STCW - New Notice of Proposed Rulemaking

[quote=TxKingfisher;27567]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 hawsepiper have?[/quote]

I was able to work my way up to Master 1,600GRT(NC) through self-study by using the 5 MET “blue books” that some of you may be familiar with, as well as attending formal training at various institutions for radar/ff/1st aid/STCW BST/GMDSS and so on. I resent the hell out of the fact that the route I took is no longer possible, no matter how motivated the individual.

If we can generally agree that the multiple-choice written examination is simply an easily-administered system for measuring (not terribly well, at that) how much memorized book knowledge an individual has [B]at the time[/B] they take the tests, then here’s the important question: [B]why does it matter at all how and where one comes by that book knowledge?[/B]

Whether learned in a class room or by self-study, the test is the same test and requires the same knowledge to pass. It should make no difference how you arrive at the point of possessing that knowledge. I can only assume (perhaps wrongly, but I doubt it) that the disproportionate influence wielded by the academies and other training institutions has been used to their financial gain by forcing everyone into schools when the need for that is highly questionable. That, coupled with the mistaken and pervasive belief that more training will fix all problems. To be sure, I fully believe that some subjects, such as stability and some of the more advanced parts of navigation, are often best learned in the classroom. Engineers, too, can benefit a great deal from classroom and shop-based technical/theory training. But it doesn’t have to apply to every subject all the time. Either this is all a carefully-planned and executed racket to unnecessarily force everyone into mostly for-profit schools to learn that which they could learn another way or else the leadership of the IMO and the Coast Guard is so incredibly misguided or incompetent that they just can’t see the harm they are doing. We should seriously consider withdrawing from the STCW Convention if this is how it’s going to be from now on.

It just sucks to know that you got to spend a whole lot of money and then, the CG comes and shut the door on you just like that! All this sea time crap that you got to have, all these courses you got to pay big bucks not mentioning lodging and food that most companies won’t pay you for, while in the academy you attend for 4 years but you dont need the sea time and all other crap and yet you come with a big unlimited license, sure if you get to work on ships it’s the requirements but for us that works on tugs you need more than that unlimited license, you need to know how to handle a tug and barge and that you wont learn in the academy! Yet, we people that comes from the deck and have experience in most of these aspects are running risk of being kicked out of what we have been doing for years.

I do agree with your comments.

I coudnt agree mor CptJackSparrow!
I fought my way up from the deck of a shrimp boat to 500NC/3000OSV Master. The government was successful at starving me out of the commercial fishing business (3rd generation) and it looks like it may be just a matter of time before they starve me out of this sector as well. On the bright side, with the new rules I get an automatic bump from 500-1600!:slight_smile: But, by the time they get around to giving it to me I will most likely have upgraded on my own anyway.:mad:

I wonder if the United States Confused Guys (USCG) will give time for mariners to prepare for all these chenges?

[quote=TxKingfisher;27586]I coudnt agree mor CptJackSparrow!
I fought my way up from the deck of a shrimp boat to 500NC/3000OSV Master. The government was successful at starving me out of the commercial fishing business (3rd generation) and it looks like it may be just a matter of time before they starve me out of this sector as well. On the bright side, with the new rules I get an automatic bump from 500-1600!:slight_smile: But, by the time they get around to giving it to me I will most likely have upgraded on my own anyway.:mad:[/quote]

As long as people pay attention to what’s going on it’s unlikely that anyone will be “forced out” by the new regulations per se, as the CG has already stated their intent to grandfather existing license-holders as they’ve done in the past. But it [B]will[/B] become much more difficult to move up to a higher grade, and some of the requirements (flashing light) are just plain silly. A lot of this is being driven by the companies, under intense direct pressure from their customers and insurers, who want bigger licenses when they aren’t required and are of questionable value. The towing industry is having a hell of a time with this right now. Only towing vessels of over 200GRT on near coastal or oceans routes actually require the favored license [I]du jour[/I], aka the 1,600GRT, and relatively few of these boats exist. More importantly, I’ve yet to see solid evidence presented by any credible source that shows that the modern towing licenses are somehow inadequate. If the knowledge standards for those licenses need to be improved then lets study the problem and make the necessary changes to the test question database and course curriculum. Turning its back on our own license structure was the worst thing the towing industry could have done…

[QUOTE=TUG4LIFE1968;27595]I wonder if the United States Confused Guys (USCG) will give time for mariners to prepare for all these chenges?[/QUOTE]

Let us Pray

[quote=Capt. Fran;26778]

To obtain 1600 GRT Mate or Master, applicant must qualify for AB and RFPNW (the requirement is a hurdle for all new applicants for ANY Ocean or NC Int’l Mate or Master license.)

