USCG Licensing Changes Update: Is there time to breathe??

I just returned from the MERPAC (Merchant Personnel Advisory Committee) Meeting held in New Orleans in March.

I know that all of you have been waiting on baited breath for some feedback about the meeting and discussions about the Notice of Proposed Rule Making we have been talking about since November.

Interestingly, the NPRM was not the big topic of the agenda that I thought it would be. That is because the comment period had ended and therefore our feedback was already provided in the form of written comments to be reviewed by the USCG at a later date. We will revisit this later in this email.

Our primary focus at this meeting was to discuss the upcoming changes in the form of STCW 2010 (yes, a new STCW on top of everything else!) and also the possible ratification by the United States of yet another international convention, the Maritime Labour Convention (MLC 2006) and its possible effects on the industry.

The STCW 2010 amendments will begin implementation in January 2012. We thought it was kind of crazy to have major changes to the licensing and certification system now and then more changes in a year. It is my hope that the majority of the changes will all start together next year. The USCG did not and will not commit to this or any other time frame yet, but I am really optimistic.

For one thing, they received literally thousands of written comments to the docket regarding the NPRM. This will in itself take some time to sort through and consider.

Please note that this is only my gut feel, the final ruling will determine the date of implementation which is at the USCG’s discretion and may still be an issue before the end of this year. I will know more at the next meeting in July 2010 and I will write back to you all in the August and September issues. If you have the time to renew, upgrade, etc. now, do not procrastinate, the possible repercussions are too great to postpone what you already qualify for. However, if you are trying to get that last little bit of sea time or training in before the changes, or you just cannot get the time off of your job at the moment, I think, I hope there is a little “time to breathe”.

It is my belief that most of the NPRM will rear its ugly head fairly close if not exactly the same as originally presented in the Federal Register, however we have been assured that the USCG will take the implementation of each item and its affect on the mariner and maritime companies into consideration. “It is all in the implementation” the USCG said numerous times.

So, let’s take a look at what we should expect from each of the conventions and their amendments:

Security Training:

The amendments will include three levels of security training

Anti Piracy training will be added to each level as well.

Marine Environmental Issues:

The amendments will include the addition of marine environmental awareness issues in the Personal Safety & Social Responsibilities Course as well as an operational level of marine environmental concerns at the

A-II/1 and A-III/1 levels of Certification.

Also being added to the Personal Safety & Social Responsibilities are enhanced coverage of:

These additions will make the PSSR module slightly longer but it should remain less than a day.

Safety Training Refreshers:

One of the key elements of the 2010 amendments seems to be the removal of loopholes with respect to refresher training. The ’95 code was vague in this area and many countries opted to interpret the “within 5 years” requirement loosely. It has been decided that certain courses that may affect the safety and survival of the crew and passengers in an emergency warrant refresher training periodically. A review is currently being conducted to determine which components can be done by e-learning or shipboard drills and which will require shore based or practical training.

The safety courses will require refresher every 5 years and the courses may be abbreviated slightly.

The courses that will need to be refreshed by an approved method (in class or shipboard – yet to be determined) are:

There will now be three categories of Tankerman on tank ships.

In addition, each category will have two levels

The biggest change will be the division of the chemical from the oil and each requiring its own sea service prerequisites on each type of vessel and training specific to each.

Also, there will be a specially designated Tanker Fire fighting Course, although the USCG believes that most schools Basic Fire will cover this requirement.

Passenger Vessels

There will be a consolidation of rules for passenger vessels.

OSV, DP and Ice Covered Waters:

There will be a new section with guidance on special licensing or training requirements for OSV’s, Dynamic Positioning Vessels and vessels operating in water that are covered in Ice.

STCW Chapter III:

As many of you know, Chapter Three of STCW refers to Engineering. The main thing that is changing in STCW 2010 in Chapter III is the addition of a Able Seafarer – Engine Rating. This is separate from the Rating Forming Part of an Engineering Watch. In the US System, we have always called this a QMED (Qualified Member of the Engineering Department). Many countries have only had the RFPEW level and this new AB Engine will require the RFPEW to be STCW Compliant. This will require training and testing. This will be a new section called A-III/5.

Section A-III/1 will be reformatted and reorganized. You will no longer need to have the 30 months of approved training in the engine room. The wording will now be more in sync with the deck department and will read three years of sea service with one year of combined work shop skills and 6months of engine room Watchstanding.

The STCW 2010 is adding a new Electro Technical Officer (ETO) and an Electro Technical Rating (ETR). The united states will not be making this a priority.

Engine Room Resource Management, teamwork and Leadership training will be mandatory at both the operational and management levels.

STCW Chapter II: Support Level

If Chapter Three is Engineering, then Chapter Two must be the deck department. The changes in Chapter II are the addition of a Able Seafarer – Deck Rating. This is separate from the Rating Forming Part of an Navigation Watch. In the US System, we have always had an Able Seaman Endorsement available for domestic certification and now it will be the upgrade from the RFPNW level which will be the required prerequisite to an STCW Compliant Rating. Based on sea time requirements, it will be critical to get your RFPNW as early in your career as possible as the sea time clock for AB will not start until you have RFPNW and your clock towards subsequent licenses will require AB. This will require training and testing. This will be a new section called A-II/5.

