The USCG has solicited comments on the proposed rulemaking to fully implement the STCW Code (International Convention on Standards of Training, Certification and Watchkeeping for Seafarers Code and Convention.) The ruling includes a number of clarifications and changes in 46 CFR Parts 10, 11, 12 and 15. The deadline for the comment period is February 16, 2010 with a planned implementation of the new ruling in July 2010.

 Many of these proposed changes will seriously affect current and future mariners, especially within our industry.  The USCG is proposing increased sea time and increased tonnage requirements to qualify both assessments and sea-time in several endorsements/licenses. This will make it extremely difficult for mariners who commonly sail on vessels under 100 tons to advance to higher licenses and will also limit many mariners to near-coastal domestic voyages.

All concerned mariners/program operators/vessel owners should submit a comment to the USCG (see USCG instructions below) listing their concerns regarding the proposed changes. We have been told very clearly that the only way to have our message heard in Washington is to have as many ASTA members as possible submit comments. The proposed changes are 90 pages (open link to read in its entirety) and the synopsis of important changes that we include below is by no means complete.  The Ship’s Operations and Safety Committee has been reviewing this proposal for a long and every time it is reviewed, a new item is discovered that may adversely affect a portion of our industry.  Please keep in mind that the real effect of many of the proposed changes may not be felt for some years. It is important that you take the time to comment on this ruling!

 http://govpulse.us/entries/2009/11/17/E9-26821/implementation-of-the-1995-amendments-to-the-international-convention-on-standards-of-training-certi

 For those who are just becoming aware of this ruling and need more information, please read ASTA’s comments as  delivered by Capt. Jonathan Kabak at a public comment session in Washington, DC on Jan. 20th.

Among the changes proposed by the USCG:

The elimination or changes of the following license endorsements –

 – Elimination of new issuances of and upgrades to Mate or Master 500GRT Near Coastal, International, or Oceans, and Master 200GRT Oceans.

Existing credentials will be renewed.

– New rules will require 150GRT sea-time to obtain a 1600GRT Master.  A 1600GRT Master will become the lowest denomination of Ocean license available

 – A first-issue NC Mate, 200GRT/500GT (suitable for int’l voyages) will now require 1080 days of sea time, instead of the current requirement for 360 days.

Requirement for domestic NC Mate will remain 360 days.

 – Practical signal examination (flashing light) will be required on new issue Oceans and Near Coastal (international) licenses AND when renewing or upgrading to     endorsements for these licenses (if applicant has not previously passed this exam).

Changes for OUPV or “six-packs” –

Uninspected passenger vessels (UPV) MAY be issued a safe manning certificate listing the number and type of crew required for an international voyage. The new ruling limits the international travel for a UPV to a “single international voyage of a non-routine nature.” 

– OUPV’s endorsed for Near Coastal travel will be limited to 100 nm.

 Also Proposed –

– Sea time requirements for Ratings Forming Part of a Navigational Watch (RFPNW)  is six months sea service, half of which must be on vessels of at least 200 GRT/500GT. 

(1600 ton Chief Mate and OICNW (mate) will have qualifying tonnage of 75GRT, and it’s a superior license.) 

  – All assessments for both RFPNW and Officer in Charge of a Navigation Watch (OICNW) must be conducted on vessels over 100 Gross Registered Tons.

 Also Proposed –

– Sea time requirements for Ratings Forming Part of a Navigational Watch (RFPNW)  is six months sea service, half of which must be on vessels of at least 200 GRT/500GT.
(1600 ton Chief Mate and OICNW (mate) will have qualifying tonnage of 75GRT, and it’s a superior license.)

– All assessments for both RFPNW and Officer in Charge of a Navigation Watch (OICNW) must be conducted on vessels over 100 Gross Registered Tons.

 Click here for a basic sample template that you may use to submit your own comment. Each vessel/program will be affected differently by these regulations.  Please feel free to alter this in any way that is appropriate for your vessel/program/license or to simply refer to the above bullet points.

 Thank you in advance for taking the time to comment on these important proceedings.

 Sincerely,

STCW Proposal Sub-Committee,
Jonathan Boulware
Jennifer Haddock
Deborah Hayes
Jonathan Kabak

 Instructions for Comment USCG FR Vol. 74, no. 220

I. Public Participation and Request for Comments

We encourage you to participate in this rulemaking by submitting comments and related materials. All comments received will be posted,without change, to http://www.regulations.gov, and will include any personal information you have provided.

A. Submitting Comments

If you submit a comment, please include the docket number for this rulemaking (USCG-2004-17914), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail or hand delivery, but please use only one of these means. We recommend that you include your name and a mailing address, an e-mail address, or a phone number in the body of your document so that we can contact you if we have questions regarding your submission.

To submit your comment online, go to http://www.regulations.gov, in the “Document Type” drop down menu, select “Proposed Rules” and insert “USCG-2004-17914” as the “Keyword.” If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 81/2by 11 inches, suitable for copying and electronic filing. If you submit them by mail and would like to know that they reached the Facility, please enclose a stamped, self-addressed postcard or envelope.

We will consider all comments and material received during the comment period and may change this proposed rule based on your comments.

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