In the interest of safety, about four years ago the U.S. Coast Guard decided it needed to make revisions to the rules governing STCW.
So on Dec. 24, the Coast Guard published the final rule on STCW amendments and changes to domestic endorsements. The agency said the final rule makes necessary changes designed to bring U.S. mariners more in line with mariners from other countries that operate under the International Maritime Organization (IMO). This will ensure that U.S. mariners comply with the standards set forth in the STCW Convention and Code. It will also reorganize, clarify and update national endorsements and general requirements, according to the Coast Guard.
STCW, the International Convention on Standards of Training, Certification, and Watchkeeping, was first adopted in 1978. This is the Coast Guard’s second major set of revisions to the STCW convention, having already overhauled the document in 1995.
“The final rule sets out how a U.S. mariner may obtain an STCW endorsement and clarifies the requirements for each endorsement, including training, service, and assessments,” Rear Adm. J.A. Servidio, assistant commandant, prevention policy, wrote in an open letter to the U.S. maritime industry when the rule was published on Dec. 24. “I recognize that many mariners are anxious about the impact of these regulations. I completely understand this anxiety and my staff and I will do everything we can to ensure a smooth transition over the coming months and years.”
STCW affects vessels that operate beyond the boundary line, in U.S. near-coastal waters (200 nm offshore), and in near-coastal waters of a foreign country. It does not affect mariners on small vessels that are exclusively engaged on domestic voyages and does not apply on the Great Lakes.
It does affect mariners on Gulf of Mexico OSVs.
“The Final Rule came out Christmas Eve (2013), so we’re 60-plus days out, and I wouldn’t say I understand all the rules of the game,” said Richard Wells, vice president, Offshore Marine Service Association, New Orleans. “It’s way too early for that.”
“Yes, this will bring the U.S. mariner more in line with mariners from other countries, but it will create a lot more paperwork, though, which can be a negative factor,” said Holly Chetta, who owns and operates Mariners World Central, a New Orleans consulting firm that helps mariners put together their credentials and license packages.
The final rule (the “Implementation of the Amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 (STCW), as Amended, and Changes to National Endorsements) is as thick as a college textbook. In spite of its girth, it’s lacking in guidance on the issuing of STCW endorsements under its own regulations. In fact, the Coast Guard will publish 26 Navigation and Vessel Inspection Circulars (NVICs) to provide guidance in implementing the final rule. Nine NVICs had been released as WorkBoat went to press in March.
POSITIVES
Wells, a former Coastie and REC head and OMSA’s point man on STCW, said that like many government regulations, the STCW final rule is a mixture of good news and not so good news. Among the positives:
• OSV endorsements are now permanently in the mariner credential regulations.
• Current OSV credentials will see their maximum tonnage increased from 500 GRT to 1,600 GRT.
• Inland and Great Lakes service can now count toward an STCW endorsement.
• Existing mariners may choose to apply under the current requirements potentially until late 2016.
• The number of QMED (Qualified Member of the Engineering Department) ratings is reduced.
• The Coast Guard has published a process for “recognition” of the STCW endorsement of a non-U.S. mariner credential as required by STCW Regulation I/10.
• The USCG has clarified that the five-year revalidation training requirements do not come into effect until a mariner’s first renewal on or after Jan. 1, 2017.
“I think this has been done more as a way to increase mariner competency, which would then increase safety,” said Wells. “The problem is that the majority of accidents that triggered these changes had nothing to do with U.S. vessels.”
CHALLENGES
Wells said several items in the STCW final rule are not so good:
• The OSV endorsement requirements are identical to an endorsement for any gross tons. While the final rule says the Coast Guard may exempt an applicant from meeting any requirement under STCW that it determines to be inappropriate or unnecessary for service on an OSV, it is unclear how that decision will be made.
• Most limited tonnage STCW endorsements will require more sea service than previously required and inland service is limited to 50% of the total required service.
• Grandfathering is limited to only the first application submitted and even grandfathered applications will require additional training and assessments if submitted more than six months after the USCG publishes a NVIC specifying the training and assessments for all engineer officer (license) endorsements and Master/Mate 500/1,600 GRT endorsements.
• All current able seaman (AB) and QMED holding mariners will need to apply for and receive a new STCW endorsement as able seafarer–deck (ASD) or able seafarer-engine (ASE) before 2017.
All merchant marine credentialed mariners who hold an STCW endorsement should have a medical certificate by March 24. The certificate must be renewed every two years for pilots and mariners serving on vessels under STCW scrutiny. (Other mariners must have it renewed every five years.)
“Mariners with certain medical conditions may receive a time limited certificate,” the final rule says. “Medically related restrictions and operational limitations will only be reflected on the medical certificate no longer on the MMC.”
Jan. 1, 2017, is the date for full compliance with STCW requirements and March 24, 2019, is when the transition period ends for national endorsements.
“I think it’s going to be good for the mariner in the long run,” said Chetta, “but it’s impossible to say to what degree right now because there is so much that we don’t know.”
Wells said he has several questions awaiting answers from the Coast Guard. “I don’t want it to sound like I’m picking on the Coast Guard,” he said, “but this is going to cost mariners more time and more money.”
Important STCW Dates
• Dec. 24, 2013: Final rule published
• Jan. 24, 2014: Medical certificate requirements became effective
• March 24, 2014: All other provisions of the final rule are effective
• Jan. 1, 2017: Full compliance with the STCW-related requirements in the final rule
• March 24, 2019: Transition period for national endorsements ends
