Q. Can you please explain the difference between the upcoming changes that are called NPRM and the changes you recently described as STCW 2010? I don’t understand the impact that each will have or the deadline for doing the new training, etc.
A. This is a very timely and excellent question. Sometimes those of us in the training side of the industry get so used to speaking in acronyms that we forget to really explain them in detail.
The NPRM will only affect USCG Merchant Mariner Credentialed crew. NPRM stands for Notice of Proposed Rulemaking. The USCG is required to publish any proposed legislative changes to the public for comment well in advance of those changes being finalized. Then after they receive the comments from the public, they must review them, decide what to do and then publish their final rule making allowing for the public to transition from one system to the other.
When STCW ’95 was implemented in 1997 with a five year deadline, February 1st of 2002 for those of you who remember that crazy timeframe, there were some components of the code that were never fully agreed upon and implemented at that time. These included some of the training requirements for Master 500-1600-3000 ton as well as some of the Engineering training requirements, etc. So long story short 15 years after the code was signed and 8 years after the deadline, here we are ready to finish STCW ’95. Just in time for a new and updated STCW Code to come out. The NPRM is the final USCG implementation of the 1995 amendments. It will not have much of a transition timeframe since it’s requirements have been expected for a very long time. However, some of the aspects of the NPRM have taken us all by surprise, including the USCG’s decision to eliminate the Master and Mate 500 grt licenses in favor of the 200grt/500 ITC and 1600grt/3000 ITC licenses which are not being eliminated. Also, the entire engineering structure as we know it is being scrapped and fully harmonized with the IMO model which is good news for some and crappy news for others. Not to mention the new career ladder which will require master 1600/3000 ton candidates to get their AB then their Mate (OICNW) then their Master with different training and testing at each step. Gone will be the days of going from 100 ton master to 1600 ton master with experience, training and testing. There will no longer be this direct path.
As for a deadline, the most we could get the USCG National Maritime Center to commit to last month was that the Final Rule Making or the Supplemental Proposed New Rulemaking would be out before January 2012. This seems so far away, but really it is within just over a year and could happen anytime before then. So basically, we are looking at within the year to get notice of these massive changes.
You also mentioned STCW 2010, the difference is that these requirements are international as opposed to the NPRM which are USCG regulations based on IMO requirements put in place a while ago.
The STCW 2010 will not have anywhere near the impact that STCW 1995 had. Do not worry. The ’95 Code carried with it major changes and this one is pretty much just an update.
It will outline some new requirements but mostly the need to refresh every five years on most of the safety subjects. Some of which we are pushing for e-learning options for you.
The likelihood is that there will be a phased in deadline for this based on renewal for existing mariners and a 2013 deadline date for new mariners and cadets. I will keep you abreast of all of the changes as we are given more information from the USCG.
In the meantime, anyone in the system can confirm that it is only getting more complicated all of the time. If you can raise your grade, do it now. Good luck and, just a reminder, I will provide you complimentary career counseling, just send me an email at amy@MPTusa.com
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