I apologize in advance that this question is not directly on topic, but there seem to be a few individuals here who might know the answer.
The scenario:
I have information and records showing that a US-flagged ship hauling supplies and cargo under a US government contract is using foreign seafarers (not citizens of the US, etc.) on the crew as ABs and OMUs. They have no MMC or TWIC credentials.
The question:
Can you tell me what section of the US Coast Guard I can contact to provide the information and records I have?
What do you have? At a minimum I would think you need the vesselās COI and a copy of the IMO crewlist that shows the people onboard arenāt qualified to meet the COI.
If itās really definitive proof of what you say, I would draw up an email with those documents attached and send it to the company whoās operating illegally, DOT, MARAD, USCG, USCBP, your Congress reps, Congress reps that are pro Jones Act/maritime, and maritime media outlets like Workboat magazine and gCaptain.
All these email addresses should be readily available via Google searches. Make all addresses visible so everybody knows who else is in copy.
In a lot of cases, all it takes is one of these entities to start asking āhey, what are you going to do about this?ā to get something rolling.
Obviously you need to have your shit together before you send it otherwise youāll look like an idiot.
@RiverRats, do they work in US waters? And if so, do they have enough American MMC holders to cover the minimum required on the COI? Iāve been through countless OSVās USCG inspections with only 2 Americans on board. USCG never seemed to mind as long as the foreign mariners had STCWs & docs from their home country to meet the COI. Back then the the foreign unlicensed mariners had to be relieved the minute the vessel tied up at a US port but I heard a couple of years ago American delivery crew mariners now have to meet the vessels outside of the US if itās headed back into the US.
Most definitely. Many countries like Mexico, Brazil, Nigeria, Angola etc. have strict labor laws similar to the Jones Act that requires local crews on board. Some companies only keep American Capts on US flag vessels, others American Capt & CE & at Otto Candies they had a couple of US flagged vessels that kept American Bosuns. I donāt ever recall US unlicensed working the oil fields outside of the US unless it was a speciality vessel like seismic, well stimulation or research for a short term job.
Absolutely, many US flagged vessels work in other countries waters, some with only a US Master and CE. Just as many foreign flagged vessels operate in US waters. As long as they donāt engage in commerce between US ports they are OK. To my knowledge since the demise of the GSF Explorer there are no US flagged drillships but there are and have been a lot of foreign built drillships and semiās working in the US for many years.
Couldnāt agree more. But just because theyāre directed to not enforce laws in one area of their scope doesnāt mean they should or will be delinquent in other areas.
Which is exactly the attitude Colin Grabow and his ilk want to see.
[quote=ājdcavo, post:11, topic:64302ā]
See 46 USCā¦[/quote]
Thanks for the link, that clears up the citizenship issue.
What I was focused on was the OPs claim that they didnāt have MMCs. Although the link doesnāt address it, I guess the assumption is that these allowed foreigners are not required to have work authorization in the US and thus would not be eligible for an MMC.
Although this carve-out doesnāt affect my sector of shipping, I find it unfortunate that our flag state allows completely unvetted personnel to work on vessels flying our flag.
Not entirely unvetted, as far as experience and training, although you might question the scope of the vetting and who has to do it. See 46 CFR 15.720(d).