MERPAC RECOMMENDATIONS Task Statement 75

Transcription

1 MERPAC RECOMMENDATIONS Task Statement 75 MERPAC makes the following recommendations on USCG SNPRM MERPAC commends the USCG for listening to our comments to the NPRM and for releasing this SNPRM. The SNPRM is an improvement to the NPRM text. We thank the Coast Guard personnel for their clarifications and for responding to our comments during the development of these recommendations. Task number 75 part 1 Section Definitions 1. MERPAC believes that any persons serving as an assessor needs to be qualified with training in the skills required to assess competency and approved by the Coast Guard, whether as a Qualified Assessor or as a Designated Examiner. Therefore, a definition of Qualified Assessor should be added as follows Qualified assessor or QA means a person who is qualified to evaluate, for STCW endorsements, whether an applicant has demonstrated the level of competence in the task for which the assessment is being made. This person must be approved by the Coast Guard or by a CG approved or accepted program of training. 2. Coast Guard should work with MERPAC to develop the standards for a QA, including developing an approval process and an auditing and oversight program. A task statement should be developed for MERPAC. 3. MERPAC recommends that a definition for Certificate of Registry needs to be added. 4. MERPAC recommends that the definition of a Domestic officer endorsement is confusing. Strike domestic and replace with National. (Globally) 5. MERPAC recommends a change to the definition of disabled vessel, that the Coast Guard should remove the last sentence of definition, and revert to the original definition. As stated, we believe this definition would mean that any time a vessel maneuvering to and from the dock with an assist tug, or a vessel that takes an assist/escort tug, that that vessel would be deemed to be a disabled vessel. 6. MERPAC notes the absence of a definition for direct supervision and recommends that one is needed.

2 7. MERPAC recommends that the definition of Drug test be amended to broaden the testing procedure. See note below: Title 49: Transportation Subtitle A: Office of the Secretary of Transportation PART 40: PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS Subpart I: Problems in Drug Tests What happens when an individual is unable to provide a sufficient amount of urine for a pre-employment follow-up or return-to-duty test because of a permanent or long-term medical condition (a) This section concerns a situation in which an employee has a medical condition that precludes him or her from providing a sufficient specimen for a pre-employment follow-up or return-to-duty test and the condition involves a permanent or long-term disability. As the MRO in this situation, you must do the following: (1) You must determine if there is clinical evidence that the individual is an illicit drug user. You must make this determination by personally conducting, or causing to be conducted, a medical evaluation and through consultation with the employee's physician and/or the physician who conducted the evaluation under (d). (2) If you do not personally conduct the medical evaluation, you must ensure that one is conducted by a licensed physician acceptable to you. (3) For purposes of this section, the MRO or the physician conducting the evaluation may conduct an alternative test (e.g., blood) as part of the medically appropriate procedures in determining clinical evidence of drug use. 8. Merpac recommends that all manning documents and COIs should separately specify the STCW endorsements from the National endorsements that must be carried onboard for international voyages. 9. MERPAC recommends that the term STCW endorsement include additional language clarifying that the underlying domestic endorsement must be held by the applicant for an STCW cert. 10. MERPAC recommends that a definition for medical certificate be added. Provide discussion of the use of the med certificate in the appropriate section.

3 11. MERPAC recommends that Coastwise voyage definition encompasses voyages to nations in which we have a treaty or other arrangements between nations that allow coastwise transit. 12. MERPAC recommends that the definition Domestic voyage language should delete the phrase that says without entering waters under the jurisdiction of another country. 13. MERPAC recommends adding the definition of ILO. 14. MERPAC recommends that the definition of Limited include horsepower. 15. MERPAC recommends that the Coast Guard review the definitions of a self propelled tank vessel and tankship definitions to ensure inclusion of all vessels. 16. MERPAC recommends correction of the definition Utility towing. We believe at this time that paragraph 2 conflicts with proposed definition for disabled vessel. 17. MERPAC recommends that CG amend the definition of Restricted to read endorsement, for example, specific 18. MERPAC recommends that Safe and suitable person needs to add safety and security of life or property 19. MERPAC recommends that the definition of Support level should coincide with STCW Code (A-I/1) -- management level and operational level, also. 20. MERPAC recommends that the definition Vessel personnel with security duties be revised. Currently, it does not accurately capture security duties and it should be changed to harmonize with text from B-VI/6 in STCW. MERPAC recommends the following revisions to specific section of the SNPRM as follows: Change the second sentence to read Except upon a written request of the applicant, the CG will post date the issuance of the MMC up to 12 months from the date that the CG accepts a complete application as defined in this part. MERPAC recommends that the new credential validity date will coincide with the expiry date of the active credential held by the mariner MERPAC recommends that a copy of a radar course certificate should not have to be certified, as proposed in (d)(4).

