# USCG Proposed Rule - STCW 2010 **URL:** \ **Category:** Maritime Training & Licensing\ **Created:** [August 1, 2011, 4:16am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972 "2011-08-01T04:16:48Z")\ **Posts on this page:** 20\ **Page:** 2
**Author:** ![Sukker](https://avatars.discourse-cdn.com/v4/letter/s/46a35a/32.png) [@Sukker](https://forum.gcaptain.com/u/Sukker)\ **Post date:** [August 3, 2011, 7:02am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/21 "2011-08-03T07:02:03Z")
Check out the checklist for C/M [http://www.uscg.mil/nmc/checklists/MCP-FM-NMC5-31%20Chief%20Mate%20AGT.pdf?list1=checklists%2FMCP-FM-NMC5-31+Chief+Mate+AGT.pdf&B1=GO!](http://www.uscg.mil/nmc/checklists/MCP-FM-NMC5-31%20Chief%20Mate%20AGT.pdf?list1=checklists%2FMCP-FM-NMC5-31+Chief+Mate+AGT.pdf&B1=GO%21) No longer does it require classes! ---
**Author:** ![Flyer69](https://sea2.discourse-cdn.com/flex016/user_avatar/forum.gcaptain.com/flyer69/32/6000_2.png) [@Flyer69](https://forum.gcaptain.com/u/Flyer69)\ **Post date:** [August 3, 2011, 7:20am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/22 "2011-08-03T07:20:27Z")
[QUOTE=TJ;53533]I just read through all 175 pages, and I also have a headache… It seems clear that I can go from my 1600T Master to STCW endorsement as Unlimited Master with sea time, some limited classes, and assessments, but what about “provide evidence of meeting the standard of competence specified in STCW A-II/2” it appears that all but ARPA can be from on board experience. Now that I have this STCW endorsement as Unlimited Master, can I use it on a U.S. vessel? The requirements for a “domestic deck officer endorsement” (11.402) still require half of the required experience be from vessels over 1600T/3000ITC, furthermore, it looks like you still need the normal progression of seatime while holding 3/m to go to 2/m, 2/m to c/m… Does anyone else make any sense of this???[/QUOTE] Doesn’t your STCW already have A-II/2 on it? ---
**Author:** ![Sukker](https://avatars.discourse-cdn.com/v4/letter/s/46a35a/32.png) [@Sukker](https://forum.gcaptain.com/u/Sukker)\ **Post date:** [August 3, 2011, 7:37am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/23 "2011-08-03T07:37:44Z")
[ATTACH]1326[/ATTACH] I’ve combined the previous checklist and the current one off the NMC website. Look under the STCW Management Level Requirements Section ---
**Author:** ![power230](https://avatars.discourse-cdn.com/v4/letter/p/5daacb/32.png) [@power230](https://forum.gcaptain.com/u/power230)\ **Post date:** [August 3, 2011, 7:58am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/24 "2011-08-03T07:58:55Z")
> [@"anchorman"](#): > > Don’t get confused with the STCW endorsement requirements, the service requirements, and professional requirements. The Chief OSV will not need an Unlimited Chief to sign assessments. Another Chief OSV will be able to do that since the endorsement you are talking about will be required to become a Chief OSV to begin with. Hence, no more time needed for the STCW endorsement, but this is separate of the professional requirements. Definitely confused. Are you saying there will still be a OSV license? By reading that, it look just what I stated. Chief limited are considered management at the present time and would require sea service to obtain that license. So how does the Chief OSV not? ---
**Author:** ![boattrash](https://avatars.discourse-cdn.com/v4/letter/b/f19dbf/32.png) [@boattrash](https://forum.gcaptain.com/u/boattrash)\ **Post date:** [August 3, 2011, 8:06am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/25 "2011-08-03T08:06:43Z")
Come on now, did ya’ll really think for a moment that this would not be confusing? ---
**Author:** ![anchorman](https://avatars.discourse-cdn.com/v4/letter/a/bbce88/32.png) [@anchorman](https://forum.gcaptain.com/u/anchorman)\ **Post date:** [August 3, 2011, 8:10am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/26 "2011-08-03T08:10:16Z")
[QUOTE=power230;53542]Definitely confused. Are you saying there will still be a OSV license? By reading that, it look just what I stated. Chief limited are considered management at the present time and would require sea service to obtain that license. So how does the Chief OSV not?[/QUOTE] Because the OSV mariner has to be management level as well (some OSV’s are 30,000hp and 6,000 GT), on the STCW side (same requirements). That’s how I read it. That doesn’t take away the fact that to become unrestricted he still has to follow the path he does now. ---
