PVA opposes training course proposal
November 26, 2012
The regulatory hits just keep on
Among the latest under consideration
by the Coast Guard is a mandatory 32-hour training course for facility security
The Passenger Vessel Association said the proposal is way out of
bounds. Citing the Coast Guard Authorization Act of 2010 that deals with facility
security officer training, PVA noted that many of the topics are irrelevant to
Cargo theft, for example, is hardly
a problem for domestic passenger vessels “since they rarely, if ever, carry cargo,”
PVA said in its comments filed for the record. On passenger vessels, also there’s
usually no containers, hazardous cargo or a need to be concerned about shore
leave for mariners because most go home each day.
What’s more, many facilities provide
security under an alternative program approved by the Coast Guard, PVA said.
And the trade group questions whether there’s any evidence that security has
been compromised or is ineffective because current officers haven’t taken a
The draft model course comes down
too hard on small businesses, a category that includes many passenger vessel
operators, PVA said. “The Coast Guard is legally obligated to make a good faith
analysis of the economic impact of a proposed mandatory [officer] training
course on small entities.”
Ticking off other recent mandates
including TWIC, the biggest thorn in everyone’s side, PVA said, “The cumulative
impact of all these regulatory initiatives is staggering.”
Others that weighed in with objections
or questions about the proposal included the Baltimore International Seafarers’
Center, the marine division of the King County [Seattle] Department of
Transportation, and the Casco Bay Transit District, Portland, Maine.
The proposal and comments are
available at www.regulations.gov;
enter USCG-2012-0908. The deadline for comments was Nov. 23.