4 Coast Guard needs to add if required at the end of (f). All references to TWIC should be modified in this way because a TWIC is no longer required per U.S. statute to accompany all merchant mariner credential. (Global) MERPAC does not support that payment of fees only electronically. Mariners should not be forced to pay via credit card. Not everyone has a credit card. Allow for cash, certified/cashiers check or money order payment Coast Guard needs to add a new paragraph to address means of proving citizenship since a TWIC is no longer required for all MMC s Delete (c)(2), since TWIC isn t required for everyone (a)(2) conflicts with (b) and (i). Modify (a)(2) to say except where provided for in (b) and (i) (d)(6) If there is going to be a national medical certificate, then de-link the medical certificate from the MMC and issue a separate medical certificate. Coast Guard needs to check for consistency with other regulations ( Et al) and if necessary, consider a Legislative Change Proposal if necessary to assure that credentials are issued after evaluating a mariners professional qualifications alone (b) (b) Replace text to ensure evaluators issue a new 5-year credential (as a default) if all required documentation accompanies the application, even if the mariner does not select renew on the application form or the Evaluator should contact the mariner to inquire if they are requesting a raise in grade, which would not reset the expiry date. Replace text as follows: If an applicant for new endorsement or raise in grade meets the renewal requirements under for the endorsements listed on the MMC that applicant will receive a credential valid for 5 years. Where an applicant does not meet the renewal requirements for an endorsement(s) such endorsement(s) may be issued with the expiration date that is the same as the current MMC (a)(5) Delete the word direct in the last line. Replace reference to with and check all references to ensure there are no errors. (Supposed to be referring to only STCW) (b) Insert a new paragraph that would allow the issuance of an STCW restricted certificate based on seagoing service on the waters of British Colombia and the inland passage. (as

5 day for day service on inland waters). To ensure continued service for seafarers working in this area (h) and (i) Change will to may since TWIC is no longer required for all mariners. Should insert text directing mariner to appeal to TSA not USCG Change in the red line of the SNPRM did not appear in the FR SNPRM. Change is not significant MERPAC believes that the NMC process needs to refocus the medical review of mariners so that the process is risk based. Additionally, MERPAC is concerned that the change to the medical review process requiring the implied issuance of a medical certificate will exceed the capabilities of the NMC because of the increase in the number of reviews necessitated by the proposed 1 and 2-year cycle of certificates, and an unacceptable backlog will be created. Therefore, mariner s jobs would be jeopardized. Therefore; (a) Replace operational limitations with limitations and/or other conditions. (to assure consistency with NVIC) (b) MERPAC believes that the NMC cannot adequately conduct or issue the certificates in a timely manner as laid out in this section. We believe that the only long term solution is development of a designated medical practitioner issued certificate as an option for the mariner. The designated medical practitioner should only be an option since there may not enough mariners in an area to support this system. See comments in 15. In addition to necessary amendments to 46 CFR , in order to put into effect MERPAC s recommendation that first class pilots and mariners merely serving as a pilot be required to have 5 year medical certificates (instead of 1 year medical certificates), 46 CFR (b) and (d) should be amended as follows: (b) Every person holding a license or MMC endorsement as first-class pilot must have a thorough physical examination each year, to be completed by the first day of the month following the anniversary of the individual s most recently completed Coast Guard required physical examination. Every fifth year, as per the medical certificate/endorsement requirements in 46 CFR (b), the results of the physical examination must be recorded on a CG-719K form and submitted to the Coast Guard no later than thirty (30) calendar days after completion of the physical examination.

