The Merchant Mariner Medical Advisory Committee (MEDMAC) was formed three years ago to help simplify and clarify a medical review process that vexes many mariners trying to get their credentials from the Coast Guard.
It’s not a quick or easy fix.
MEDMAC, a federal advisory committee made up of 10 health care professionals and four mariners, was scheduled to meet in late September after not having met officially since a year ago when they had no quorum. Seven new member applications were under review to fill vacancies. Also, the Coast Guard’s National Maritime Center (NMC) expects to have a new medical evaluation division chief this fall to head the 35-person division replacing Dr. Laura Gillis, who resigned last year.
In addition, the Coast Guard’s normal workload increased with the new STCW rules that require more frequent medical certification for some mariners.
High on the committee’s to-do list is a revision of the complicated Navigation and Vessel Inspection Circular (NVIC) 04-08 that lays out medical and physical evaluation guidelines.
MEDMAC members say they’ve made progress especially in being more adaptable to conditions that might have barred mariners in the past. And they’ve endorsed a Designated Medical Examiner (DME) program — a nationwide network of professionals who know what the rules are and are authorized to issue certificates.
Meanwhile, frustration with the medical certification process persists.
“You people want a 20-year-old body with 20 years experience,” Capt. Rhett J. Meyers with the Associated Branch Pilots, Venice, La., said in response to the Coast Guard’s request for comments on the examiner program. The program would be similar to those run by the Federal Motor Carrier Safety Administration and the Federal Aviation Administration (FAA).
“What mariners need is a go-to person,” Meyers said in a recent interview. “Every time I called the Coast Guard with a question as to what they wanted, I would get somebody different. If my hands-on doctor says I’m OK, how can a bureaucrat several states away determine whether I’m fit or not? I can understand safety, but they’re keeping people from working.
KEEP MARINERS WORKING
And employment is what everyone says is the goal.
“We’ve made the NVIC much more flexible. We’re anticipating putting into place restrictions and limitations that will allow a mariner to receive certification but provide for further interaction with his doctors,” said Dr. Kenneth Miller, committee chairman. Or there would be geographic limitations, specifying near coastal rather than oceangoing work.
“That would apply to many of the medical conditions for which mariners have been denied in the past,” Miller said, such as seizures and the use of defibrillators. “The goal is to keep people employed. We’re working very hard to move this thing forward. I’m very optimistic at the end of the process mariners will have a much easier time getting their documents.”
The committee has suggested a system of health care providers trained and certified by the Coast Guard to perform medical evaluations that would be accepted by the agency. Mariners would have a choice of using the designated examiner or the current system — their personal doctor whose report would be reviewed by the Coast Guard. The DME “one-stop shop” is designed to speed the process, Miller said.
The American Waterways Operators (AWO) and the Passenger Vessel Association (PVA) favor the DME option. So does the International Organization of Masters, Mates & Pilots (MM&P).
The system “would be less onerous for the mariner,” said Klaus Luhta, chief of staff for the MM&P. It would provide uniformity and efficiency “so doctors evaluating mariners are part of the same system that issues the credentials.”
And he’d like to cut out some redundancies since companies give mariners medical exams when they’re dispatched. “So the mariner ends up having three or four physicals a year,” Luhta said. “It would be nice if we could use the employment physical.”
Dr. Joseph Tordella of Air, Land & Sea, Ocean City, N.J., who served a two-year term on MEDMAC and is both an airplane pilot and Coast Guard licensed master, said the big plus with examiners is standardization and training. And while working environments may differ in the air or at sea, “good medicine is good medicine,” he said.
The examiners may be part of the NVIC revision or require a separate rulemaking. “Going to some sort of hybrid system is probably best,” said Capt. Jeff Novotny, NMC’s commanding officer. “The bottom line is we’re here as part of the credentialing program to make sure we do what’s best for the mariner but equally we have to safeguard the marine transportation system. We’re not in the business of preventing people from getting credentials.”
Luke Harden, chief of the Mariner Credentialing Program Policy Division in the Coast Guard’s Office of Commercial Vessel Compliance, Washington, D.C., said the agency would consider the examiner recommendation but “has made no decision on the matter.”
Less than 1% of applications are denied for medical reasons, suggesting that mariners with known medical issues submit an application six months in advance of their expiration dates. New regulations allow NMC to post-date credentials, so the expiration date will not change even if the application is submitted early. Also as part of STCW, the NMC is issuing credentials and medical certificates separately, but the documents must be kept together. (In the past, medical certificates were embedded in credentials.)
Pilots and mariners on STCW vessels must renew medical certificates every two years, versus five years for others. The rule adds 18,000 to 20,000 applications to NMC’s average annual workload of about 60,000.
Published last Dec. 24, the rule mandated that mariners have certificates by March 24, so the Coast Guard started producing them Jan. 2. They sent 65,000 to mariners in the first three months of the year, Novotny said, and had issued another 40,000 as of mid-August. For the last several months, they’ve processed medical certificates in under 15 days.
NVIC REVISION BY YEAR END?
Harden, whose office drafts all NVICs, could provide no timetable on the medical NVIC changes.
“We have to go through a regulatory and policy process,” he said. “We’re working through the advisory committee process. We’re trying to keep moving.”
Capt. William Mahoney, committee vice chairman and a consultant for APL Maritime, expects the NVIC rewrite by the end of the year.
The new version “will be more specific to issues the mariner cares about, because there’s a lot of input from medical professionals,” he said. “The advantage for seafarers is they will now see there are waiver conditions versus adamant denial of documentation. Before, you were either fit for duty or unfit for duty.”
As for MEDMAC’s lack of a quorum, he said, “Of course, it’s frustrating for all of us. Those things are being addressed.”
He and others say the Coast Guard is listening. But some familiar with the committee said there was frustration that non-medical people had a lot of say over medical guidelines.
“They’ve been having some growing pains which any committee has when getting started. They’ve been working hard,” said Andrew McGovern, vice president of the Sandy Hook Pilots Association, Staten Island, N.Y., and the liaison to the medical committee from the Merchant Marine Personnel Advisory Committee (MERPAC), which he chairs.
It was a multiyear project just to get the original NVIC out. A lot of the information in it “needs to be updated on almost a continuous basis,” he said.
“Doctors are busy people and getting them all together has proven to be a little bit tough. You’re going to see a lot more work come out of it a lot quicker,” he said, urging public participation.
The current NVIC was prompted by the 2013 Staten Island Ferry accident that killed 11 and injured 70. The assistant captain, who did not disclose his medical condition and the medications he was taking, lost consciousness before the ferry Andrew J. Barberi slammed into a pier. The National Transportation Safety Board suggested that the Coast Guard overhaul its medical review process and require reporting the results of all physicals.
But there were concerns the NVIC didn’t provide enough specifics for medical examiners in the field, so mariners often had to get more tests that delayed certification. Others worried that the overhaul was so strict mariners would not get the care they need or fill a prescription for fear of losing their licenses.
“The current NVIC doesn’t set a very clear course on what a mariner needs to do,” said Clay Diamond, deputy director and associate general counsel for the American Pilots Association, and a member of the Navigation Safety Advisory Committee (NAVSAC), who’s been at MEDMAC meetings. “I don’t think any member of any segment of the industry appreciates more the need for medical standards than our members.”
