Mariners need to prepare for another round of big technical changes that will be coming soon to your Merchant Mariner Credential (MMC). It will still look the same — a small red passport-style booklet that contains each mariner’s domestic and international qualifications. What is undergoing a seismic shift are the federal regulations that control all of the stuff that goes inside the MMC.
The Coast Guard recently published a Supplemental Notice of Proposed Rulemaking for the implementation of the 2010 STCW amendments, as well as changes to our domestic “endorsement” (LICENSING!) system. Click here for the text or here to download the pdf file. It contains a lot of serious content and my initial reaction is that a good bit of it has the potential to improve the current state of affairs. I’ll comment more on that after I delve deeper into it.
I urge every mariner to thoroughly read the SNPRM and submit comments to the Coast Guard. The public comment period is just 60 days, ending on Sept. 30. To me, two months doesn’t appear to be enough time to consider this important proposal, unless the intention is to have one or more Interim Rules (IRs) that will also be subject to public review, comment and appropriate revision. STCW generally undergoes major changes only at long intervals, and there are substantial changes to our domestic rules too, so this must be done right. But that takes time and the comment period should be twice as long.
While I’m on the subject, does the Coast Guard honestly expect full participation from the entire U.S. maritime industry that will be affected by these proposed changes when the industry is about to be consumed by the publication of the new Towing Vessel Inspection Program rules?
If the towing vessel inspection Notice of Proposed Rulemaking comes out this week, as rumored, that means two major industry rulemaking procedures will be open to public comment simultaneously. If it is subject to the typical 60-to-90-day comment period, the industry and mariners will have a tough time submitting constructive criticism and/or affirmation that will help the inspection program live up to the expressed desires of the Congress that made it law.
It would probably be wise to wait until the STCW comment period closes before publishing the towing vessel inspection NPRM or at least make the comment period long enough to give everyone time to properly read and digest it. Go long, Coast Guard, go long.