STCW Chapter II: Operational and Management Level

ECDIS will now be required training for all deck officers on all vessels that are equipped with ECDIS. This will be just like ARPA or GMDSS where it is a restriction if you don’t have it.

Keep in mind that as of 2012 nearly all vessels over 200 tons will be required under separate law to have ECDIS equipment, therefore by default, any deck officer over 200 tons will need this.

There will be two levels of ECDIS, operational and management dealing with the different responsibilities of each.

Some good news is that there will be a reduction of requirements for two areas that people usually hate:

Bridge Resource Management, teamwork and Leadership training will be mandatory at both the operational and management levels. Thank fully, in the United States, we have required this since 2002.

This section of the code will be harmonized with the Labor convention.

MLC 2006: parts excerpted from the ILO website

The Maritime Labour Convention was signed in 2006 and was created to create regulations for seafarers right’s so that there would be a global minimum standard for how mariners are treated.

Where the IMO (International Maritime Organization) oversees the STCW Certification Convention, the ILO (International Labour Organization) oversees the MLC Convention.

When the International Labour Organization adopted a “bill of rights” for the world’s maritime workers, all concerned – governments, seafarers and shipowners – hailed this new labour standard as a landmark development for the world’s most globalized sector.

The maritime industry is a highly specific, emblematic element of the global economy. Until recently, the labour standards that affected this sector had been fragmented, both in content and application. The International Maritime Organization (IMO) had taken important steps to build protections in the areas of safety, certification and pollution, but the sector was awash in a wide range of international labour standards going back over eight decades.

The new ILO Convention modernizes these standards to:

All this is new. What is more, this standard also recognizes that in today’s maritime sector, quality work and quality shipping go hand in hand. This exceptional vision and capacity for social dialogue among seafarer and shipowner organizations has thus helped build the foundation for an innovative approach to social policy that represents a pioneering contribution to making globalization fair.

How does it achieve this? First, by providing a necessary balance between labour standards and regulations needed in the sector with the promotion of productivity and competitiveness. Such balance is essential today across the globalized world. It is not an “either/or” proposition, but one that provides both fairness and efficiency in a diverse and changing sector. Second, it is the first major comprehensive set of global labour standards to be adopted without the opposition of any of its tripartite stakeholders – in this case, representatives of seafarers, shipowners and governments. Of the more than 300 delegates attending the recent ILO Maritime Conference, not one voted against the Convention.

Third, the Convention contains common sense and viable provisions for its own enforcement. No longer will seafarers or shipowners face a bewildering array of national laws subject to differing international labour standards. Under its provisions, for the first time in history, there will be a truly global foundation available for the various national laws in the maritime labour sector.

Fourth and finally, this Convention shows that the human capacity, intelligence and political will, exists to find balanced solutions to help make globalization fair. Other globalized sectors face similar challenges. Governments are trying to manage and develop national economies and specific sectors while dealing with the demands of adjustments to financial and trade liberalization. Businesses are struggling to succeed, grow and survive in the face of intensifying competition in domestic, regional and global markets. And workers often feel they are at the receiving end of these tensions. In the search for a way forward it has become more and more evident that there can be no lasting success with purely national solutions to global problems. Nor will we find the right solutions without dialogue among the key parties. It is incumbent upon policymakers to rapidly move forward with the ratification of this new standard. I wish to make a call to all Heads of State and Government and to Speakers of national parliaments to place the ratification of the Maritime Labour Convention on their priority list. Together they can make it happen quickly.

The sooner we have the necessary ratifications (30 countries representing 33 per cent of world tonnage), the sooner it will come into force and the sooner we can confirm the Maritime Labour Convention’s role as a harbinger of a new era in our globalized world – one in which workers, employers and government came together to produce an international instrument that benefits us all. This is just the beginning. History will one day record that dialogue could address not only the challenges of living, working and conducting business at sea – but provide a new paradigm for dealing with the challenges of a fair globalization as well.

A review of previously released MPT material

USCG Announces Notice of Proposed Rule Making –
Major Impact on Licensing and Certification

The United States Coast Guard is requesting comments on the proposed final implementation of STCW for US mariners. The goal is to have the final implementation in place in the near future thus ending the Interim Regulations.

The proposed implementation includes changes in required sea time to achieve various licenses, clarification of definitions that have been ill-defined or gray for many years, and also specifies training requirements that are expensive, and in some cases irrelevant, to our industry.

NOTABLE POINTS FROM THE USCG PROPOSAL:

We do have more time to breathe than we had worried about earlier this year. Originally, the USCG had planned to start implementing these new rules as early as July 2010. It does not look like this will happen that soon. I think we have the better part of a year to all collectively get the best credential we can before the changes are carved in stone. Unfortunately, this is only a crystal ball prediction, we do not have an exact implementation date yet.

Long story short, however, with all of these changes, licensing is only getting more difficult and time consuming as well as costly.

Now is the time to get your license or upgrade your qualifications. MPT is here to help you every step of the way.

Call today to set up a complimentary career counseling session. We know that in a difficult economy it is hard to spend time and money on training, however this may be the best way to get the advantage in the job market, not to mention meeting the licensing requirements currently in effect rather than adding the burden of all of these new requirements into the schedule.


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USCG Announces Notice of Proposed Rule Making – Major Impact on Licensing and Certification

USCG Announces Notice of Proposed Rule Making –
Major Impact on Licensing and Certification