6 PLAN B : MERPAC feels strongly about the above recommendation. However, as a Plan B in the event the Coast Guard does not accept MERPAC s recommendations that first class pilots and mariners merely serving as a pilot be required to have 5 year medical certificates, MERPAC recommends that first class pilots and serving as pilots be required to have 2 year medical certificates. Under Plan B, 46 CFR (b) and (d) should be amended as shown below: (b) Every person holding a license or MMC endorsement as first-class pilot must have a thorough physical examination each year, to be completed by the first day of the month following the anniversary of the individual s most recently completed Coast Guard required physical examination. Every other year, as per the medical certificate/endorsement requirements in 46 CFR (b), the results of the physical examination must be recorded on a CG-719K form and submitted to the Coast Guard no later than thirty (30) calendar days after completion of the physical examination. (d) If a person holding a first class pilot license or endorsement does not submit his or her CG-719K form in accordance with 46 CFR (b), the individual may not operate under the authority of that license or endorsement until the CG-719K form has been properly submitted to the Coast Guard. (b)(3) If Coast Guard moves forward with a certificate for National mariners, pilots should be included in this group if applicable (b) What is a communicable disease? CG needs to define exactly what the concerns are. Mariners that ONLY have a FH credential are receiving extensive, potentially unnecessary medical testing. Clarification needs to be provided in guidance as there currently is no standard communicable. Recommend to drop (d)(2) which has been imported from NVIC and STCW. Recommend leave it in guidance (b) Amend redline to conform with SNPRM Change course approval to mirror the IMO format to avoid confusion in the implementation. (e) Add significant before the word change in course approval (a)(6)(i) Replace answers with scores

7 (a)(6)(iii) Change to read Compliance with attendance policy. (a)(7) Add significant before change (a)(3) After allowed, add substitution of required service as a result of (to avoid individuals from having to take the same class twice to maintain an endorsement when upgrading) Include a five-year renewal requirement for QA and DE. Consistent with the five-year requirement for instructors. (a) (3) After a level of qualification, insert being sought. And change training objectives to tables of competence. Change paragraph (c) into new paragraph (b)(4). In new (b)(4), change and/or to or ; and delete the final sentence. The sentence is an IMO reference that is inappropriate for domestic credential. These two changes are current practice for DEs (h)(2)(i) MERPAC believes this language is unclear. Change the word client to insure that it reflects the intent that a QSS can not approve courses for a subsidiary of its own organization Include a requirement that if company training is included under the ISM, Coast guard should accept ISM to the extent that it meets the QSS requirements. (d) change national to nationally recognized. (c)(2)(v) delete training (c)(3) delete proposed language and insert Organizations are subject to audits at least twice in a five-year period. Organizations should cooperate with Coast Guard scheduled audits Replace A-1/6 with B-1/6

8 46 CFR 11 General Comment Mariners should not be able to obtain an STCW endorsement without meeting the service requirements for the associated national endorsement.. this is not about qualification requirements, it IS about progression requirements (a) link is not helpful Somehow, make STCW available to the general public. It is not sufficient to incorporate by reference, since the document is only available by purchase (a) change passage of a professional examination to demonstration of competence (more encompassing of different methods). (e)(2) no STCW endorsements listed considering the title and the application of the entire section. (f) amend to be consistent with (a). (h)(1) recommend change within the previous to read more than. Coast Guard needs to define evidence as detailed in the proposed language. (global) (j)(1)(iii) recommend extend time from 3 months to 6 months (i) should extend grandfathering provisions. (persons with an operational level endorsement upgrading to management level should not be required to do the assessments for operational level, since they were already completed) (a)(3)(ii) Change language if required to read if serving on a vessel consistant with STCW (b)(1) but also global Leadership competency how is it achieved? Specify in regs or policy what kind of evidence will be used (b)(2) Change by completing Coast Guard approved or accepted training to demonstrating competence

9 11.323(e) Delete - this is inconsistent with (a)(3) and other similar paragraphs are unnecessary. (This applies to all sections with the same language) and should deleted as it not reflecting the required competencies (b)(2) Why has this specifically been mentioned, when the STCW table mentions managing other items? (this function is not new to STCW). (This applies to all sections with the same language) (c) Recommend that a working group be formed with Coast Guard HQ and NMC and Industry to clarify and define the certification process for single or limited size engine staff. In addition, this working group should also develop the same for vessels of limited size deck staffing. Change the wording in the last sentence as follows: Under these circumstances, the certificate may will include a corresponding limitation (This applies to all sections with the same language) (c) Delete current text and Replace with An applicant who holds an STCW endorsement as OICEW, second engineer officer, or chief engineer officer will be allowed to receive the ETO endorsements upon completion of the requirements in Section A III/6 of the STCW Code (d) Delete due to above recommendation (e) will now be (d) Table (a) Use attached table as needed (as modified in 4 year row between 2 A/E Unlimited and Chief Engineer Limited) and notes (Need to add appropriate Limited Chief Engineer, MODU and OSV Engineer Endorsements). Effect is to eliminate engineer near coastal endorsement. If working outside of boundary line, STCW applies. If not, US endorsement applies. (new crossovers) Need better explanation of crossover from Unlimited DDE to OICEW within regulations (DDE to have x years as DDE = OICEW (after completing assessments). Need to develop assessments for Limited Chief Engineer at STW (a)(3)

