOTE=jdcavo;26813]This refers to the new 2010 amendments to STCW. The current proposed rule making is to implement the [U][B]1995[/B][/U] amendments.[/QUOTE]
Yes, Mr. Cavo, that is quite a bit of help. That is the all the insight I needed, as that is an important distinction. Look we're sorry to put you on the spot like this. You are a TREMENDOUS asset on here, and I for one am very grateful, as I'm sure is everyone else. They tell us to ask Mark Gould if we have any questions, but if it weren't for you we wouldn't even know that NMC personnel aren't allowed to comment. We would be waiting an eternity for answers that were never going to come. Everyone's big question is about this July 2010 timeframe that is circulating, but no one seems to know where it came from, certainly not from the coast guard. It is floating around on email flyers from training schools with no references or substantiation, just speculation. Just continue to guide us to where we can find our own answers and draw our own conclusions, as best as you can, and like you just have. Thank You, and Regards
Fellas, It appears to me we are looking at two different things here. What is coming up is just the CG attempt to implement what was passed 15 years ago. They could I guess theoretically implement at any time. The 2010 rewrites won’t go into effect for years. I’m just going to continue and hope for Fall or Winter 2010 implementation. If not then I guess plan B. Hopefully, the veil of secrecy will be lifted soon and a clearer picture will emerge. I’m sure some of these schools are using this opportunistically to drum up some business, which is where all these newsletters are coming from. Keep putting out stuff you find though because we are all on the edge of our seats.
[QUOTE=Diesel;26817]Fellas, It appears to me we are looking at two different things here. What is coming up is just the CG attempt to implement what was passed 15 years ago. They could I guess theoretically implement at any time. The 2010 rewrites won’t go into effect for years. I’m just going to continue and hope for Fall or Winter 2010 implementation. If not then I guess plan B. Hopefully, the veil of secrecy will be lifted soon and a clearer picture will emerge. I’m sure some of these schools are using this opportunistically to drum up some business, which is where all these newsletters are coming from. Keep putting out stuff you find though because we are all on the edge of our seats.[/QUOTE]
Nobody, and I mean nobody from the Coast Guard is allowed to comment on the answers that most of you guys want. There are laws to restrict this. The only way that the Coast Guard can comment, or we can give any feedback - has to be in a full open forum. That was the purpose of comment period and nationwide meetings. It was a legal requirement to facilitate conversation with the public. In my opinion, the comment period will yield no results. Mainly, because how long its been since STCW’95 went into effect and how long the USCG has had to get this right. I doubt they listen at all, but if the Coast Guard decided to change the propose rule, nothing will happen this year. The process will start over and public comment will need to happen regarding the changes.
No one is being deliberately evasive. The Administrative Procedures Act and oter similar laws are pretty clear on what Federal employees and can and can’t say. and when and where they can comment.
[I][quote=Diesel;26817]…The 2010 rewrites won’t go into effect for years…[/quote][/I]
The 2010 amendments will “enter into force” January, 2012. This is the date in the STCW for countries to adopt them. The date for the 1995 amendments was February 1, 2002.
The 2010 amendments will “enter into force” January, 2012. This is the date in the STCW for countries to adopt them. The date for the 1995 amendments was February 1, 2002.[/QUOTE]
So the date that is in question is the ending of the “Interim Rule?” I think I’m catching on.
Thank you Anchorman - I’ve been continuing checking with other sources (outside of the USCG) knowledgeable with the proceedure, and they confirmed your posting. Apparently if there are any changes, they will have to be published again in the Federal Register, and the public will have the 90 day comment period.
There are a lot of comments coming in that they will have to deal with.
So it looks like there will be a period of time that the USCG will have to respond to the comments, and then at least 90 days after the final changes are published in the Federal Register.
Thanks to gCaptain for this forum. I’d be lost in the wilderness without it.
[QUOTE=water;26889]Thank you Anchorman - I’ve been continuing checking with other sources (outside of the USCG) knowledgeable with the proceedure, and they confirmed your posting. Apparently if there are any changes, they will have to be published again in the Federal Register, and the public will have the 90 day comment period.