**Author:** ![Sukker](https://avatars.discourse-cdn.com/v4/letter/s/46a35a/32.png) [@Sukker](https://forum.gcaptain.com/u/Sukker)\ **Post date:** [August 3, 2011, 12:28pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/27 "2011-08-03T12:28:33Z")
[QUOTE=anchorman;53544]Because the OSV mariner has to be management level as well (some OSV’s are 30,000hp and 6,000 GT), on the STCW side (same requirements). That’s how I read it. That doesn’t take away the fact that to become unrestricted he still has to follow the path he does now.[/QUOTE] The OSV Mariner still has to fulfill the C/M Seatime (i.e. 6 months) and tonnage to become Master Unlimited. ---
**Author:** ![anchorman](https://avatars.discourse-cdn.com/v4/letter/a/bbce88/32.png) [@anchorman](https://forum.gcaptain.com/u/anchorman)\ **Post date:** [August 3, 2011, 4:04pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/28 "2011-08-03T16:04:04Z")
[QUOTE=Sukker;53560]The OSV Mariner still has to fulfill the C/M Seatime (i.e. 6 months) and tonnage to become Master Unlimited.[/QUOTE] Yes, there are no new loop holes or anything like that, and I’m sure for the most part, the Coast Guard’s biggest challenge was to make sure they don’t create major loop holes in such a big regulation change. STCW endorsements seem to be easier now, for the mariner, not in quantity or substance, but in flexibility with shipboard assessments, and I am trying to discern some of the double speak that I have read so far. Some assessments will be impractical on a ship, unless the owner gives you the ship for a day just to go play around - I don’t see that happening, but the opportunities are there more often then not when comparing getting into a class that isn’t taught on your scheduled time off. It’s easy to get confused with license requirements (service) and STCW officer endorsements, which are two different animals. ---
**Author:** ![Sukker](https://avatars.discourse-cdn.com/v4/letter/s/46a35a/32.png) [@Sukker](https://forum.gcaptain.com/u/Sukker)\ **Post date:** [August 3, 2011, 5:02pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/29 "2011-08-03T17:02:12Z")
[QUOTE=anchorman;53569]Yes, there are no new loop holes or anything like that, and I’m sure for the most part, the Coast Guard’s biggest challenge was to make sure they don’t create major loop holes in such a big regulation change. STCW endorsements seem to be easier now, for the mariner, not in quantity or substance, but in flexibility with shipboard assessments, and I am trying to discern some of the double speak that I have read so far. Some assessments will be impractical on a ship, unless the owner gives you the ship for a day just to go play around - I don’t see that happening, but the opportunities are there more often then not when comparing getting into a class that isn’t taught on your scheduled time off. It’s easy to get confused with license requirements (service) and STCW officer endorsements, which are two different animals.[/QUOTE] Ok, maybe in the end I haven’t gotten as …ked like I originally thought. Especially when the owner handed over the vessel for not 1 day but 4 days to burn fuel and do things that I would normally never have the opportunity to do. Make sure we keep record of me saying something positive because this never happens. ---
**Author:** ![Cal](https://avatars.discourse-cdn.com/v4/letter/c/f1d935/32.png) [@Cal](https://forum.gcaptain.com/u/Cal)\ **Post date:** [August 3, 2011, 5:48pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/30 "2011-08-03T17:48:40Z")
8 years with the same employer in the Northeast. If you want any Near Coastal license over 200 GRT you have to take the required Operational Level STCW courses. Juggled the work schedule, lost some wages in the process, and sacrificed time at home in order to get my 1600 Ton Mate. One year and five months after I get my license they change the policy and I could now do assessments for the majority of the courses and test. Now put the word “Advanced” in front of every class I took at the operational level and that’s what I have to do if I should ever choose to upgrade to Master in order to comply with the management level requirements. Can’t upgrade my 3rd Mate to 2nd Mate and take a crossover test because I’m working as a Mate on an Inland tug. It simply isn’t possible for me to have sufficient inland sea time (or anywhere close to it) in order to upgrade the 1600 Ton Mate to 1600 Ton Master prior to 1/1/2012. I try to be a positive person, but I’m having a hard time swallowing this one at the moment. ---