10 Replace graduation from with completion of an Engineering Officer Qualification Course. An EOOW letter from the Army, Coast Guard or Navy should be prima facie evidence of competence Table Insert exam between 2 nd mate and C/M on far-left progression. Also in Table, In far right progression, don t have to go through BCO/BS to get to OIM. It is only one path. Re-assess entire chart for accuracy..including the two above (c) (et seq). Great Lakes time is linked with inland time need to break out, 12 months for GL and 24 months for inland. All the way through, even in uifvs and t/v. New policy recognizing GL time as equivalent to ocean not carried through Section Harbor assist license creation of a new license would unnecessarily complicate the licensing scheme and potentially stovepipe mariners. The current TOAR system allows mariners to complete applicable assessments and receive a restricted towing license (b)(2)(iii) check name (check to see if BOEMRE/MMS still exists) recommend that correct name is obtained immediately before publication (d) confusing when renewing radar endorsement or credential endorsement? Re-draft to ensure current practice of not putting radar endorsement on MMC is stated (d) and 713(a) come up with a different term than invalid Adding this standard extracted from a different (HSC) code is confusing and inappropriate. At a minimum add clarification about high speed craft code ( reference the code) and to what vessels it applies to tables are pre-stcw-95. MERPAC recommends that the tables be separated by operational and management levels. Small group to discuss and to locate any Δ between national and STCW endorsements that occur in this table. 1). Completely remove the table & from the SNPRM. 2). In lieu of the table, the USCG should issue documentation with considerable detail as to what is contained in each exam for each license level.

11 3). MERPAC should assist in the development of this documentation, which might take the form of a module description as has been used in the past. 4). MERPAC Task 71 regarding license exam questions cannot logically proceed until the recommendations 1-3 are well underway Part 12 Global make endorsements comply with the titles in the law (a) change after every person to read every person serving under the authority of a rating endorsement as lifeboatman-limited on any United States vessel fitted with liferafts but not fitted with lifeboats must hold an endorsement as lifeboatman or as lifeboatmanlimited. (bad language in both and ) (c) make identical to (b)(3) (b)(1) add text to require a QA. Table (e) Able Seafarer Special. Include a new footnote to allow for the reduction of sea service (6 months) by taking an approved course (b) first line change may to shall Table (c) Ordinary seamen. Include a new footnote to allow for the reduction of sea service (6 months) by taking an approved course (b) first line change may to shall (b) Delete current text and Replace with An applicant who holds an STCW endorsement as able seafarer-engine and domestic rating endorsements as electrician, electrician/refrigerating engineer, or junior engineer will be allowed to receive the ETR endorsements upon completion of the requirements in Section A III/7 of the STCW Code (c) Delete due to above recommendation (d) will now be (c)