.[/quote]

Capt Fran, I know this wasn’t yours but can you or anyone tell me the page or reference number to this??..On page 7, 11.401, of the new proposals, it talks about removing the AB requirement …

Also, if an individual were to accomplish all of the OICNW courses, assessments and required sea time, wouldn’t they already surpass RFPNW?

Shellback, I think that has someting to do with an earlier time when say, 500ton master wasn’t also holding an AB, they had to get AB before increasing to 1600 master. I knew a guy like that

Thanks Jeff, I have a skipper now, that falls under that category…

I just haven’t seen the passage in the proposal, except the portion I already stated, which was in contrast to what Capt Fran’s, ( stolen :wink: ) news letter said…Trying to get a handle on this crap before I dump any more money into this quest…

Now that the comment period has passed a few weeks ago, has anyone heard any updates to the proposed changes??

I wonder what kind of time frame until any information will be released to the public we should expect. I am one of the guys that is scrambling to get the last class I need ( AFF ) before applying for my 500 GRT Master upgrade. It will be a relief when I finally get the application in and hopefully receive my approval to test letter.

Anyone have something to share w/ the rest of us?

Attended both days of Towing Vessel Advisory Committee and both days of Merchant Marine Personnel Advisory Committee in New Orleans last week representing the National Mariners Association. STCW was a very hot Topic. Most of the public Comments were strongly against the proposed regulation changes. Both management and unions claimed the proposed regs would greatly hurt the industry. There is also a question concerning the legality/constitutionally of the proposed regs. since the U.S. Senate never ratified the 1995 amendments. There is also scuttlebut that a formal inquary has gone to the Dept. of State IMO section with this question. Get every thing you can right now, as soon as possible. Appears CG believes we all need more Formal Training, meaning time in a classroom, and to hell with the cost.
Chief

[I][quote=chief;29200]…There is also a question concerning the legality/constitutionally of the proposed regs. since the U.S. Senate never ratified the 1995 amendments…[/quote][/I]

This theory is not new. Indeed, at the MERPAC meeting among the handouts at the table by the door wasa re-print of a 1998 article in the National Association of Maritime Educators newsletter written by the same outspoken individual that is the main proponent of this argument.

From the USCG

Announcements:

March 23, 2010

The Coast Guard announces that it is revisiting the approach proposed in the Notice of Proposed Rulemaking (NPRM) on the Implementation of the 1995 Amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as published in the Federal Register on November 17, 2009.

In response to feedback we have received and to the expected adoption of the 2010 amendments to the Convention under development at the IMO, the Coast Guard is reviewing the approach outlined in the NPRM. As such, we are considering publishing a Supplemental NPRM (SNPRM) as a next step. The SNPRM would describe any proposed changes from the NPRM, and seek comments from the public on those proposed changes.

For complete details, please view the March 23, 2010 Federal Register Notice at http://edocket.access.gpo.gov/2010/pdf/2010-6297.pdf.

Sharp eye, there, Capt Fran!

Thank You!

Excerpt from Federal Register Vol. 75, No. 55 / Tuesday, March 23, 2010 / Proposed Rules

"The International Maritime Organization (IMO) is currently developing amendments to the STCW Convention that are expected to be adopted at a diplomatic conference in June 2010. If adopted, these amendments will change the minimum training requirements for seafarers. They are expected to enter into force in accordance with Article XII of the Convention on January 1, 2012 for all countries that are party to the STCW Convention.

In response to feedback we have received and to the expected adoption of the 2010 amendments to the Convention under development at the IMO, the Coast Guard is reviewing the approach outlined in the NPRM. As such, we are considering publishing a Supplemental NPRM (SNPRM) as a next step. The SNPRM would describe any proposed changes from the NPRM, and seek comments from the public on those proposed changes."

Good News, and the most logical i think given the proposed 2010 amendments. Thanks Captain Fran!

wouldn’t get too excited just yet…the operative word is??

In response to feedback we have received and to the expected adoption of the 2010 amendments to the Convention under development at the IMO, the Coast Guard is reviewing the approach outlined in the NPRM. As such, we are[B][I] considering[/I][/B] publishing a Supplemental NPRM (SNPRM) as a next step. The SNPRM would describe any proposed changes from the NPRM, and seek comments from the public on those proposed changes