**Author:** ![anchorman](https://avatars.discourse-cdn.com/v4/letter/a/bbce88/32.png) [@anchorman](https://forum.gcaptain.com/u/anchorman)\ **Post date:** [August 3, 2011, 7:28pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/31 "2011-08-03T19:28:40Z")
[QUOTE=Cal;53580]8 years with the same employer in the Northeast. If you want any Near Coastal license over 200 GRT you have to take the required Operational Level STCW courses. Juggled the work schedule, lost some wages in the process, and sacrificed time at home in order to get my 1600 Ton Mate. One year and five months after I get my license they change the policy and I could now do assessments for the majority of the courses and test. Now put the word “Advanced” in front of every class I took at the operational level and that’s what I have to do if I should ever choose to upgrade to Master in order to comply with the management level requirements. Can’t upgrade my 3rd Mate to 2nd Mate and take a crossover test because I’m working as a Mate on an Inland tug. It simply isn’t possible for me to have sufficient inland sea time (or anywhere close to it) in order to upgrade the 1600 Ton Mate to 1600 Ton Master prior to 1/1/2012. I try to be a positive person, but I’m having a hard time swallowing this one at the moment.[/QUOTE] And the thing is, you may not have been required to do those classes either, even before the new policy 07-11 came out. Same thing will go for the Chief Mate/ Master courses, and I mean now, not in many months after the new SNPRM becomes rule. There was a driving force of why policy 01-02 got changed, and it certainly wasn’t because it was right to begin with, or it would not have changed. Sounds logical. I think several appeals by mariners, to USCG headquarters (an area that Cavo cannot speak to most likely), was the driving force behind the change, but I’m glad it did change for the future mariner. There were many requests to change policy letter 01-02 over the years, but I never thought requirements in NMC policy were overstepping authority by not having regulations in place validate those requirements. Think about it, there is nothing anywhere that says you have to be in a 2 week class for ship handling - besides in a NMC policy letter. What weight does a policy letter hold if there is nothing in the regulations, or STCW for that matter? There are requirements obviously, but nothing to the extent of what NMC policy has mandated in one certain way. At least there is a mechanism for a mariner to appeal to USCG headquarter, but too bad we need it, and thank god it works. ---
**Author:** ![Cal](https://avatars.discourse-cdn.com/v4/letter/c/f1d935/32.png) [@Cal](https://forum.gcaptain.com/u/Cal)\ **Post date:** [August 3, 2011, 8:14pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/32 "2011-08-03T20:14:51Z")
You’re right Anchorman. Part of the problem for me though was merely trying to figure this industry out. I never thought of garnering the experience and then appealing a denial. Armed with my experience, the whole of it, not just the courses and the license process I went through, and recent events, you can bet I will be documenting and arguing it the next time. Just frustrated at the moment and not willing to bury my head in CFR’s to make sure I dot all of my i’s and cross all of my t’s. ---
**Author:** ![power230](https://avatars.discourse-cdn.com/v4/letter/p/5daacb/32.png) [@power230](https://forum.gcaptain.com/u/power230)\ **Post date:** [August 3, 2011, 8:58pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/33 "2011-08-03T20:58:07Z")
1. Grandfathering and Transitional Provisions The Coast Guard proposes transitional and grandfathering provisions consistent with the 2010 amendments to the STCW Convention. The 2010 amendments to the STCW Convention will enter into force on January 1, 2012. However, STCW Regulation I/15 on transitional provisions, allows requirements to come into effect over a 5-year period in order to avoid disruption to the maritime industry. STCW Regulation I/15 also provides that a Party may continue, until January 1, 2017, to issue certificates (MMC) in accordance with the credentialing rules it has in place before the 2010 amendments come into force (January 1, 1. only with respect to seafarers who begin their sea service or their approved maritime training before July 1, 2013. Candidates who begin their service or their training on or after July 1, 2013, will be subject to the full application of the revised STCW requirements. The Coast Guard has drafted this SNPRM to allow for this phase-in process. These provisions require any seafarer who holds an STCW endorsement prior to January 1, 2012, to provide evidence of meeting the appropriate standard of competence for the applicable STCW endorsement by January 1, 2017. Domestic requirements provided in this proposed rule will be transitioned during a 5-year period (after the effective date of the final rule) to coincide with the renewal of existing domestic endorsements. Individuals seeking an original credential or raise of grade to an existing credential during this period, and who begin training or service before January 1, 2012, need only meet the requirements in place before that date. Those individuals who start training or service on or after January 1, 2012, must meet all provisions described in the final rule. Seems to me we can go about the current way until 2017 with upgrades and so forth. ---