12 and 627 re-draft to ensure that it provides all transitional provisions from STCW. (check implementation date and make sure they re the same). TANKERMAN PART (d) revise text remove and for maintaining and operating the bunker systems including the fuel oil (tankerman engineer is specifically for cargo operations. Delete everything after the semicolon.) and add liquid cargo in bulk. Ensure that text does not apply to the transfer of other than bulk liquid cargoes and a tankerman endorsement is not needed revise to allow applicant to complete an approved course for renewal when expired by more than 12 months see (a)(3). Many mariners are not aware that taking a course counts towards renewal of tankerman endorsements. This would allow the mariner the ability to maintain their tankerman endorsement following expiration of greater than 12 months. Change reference from rating to endorsement (a)(1) after tank vessel, insert including service aboard a barge, as appropriate. This is to enable mariners serving on towing vessels, with tankerman credentials, the ability to renew those credentials add text to give ATBs full credit for sea time and experience (loads/discharges) towards full tankerman-pic endorsement. Many new ATBs have identical cargohandling equipment as tankships. In (C) need to include a crossover program from different types of tankers. Seafarers would already have tanker experience. A shorter course consistent with the STCW could be appropriate Split oil and chemical tanker requirements into separate sections can combine courses, but split sea time requirements. Incorporate STCW code properly.. include fast track in regulation V/I-1. Seafarers serving on board tankers certified to carry both oil and chemical should receive sea credit for both oil and chemical allow T/E to obtain this endorsement so C/E and 1 st don t have to get tankerman-pic endorsement Under this text engineers C/E and 1 st will be unable to do the loading and discharges. Include language to allow mariners with STCW management level engine endorsements and tankerman-engineer national endorsement to receive an STCW Advanced tanker cargo operations endorsement if they have completed the STCW assessments. Changes may be accomplished by amending the domestic (13.201) requirements and the STCW requirements

13 Create a new STCW section for Tankerman (Barge) to build on for the service requirements but not the training requirements. The training requirements would be the same as Include grandfathering provisions Apply comments from , as appropriate. 46 CFR 14 No comments 46 CFR 15 General comments - Add section about Manning documents and COIs should also separately specify the STCW endorsements that must be carried onboard for international voyages. Pilots The statutory requirement does not require submission of the medical exam nor does it imply issuance of a new certificate. Considering the high volume of medical certificates that will need to be processed to move to a 2 year medical certificate, the Coast Guard should continue a five-year certificate applicable to first class pilots and those serving as first class pilots. Amend (c)(3) to include first class pilots and delete (c)(2) where the pilot would be subject to an annual medical exam and should make it available upon request. Change and accordingly The Coast Guard should issue a notice to all shipowners explaining the implementation of the US medical certificate to facilitate port state control inspections. Add New (g)(3) Add: Pilot vessels are not considered seagoing ships because they operate within, or closely adjacent to, sheltered waters or areas where port regulations apply (c) medical certificate, there is no effective date. Add an additional sentence: Until such date as a separate certificate is issued, a valid MMC serves as the medical certificate (c) Amend to ensure that is not meant to include uncredentialed mariners. Amend A person may not employ or engage an individual who is employed in a position required to hold an MMC (a) requirement to have a TWIC with a MMC is in conflict with the current statutes. Amend by adding if applicable (b) Same as (a)

14 General comment Text should honor original agreement with DOT that the STCW application in domestic trade would start at 500 grt. Amend text in Part 15 to apply this agreement. Global change in Part 15 - add or 500 grt on a domestic voyage wherever 200/500 tonnages are used. This is per DOT agreement to use 500 grt and on the application of the STCW. Global change in Part 15 add after seagoing vessel wherever horsepower is mentioned, tonnage should be also mentioned 200grt/500gt. Example seagoing vessel of 200 GRT/500 GT or more driven by main propulsion machinery of 1000HP/750 kw propulsion power or more (D)(3) Recommend Delete, after much discussion Current language indicates that all ratings, including wipers, must possess endorsement as Able Seafarer Engine instead of QMEDs. MERPAC needs to categorize what QMED categories should be RFPEW (watchstanding) (FWT, Oiler) and which QMED categories should be Able Seafarer Engine (non-watchstanding) (all others) to reflect the rating who stands a watch and who does not. Requirements should reflect that those all watchstander ABs and QMEDS are required to hold a RFPNW or RFPEW. QMEDs serving on vessels in a non-watchstanding position, excluding wipers, oilers and FWT, must hold able seafarer-engine Too broad, goes too far beyond what should be required. Replace on which he or she is engaged with appropriate to their duties and responsibilities. Second sentence - After the word these insert may (b) overly restrictive and impossible during normal vessel operations. Delete made fast to shore change competence to documentary evidence meeting the regulations as per 46 CFR 11.23xx There are no guidelines for GMDSS maintainer courses in the U.S. These need to be developed and provided to industry (i) to (j) Amend paragraph (i) in accordance with the recommendation under part 13 to include a new STCW endorsement for barge Table 1 Place double or triple asterisk and associated note that an engineer that holds a tankerman PIC (XX) can be substituted for a tankerman-engineer conflict between redline and SNPRM. Redline is correct version

