Monday, August 8, 2011

Monday Morning Mariner: STCW Changes. Again.

I've written before about both the IMO's changes to the STCW Convention and the US Coast Guard's efforts to bring the American licensing and documentation system more in line with that of the rest of the world. Part of the Coast Guard's procedure for implementation of new regulations is public feedback and, as a result of feedback on some of the proposed changes, the Coast Guard has issued a Supplementary Notice of Proposed Rulemaking (SNPRM) incorporating some the concerns raised at both the public meetings and written comments.

Among the proposed changes are an attempt to separate the US domestic licensing system from STCW requirements, while at the same time allowing service on Inland or Great Lakes vessels to qualify -- at least in part -- a mariner for an Oceans license. It's unclear if this applies to all licenses or only those of unlimited tonnage. The formula would be day-for-day for Great Lakes service and "1 day of ocean service for every 2 days of inland service for up to 50 percent of the total required service." The Coast Guard cites differences in conditions, vessels and equipment, and training as the reason for the difference in sea service credit.

The Coast Guard also proposes to change medical requirements to more closely fall in line with international standards. STCW medical certificates will only be valid for two years, and only for one year from pilots and mariners under 18 years old. The requirements for US-issued credentials would remain at the current five years. Mariners will now be required to demonstrate physical ability, and there will be changes to the hearing and visions tests. On the one hand, the range of allowable vision tests will be expanded and not limited to the current, often unavailable, specific tests. On the other hand

the Coast Guard proposes to revise the vision standards for deck personnel with STCW endorsements by expanding the applicability of the vision standards from one eye to both eyes. This proposal would provide consistency with the 2010 amendments to the STCW Convention. Requirements for mariners who suffer from vision loss or lost vision in one eye remain the same

Implementation. The comment period for the SNPRM expires at the end of September. Expect the new regs to kick in early in 2012 with requirements phased in based on the expiration date of the mariner's current credentials. Those mariners with expiration dates in 2012 are likely to have to meet the new requirements early on.

For the text of the complete SNPRM, click here.

For my post on the current US license and MMD structure, click here.

For my post on mariner medical requirements, click here.

For my post "Is STCW Un-American?" click here.

For my post on proposed changes to the deck license structure, click here.

For my post on proposed changes to the engineer license structure, click here.

For my post on the Maritime Labour Convention, including the "Seafarer's Bill of Rights," click here.

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