**Author:** ![PR-9](https://avatars.discourse-cdn.com/v4/letter/p/3e96dc/32.png) [@PR-9](https://forum.gcaptain.com/u/PR-9)\ **Post date:** [August 4, 2011, 2:12am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/34 "2011-08-04T02:12:02Z")
> [@"anchorman"](#): > > Yes, there are no new loop holes or anything like that, and I’m sure for the most part, the Coast Guard’s biggest challenge was to make sure they don’t create major loop holes in such a big regulation change. STCW endorsements seem to be easier now, for the mariner, not in quantity or substance, but in flexibility with shipboard assessments, and I am trying to discern some of the double speak that I have read so far. Some assessments will be impractical on a ship, unless the owner gives you the ship for a day just to go play around - I don’t see that happening, but the opportunities are there more often then not when comparing getting into a class that isn’t taught on your scheduled time off. It’s easy to get confused with license requirements (service) and STCW officer endorsements, which are two different animals. Anchorman, so are the C/M classes a thing of the past? I saw the checklist that Sukker posted. ---
**Author:** ![anchorman](https://avatars.discourse-cdn.com/v4/letter/a/bbce88/32.png) [@anchorman](https://forum.gcaptain.com/u/anchorman)\ **Post date:** [August 4, 2011, 6:16am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/35 "2011-08-04T06:16:27Z")
[QUOTE=PR-9;53598]Anchorman, so are the C/M classes a thing of the past? I saw the checklist that Sukker posted.[/QUOTE] I am saying that I would not take any course that wasn’t in the CFR, in regulation, complete assessments, and appeal any requirement past that. ---
**Author:** ![Cal](https://avatars.discourse-cdn.com/v4/letter/c/f1d935/32.png) [@Cal](https://forum.gcaptain.com/u/Cal)\ **Post date:** [August 4, 2011, 11:08am UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/36 "2011-08-04T11:08:34Z")
[QUOTE=power230;53591]Seems to me we can go about the current way until 2017 with upgrades and so forth.[/QUOTE] Thanks Power, I had read that a couple of times but I guess I was glazing over it in a panic. It may make things interesting over the years but it’s not a complete show stopper the way I was interpreting it to be. ---
**Author:** ![Capt\_Phoenix](https://sea2.discourse-cdn.com/flex016/user_avatar/forum.gcaptain.com/capt_phoenix/32/281_2.png) [@Capt\_Phoenix](https://forum.gcaptain.com/u/Capt_Phoenix)\ **Post date:** [August 4, 2011, 2:09pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/37 "2011-08-04T14:09:33Z")
Can someone give a page number for the references to changes in unlimited tonnage requirements? I an trying to view the .pdf on my phone and I need a place to start. ---
**Author:** ![anchorman](https://avatars.discourse-cdn.com/v4/letter/a/bbce88/32.png) [@anchorman](https://forum.gcaptain.com/u/anchorman)\ **Post date:** [August 4, 2011, 2:18pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/38 "2011-08-04T14:18:38Z")
[QUOTE=Capt. Schmitt;53631]Can someone give a page number for the references to changes in unlimited tonnage requirements? I an trying to view the .pdf on my phone and I need a place to start.[/QUOTE] Try page 81, as far as Officer Endorsements over 3,000 tons…that is the biggest change I have seen. ---
**Author:** ![Capt\_Phoenix](https://sea2.discourse-cdn.com/flex016/user_avatar/forum.gcaptain.com/capt_phoenix/32/281_2.png) [@Capt\_Phoenix](https://forum.gcaptain.com/u/Capt_Phoenix)\ **Post date:** [August 4, 2011, 2:57pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/39 "2011-08-04T14:57:32Z")
> [@"anchorman"](#): > > Try page 81, as far as Officer Endorsements over 3,000 tons…that is the biggest change I have seen. Wow. A 1600 ton master can upgrade to unlimited master with 6 months of sea service as master? Nice… ---
**Author:** ![anchorman](https://avatars.discourse-cdn.com/v4/letter/a/bbce88/32.png) [@anchorman](https://forum.gcaptain.com/u/anchorman)\ **Post date:** [August 4, 2011, 3:05pm UTC](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972/40 "2011-08-04T15:05:39Z")
[QUOTE=Capt. Schmitt;53634]Wow. A 1600 ton master can upgrade to unlimited master with 6 months of sea service as master? Nice…[/QUOTE] That only has to do with the STCW from what I can tell. [Previous page](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972.md?page=1) [Next page](https://forum.gcaptain.com/t/uscg-proposed-rule-stcw-2010/5972.md?page=3)