15 15.901(c)- amend to be consistent with definition of self propelled vessels conflict between redline and SNPRM. Redline is correct version (a)- Return the conditions under which a DE can sail to the current regs, Need to retain the 500 grt limit See recommendation regarding exemption of pilot vessels to STCW. In of this subchapter, change comma to period and delete the remainder of the sentence. This is done to increase the clarity of paragraphs 1 and (a) add at the end of the paragraph and other relevant national license requirements (b) and (c) change the tonnage to 500 grt and add tonnage to all HP references (f) (1) change to serving on seagoing vessels, except those vessels listed in of this part. Add also to implementation of medical certificate in earlier recommendations about implementation date Subparagraphs written too broadly. Add insertion referencing exempted vessels from paragraph (a) into paragraphs (b) and (c) ( c )(1) change from BST or safety familiarization to BST and safety familiarization specific to that vessel add serving on seagoing vessels, except those vessels listed in of this part (i) in SNPRM, but not in redline, match up redline to match SNPRM (j) delete from SNPRM (not in redline) add definition of work which includes drills not being counted as such. Use an existing definition that is consistent with other regulations dealing with work and rest. Concern expressed about meeting and logging OPA 90 work rules vs STCW rest rules. Outside of this rulemaking, congress should revisit OPA 90 work rules and revise to be consistent with STCW (c) Amend text to address the following issues: Ensure (a), (b) and (c) apply only to vessels over 500 GT. Include all transitional provisions from STCW Account for existing mariner compliance by 2012

16 Account for new mariners compliance by 2014 Contractors and other personnel should not be required to obtain an endorsement. (Additional burden) Individuals who have completed a USCG accepted VSO course or have been designated as VSO are considered as having met the requirements of training for personnel with or without security duties Ensure that requirements take into account STCW.Circ 7(16) providing a compliance waiver until MERPAC recommends that the text should be amended as follows: Security personnel. (a) Onboard a seagoing vessel of 200 GRT/500 GT or more, all persons performing duties as Vessel Security Officer (VSO) must hold a valid endorsement as VSO. (b) Persons who hold an endorsement as VSO will be deemed to satisfy the requirements for vessel personnel with security duties in paragraph (c) of this section. (c) After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all personnel with security duties must hold a valid endorsement as vessel personnel with designated security duties, or a certificate of course completion from an appropriate Coast Guard-accepted course meeting the requirements of 33 CFR (d) Persons who hold an endorsement as vessel personnel with security duties, or a certificate of course completion from an appropriate Coast Guard-accepted course will be deemed to satisfy the requirements for all other vessel personnel in paragraph (e) of this section. (e) After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all other vessel personnel must hold a valid endorsement in security awareness, or a certificate of course completion from an appropriate Coast Guard-accepted course meeting the requirements of 33 CFR (f) After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all contractors, whether part-time, full-time, temporary, or permanent, must have knowledge of, through training or equivalent job experience in accordance with the requirements of 33 CFR Vessel owners and operators must maintain records documenting this requirement and produce those records to the Coast Guard upon request Requirements to qualify for an STCW endorsement as vessel personnel with security duties. (a) The applicant for an endorsement as vessel personnel with security duties must present satisfactory documentary evidence of meeting the requirements in 33 CFR (b) All applicants for an endorsement must meet the physical examination requirements in 46 CFR, part 10 subpart C. (c) All applicants for an endorsement must meet the safety and suitability requirements and the National Driver Registry review requirements in (e) of this subchapter, unless they have met these requirements within the previous 5 years in connection with another endorsement. (d) Until 1 January 2014, seafarers who commenced an approved seagoing service prior to 1 January 2012 shall be able to apply for an endorsement as vessel personnel with designated security duties by: (1) approved seagoing service as shipboard personnel with designated security duties, for a period of at least six months in total during the preceding three years; or (2) having performed security functions considered to be equivalent to the seagoing service required in sub-paragraph paragraph (d)(1) of this section; or (3) passing an approved test; or (4) successfully completing approved training Requirements to qualify for an STCW endorsement in security awareness. (a) The applicant for an endorsement security awareness must present satisfactory documentary evidence of meeting the requirements in 33 CFR (b) All applicants for an endorsement must meet the physical examination requirements in 46 CFR, part 10 subpart C.