There are a lot of comments coming it that they will have to deal with.
So it looks like there will be a period of time that the USCG will have to respond to the comments, and then at least 90 days after the final changes are published in the Federal Register.
Thanks to gCaptain for this forum. I’d be lost in the wilderness without it.
Thanks, too, for all who post here.[/QUOTE]
Maybe bureaucracy can work in our favor this time. Overall I like a lot of the changes, but there are some issues that need to be addressed and ironed out still…
I’ve started a new thread to pick up where this one left off.
In particular, I am hoping that there are other mariners who will take the time to contact their members of Congress to influence the USCG to “re-think” their approach to this rulemaking to more closely reflect the actual working experience of the vast majority of Licensed Mariners in the USA.
This is from the MMP website. The last paragraph makes a lot of sense, but their objection to the proposed path to Unl Master is Fallacious. Ships Masters, et al, aren’t hired for the job solely on the fact they hold the license, experience that satisfies the ships owners is always in play.
[B]USCG PROPOSAL TO CUT SEA-TIME REQUIREMENTS FOR MASTER’S LICENSE A SAFETY RISK[/B]
MM&P has told the Coast Guard it should hold off on proposing controversial changes to licensing regulations until the Standards of Training, Certification and Watchkeeping (STCW) Code of 2010 takes effect. The union is also warning that the changes being proposed by the Coast Guard, in particular a reduction in sea service requirements for the unlimited tonnage master’s license, will diminish professional standards in the industry and could seriously compromise maritime safety.
The Coast Guard’s proposed regulations would allow a third or second mate to progress to an unlimited master’s license with only 36 months’ service as a third or second mate and no experience at all as a chief mate. “This is a substantial and alarming reduction in the current U.S. regulatory standards for holding a license to serve as a master of a ship of unlimited tonnage,” the union said. “To permit a progression from third or second mate to unlimited master without any required sea service as chief mate will create a situation where an individual with experience as only a junior officer at the operational level will be licensed by the Coast Guard to exercise overall command responsibilities and oversee and supervise the performance of a chief mate’s duties even though he has no actual experience that demonstrates proven proficiency in performing a chief mate’s duties.”
“We urge you to retain the requirement of at least six months’ service as a chief mate on ships of unlimited tonnage before progressing to master unlimited,” the union said. The union also took issue with a Coast Guard proposal to allow a third mate with only 12 months’ service as an OICNW to progress directly to chief mate unlimited tonnage.
“The proposed changes in the Federal Register are extensive, complex and confusing, and will have substantial consequences, some unintended and negative, for the mariner community and their training facilities,” the union said. In addition, the Coast Guard proposals are outdated in that they address the 1995 version of the STCW Code. This means that an additional round of rulemaking will be necessary to bring U.S regulations into conformity with the new revised STCW Code of 2010.
“A prudent and rational course of action would be to postpone implementation of this rulemaking until the new provisions of the STCW Code of 2010 can be taken into account,” the union said. “We request that implementation of the present notice of proposed rulemaking be delayed until the provisions of the STCW Code of 2010 can be taken into account, and then U.S. regulations brought into conformity with the STCW Code of 2010 in one, five-year transition period.”
[I][quote=Jeffrox;27529]“A prudent and rational course of action would be to postpone implementation of this rulemaking until the new provisions of the STCW Code of 2010 can be taken into account,” the union said. “We request that implementation of the present notice of proposed rulemaking be delayed until the provisions of the STCW Code of 2010 can be taken into account, and then U.S. regulations brought into conformity with the STCW Code of 2010 in one, five-year transition period.” [/quote][/I]
[B]That is too practical and efficient for government work. [/B]
I do…
Legislated right out of the industry! We’re headed for a ringknockers only club. I don’t mean to bash the academy boys, but the academy can’t teach you how to be a captain. That comes from time and experience. The academies have the money and political clout to throw their weight around and push their agenda. Who does the hawspiper have?