Can someone help me with this? I thought it was addressed before, but I can’t find what I need. According to NMC:
The Coast Guard is aware that as a result of the limited number of approved QAs, there may be a hardship on mariners trying to complete STCW assessments after December 31, 2017. In consideration of this, the Coast Guard will continue to allow STCW assessments to be signed by an assessor who meets the requirements specified in NVIC 02-14 until December 31, 2019. These assessments must be submitted to the Coast Guard as part of a complete application no later than June 30, 2020.
But NVIC 02-14 just says “the Coast Guard will accept STCW assessments that have been performed and signed by an assessor who has not been Coast Guard approved provided that the assessor meets the professional requirements in 46 CFR 10.405(a)(3) to assess competence for the specific endorsement: assessors must be in possession of the level of endorsement, or other professional credential, which provides proof that he or she has attained a level of experience and qualification equal or superior to the relevant level of knowledge, skills, and abilities to be assessed.”
Would having a national endorsement make one eligible to sign for assessments or would Coast Guard also expect the assessor to have an STCW endorsement?
The person signing off needs to have the equivalency of what you’re getting a signed off for, so yes, they would need all the proper STCW endorsements to sign off OICNW.
It’s explained on page 1 of Enclosure 2 of every NVIC that has assessments. For the immediate future, assessments do NOT have to be signed by an approved “Qualified Assessor.”
Do you think they’re going to start enforcing the QA requirement at the end of this year? (I’m not asking for an official binding statement, just an educated guess.)
Thank you. That was more of the answer I recalled. I just didn’t remember where it was written. From NVIC:
“In the interim, the Coast Guard will accept assessments signed by mariners who hold an appropriate national endorsement and have at least 1 year of experience as Master on vessels at least 200 GRT or 500 GT.”
(3) Possession of the level of endorsement, or other professional credential, which provides proof that he or she has attained a level of experience and qualification equal or superior to the relevant level of knowledge, skills, and abilities to be assessed.
You don’t have to convince USCG of anything. They wrote their own interpretation into every STCW NVIC. At least it is clear and in black and white (once you know where to look). Even NMC can’t argue a point that is spelled out in a NVIC.
I’ve heard of 3rds with OICNW/OICEW that took the QA Class and sent in their info and got denied QA. So, I imagine there are fewer QA’s than expected if the USCG is denying people the QA cert.
I also read in the regulations or NVIC or somewhere that the QA application “should” have xxxxxxx. Nothing said shall. As normal, the implementation has been far from seamless.
As noted in NVICs 12-14, 17-14, and 19-14, OICNW and OICEW require one year of experience as an officer in charge, that’s also what’s required to upgrade to 2nd. So it’s likely those denied don’t have sufficient experience.
The availability of QAs and denying those who don’t meet the qualification standards are not related. The approval standard is not enforced or waived based on how may QAs there are. If there is a chnage in the stabndard, the various applicable NVICs will be changed.
You are correct that the standard in the NVICs is not mandatory (the term :“shall” is never used, a mandatory requirem,ent uses "must’). However, the burden will be on the applicant to provide compelling information that they have superior experience. In my experience, it is a very rare case when someone prevails on this. If an applicant has nothing more than a 3rd license and less than one year experience, they aren’t likely to prevail. Many (most?) Captains are not comfortable letting a new 3rd stand watch without some monitoring - if you aren’t comfortable leaving them alone in critical situations, would you be comfortable with them decidfing who is competent to do the same thing you won’t let them do?
You’re only looking at, or remembering, part of the regulation. In its entirety, it is: Possession of the level of endorsement on towing vessels, or other professional credential, which provides proof that he or she has attained a level of qualification equal or superior to the relevant level of knowledge, skills, and abilities described in the training objectives.
The relevant requirement is actually the experience and skills. Holding a current endorsement is only evidence of having that.
Generally, it’s the experience. In the case of engineers, it’s also to recognize that an engineer on the Great Lakes may have the experience and be qualified, yet not hold the STCW endorsement.
Another reason generally to not require holding is that there may be very qualified assessors who have tons of experience, but are unable to hold a current STCW endorsement. For example, a recently retired Master who has developed a disqualifying medical condition, but is able to work be a QA as a contractor-consultant. The “other credential” in the applicable regulation would be their now expired license (it’s expired, but they still hold it and it does evidence their experience) Holding a current endorsement also presents issues with military assessors (on those things they have comparable and equivalent experience with).
The NVICs are pretty specific, I think as specific as is possible, Considering the other factors I mentioned. The regulation has to be vague. We can’t write a regulation that would cover every STCW endorsement (we can write it, but it will never get past the external (to the CG) government offices that have to be approve it. They would look at a single 230 page regulation and choke, sputtering things like “too burdensome…”
I have no idea. It’s perceived as being outdated and went into disfavor in the 80s/90s when there was a big push for plain language (some of our most vague regulations are from this era). It seems that they are interchangeable synonyms, but gov’t regulation lawyers are quite obsessed and zealous with not using shall.