17 (c) All applicants for an endorsement must meet the safety and suitability requirements and the National Driver Registry review requirements in (e) of this subchapter, unless they have met these requirements within the previous 5 years in connection with another endorsement. (d) Until 1 January 2014, seafarers who commenced an approved seagoing service prior to 1 January 2012 shall be able to apply for an endorsement in security awareness by: (1) approved seagoing service as shipboard personnel, for a period of at least six months in total during the preceding three years; or (2) having performed security functions considered to be equivalent to the seagoing service required in sub-paragraph of this section; or (3) passing an approved test; or (4) successfully completing approved training. Task number 75 part 2 List of training elements for 46 CFR Part 11 STCW Engineering competencies with formal training requirements Table A-III_1 - OICEW Application of Leadership & teamworking skills ERM - No subject matter experts on board, no time, & more effective Maintenance and repair of electrical and electronic equipment Safety Concerns Table A-III_2 Management Level CE/2E Use leadership and managerial skills - No subject matter experts on board, no time, & more effective Maintain safety and security of the vessel, crew and passengers and the operational condition of life-saving, fire-fighting and other safety systems Required by STCW Table A-III_4 Table A-III_5 -

18 Table A-III_6 The USCG needs to ensure that assessments (i.e. exams) are truly testing knowledge, not just the ability to memorize answers to questions. This may include removing access to exam questions for studying or moving away from the multiple choice exams. STCW Deck competencies with formal training requirements General Comments: 1. Generally, the officers do not have the time to perform training and assessment onboard due to minimal manning, higher workload and operational constraints. 2. Under STCW mandatory rest period rules, the time available for training is limited. 3. The officers may not have the requisite knowledge to effectively teach and assess the needed subjects. 4. Training not part of a ship s officers job description. 5. Most officers have not been exposed to train the trainer techniques. 6. Most officers are reluctant to assume the legal liability of training. 7. Some subjects can be better conducted ashore due to safety and economic reasons. 8. If a company wants to address the above issues, then the company must provide the resources to conduct approved onboard training. Code reference: Table A-II/1-Specification of minimum standard of competence for officers in charge of a navigational watch on ships of 500 gross tonnage or more The following competencies and KUP would better serve the intents of STCW if they were presented in a structured program: Coastal Navigation theory (including magnetic and gyro compasses and passage planning) Basic Stability and trim Watchkeeping (BRM, application of COLREGs) simulation based ) Celestial Navigation (for oceans endorsement) Meteorology Basic Shiphandling Basic Cargo Handling The length of the training can vary depending on the delivery medium (classroom, online, shipboard, blended, etc.). It should be the responsibility of the training provider to

19 justify, to the National Maritime Center, how they can accomplish the goals in less time than outlined by the model courses. (Start with the model course as the benchmark and adjust as necessary.) The content of the training should be appropriate to the tonnage, route and/or type of vessel. For example, basic shiphandling can be performed aboard an OSVs, tugs and ferries, rather than in a full mission simulator. Code reference: Table A-II/2-Specification of minimum standard of competence for management level on ships of 3,000 gross tonnage or more The following competencies and KUP would better serve the intents of STCW if they were presented in a structured program: Advanced Watchkeeping (simulation based focused voyage planning, communication and leading the bridge team) Advanced and Emergency Shiphandling (maneuvering a large vessel in restricted waterways) Advanced Cargo, Stability and Trim including damage stability Weather routing Monitor, Control and Compliance with laws and regulations IBS/INS Marine Propulsion Systems Code reference: Table A-II/2-Specification of minimum standard of competence for management level on ships of greater than or equal to 500 GT, but less than 3,000 GT. The following competencies and KUP would better serve the intents of STCW if they were presented in a structured program: Advanced Watchkeeping (voyage planning, communication and leading the bridge team) Advanced and Emergency Shiphandling * (maneuvering a large vessel in restricted waterways) Advanced Cargo, Stability and Trim including damage stability Weather routing * Monitor, Control and Compliance with laws and regulations IBS/INS, if so equipped Marine Propulsion Systems *The content of the training should be appropriate to the tonnage, route and/or type of vessel. For example, Advanced and Emergency shiphandling can be performed aboard an OSVs, tugs and ferries, rather than in a full mission simulator.

20 ADDITIONAL COMMENTS MERPAC recommends that the government pursue creating methods of funding for maritime education due to the impact of the regulatory training and education requirements. (46 USC sec 51103)