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 by July 2010 thus ending the Interim Regulations.

The proposed implementation includes changes in required seatime 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.

The overall proposal is 90 pages long and can be accessed through the following link:
http://govpulse.us/entries/2009/11/17/E9-26821/implementation-of-the-1995-amendments-to-the-international-convention-on-standards-of-training-certi

A working group of the Ships’ Operation and Safety Committee (SOS) at ASTA has been working to determine what aspects of the proposal may affect ASTA members and is preparing comments to be submitted in ASTA’s name to the CG regarding this docket.

Below are some of the items that the working group feels may impact our member vessels who travel on an ocean or near coastal route.

Additionally, most of these items WILL affect mariners who hope to upgrade or obtain
first issue merchant mariner credentials.

You are strongly encouraged to take some time to read through the pertinent sections of this proposal and send a comment from your own organization. The specific impact of this proposal must be determined by each organization.

The deadline for comments is Feb 16th. The procedure for submitting comments is outlined here – Federal Register Docket No. USCG-2004-17914 (PDF) .

Also of note, there will be a public comment session held at USCG Headquarters in DC next week on Jan. 20. ASTA and SEA will be sending representatives to this session. It is very important to have as many representatives as possible from affected programs at this session. Please consider sending a representative to this meeting. The address and time of this meeting may be found in the attached document.

SOME KEY POINTS FROM THE PROPOSAL:

200GRT NC Mate (suitable for int’l voyages) will require three years of sea time (1080 days) for an original issue. This is three times longer than the current requirement.
(As this relates to STCW it is unlikely that we can have any effect on it, but it will make finding NC mates in the 200 ton category very difficult for international voyages or voyages which enter foreign waters)

Rating Forming Part of a Navigation Watch (RFPNW) will require service on vessels over 200GRT.
(Time that is extremely difficult to obtain in our industry.)

The lowest level Master/Mate licenses for Oceans will now be 1600 tons. No new Ocean 500, 200, 100 ton licenses of any kind will be issued. Existing licenses of this tonnage will be renewed. Primary qualifying time for 1600/3000 will be 75GRT.

Flashing light will be required for all licenses (not ratings) subject to STCW code (all over 200GRT, all Oceans, all NC int’l.) and for upgrades if not previously completed.

To obtain 1600 GRT Mate or Master, applicant must qualify for AB and RFPNW (The requirement is a hurdle for all new applicants for ANY Ocean or NC Int’l Mate or Master license.)

All licensing pathways above 200GRT operating in waters subject to STCW Code will require sequential advancement from Mate to Master. (This differs from the current scheme.)

OUPV for nearcoastal waters will be limited to sailing on domestic voyages out to 100nm.

Mariners holding a valid STCW endorsement on or before the effective date of the final rule will NOT need to take additional training to retain the STCW endorsement. (USCG is aiming for July 2010) Any future upgrades will only need to meet the requirements for the new credential being sought.

Mariners currently in the application process should move forward as rapidly as possible to avoid new requirements.

To clarify the impact of adoption of rules, any new mariner wishing to progress to mate or master of any vessel that transits foreign waters or into Ocean waters (>200nm from shore) will now be required to obtain a 1600GRT/3000GT license REGARDLESS OF THE TONNAGE OF THE VESSEL.

In closing, the sail training and small vessel industry continues to be unrecognized to our detriment when new rules and regulations are introduced.

It is safe to say that if this proposal goes through unchanged, the challenges of attaining new licenses will increase dramatically and vessels who include any foreign portion in their program will experience extreme difficulties meeting their manning requirements.

We need to make and keep the USCG aware of the impact these changes will have on our industry.

If you or some representative from your organization is unable to attend the session in DC next week, and have a specific question you would like addressed at that session, Jonathan Boulware has volunteered to be the ASTA point of contact.
Jonathan Boulware
j_boulware@hotmail.com
203.500.3404 cellular

Thank you for attention to this,
Deborah Hayes Co-Chair SOS Committee
Jonathan Boulware
Jennifer Haddock
Jonathan Kabak

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