Commercial Vessel Compliance

9/23/2015: Mariner credentialing – Update from Commercial Vessel Compliance, Mariner Credentialing Division

Maritime Commons attended an open house hosted by the Coast Guard’s National Maritime Center to provide updates on the credentialing process, future credentialing policies and their impacts on mariners and industry.

The Coast Guard’s Office of Commercial Vessel Compliance CG-CVC, Mariner Credentialing Division Chief, Luke Harden, provided remarks and updates on CG-CVC operations and initiatives.

For those of you who were unable to attend, Maritime Commons is providing a condensed version of Harden’s remarks in a four-part series. These remarks are not ‘as delivered’ but provide a condensed version of the highlights for your informational purposes…

Delivered by Luke Harden, division chief of Coast Guard’s Office of Commercial Vessel Compliance, Mariner Credentialing Division

The Coast Guard’s Office of Commercial Vessel Compliance, or CG-CVC, is responsible for the management of the credentialing program. We do this in the Mariner Credentialing Division where we interpret standards and implement regulations, serve as the technical control office for the National Maritime Center, develop program policy, prepare final action on appeals and manage the Merchant Mariner Advisory Committee, or MEDMAC.

Current CG-CVC initiatives

MEDMAC Tasks:

  • The committee is currently working on a health risk analysis as a joint task with the Merchant Marine Personnel Advisory Committee, or MERPAC. As a follow-up to the publication of NVIC 04-08, the Coast Guard would like a review of mariner duties to determine whether the current one-size-fits-all medical evaluation that currently exists should be retained, or whether the evaluation should be varied based upon the endorsement held by the applicant. The maritime community has expressed interest in this type of study. Since both MERPAC and the Merchant Mariner Medical Advisory Committee, or MEDMAC, have expertise in the areas involved in this study, the Coast Guard is asking both committees to participate in the tasking. After receiving recommendations from both committees, the Coast Guard will consider the recommendations and develop an appropriate course of action regarding current regulations and policy. The course of action could result in further revision to NVIC 04-08, as well as proposing future changes to the medical evaluation regulations found in 46CFRPart 10, subpart C.
  • Revision of forms CG-719K & K/E, the application for medical certificates. The forms need to be reviewed every few years. MEDMAC will be reviewing the forms that are to be released in October.
  • Mariner medical education and prevention
  • Review of MSC/Circ. 1014-Guidance on Fatigue Mitigation & Management

Standards of Training, Certification and Watchkeeping STCW

The implementation of the STCW final rule impacted all mariners holding STCW certifications. To provide further information and clarification, we’ve published 24 STCW Navigation and Vessel Inspection Circulars, or NVICs, from this final rule.

Though we’ve published these guidance documents, all 24 NVICs can and should be revised as necessary. If you see something that needs changing, you should let us know.

The ‘STCW Rule Frequently Asked Questions’ was last updated July 22, 2015 and the complete list is on NMC’s website.

For questions and feedback on STCW or policy documents, you can email us at: STCWask@uscg.mil

To provide feedback on NVICs, email us at:mmcpolicy@uscg.mil

NVIC policies under development

We are currently working on four NVICs for assessment of offshore supply vessels. Initially, this began as one big NVIC but we realized that we needed to go into more detail and divide the one into four separate pieces of guidance.

We are also working on the revision and rewrite of medical evaluation guidelines (NVIC 04-08) and the top 10 medical conditions mariners are affected by. We are focused on information collection and how we will evaluate mariners affected by these ‘most common’ conditions. Once we have this information, we will write the policy and criteria for evaluating someone with this condition.

Lastly, we are working on revising the NVIC for ‘Guidelines for Credentialing Officers of Towing Vessels.’ It’s gone through the Towing Safety Advisory Committee and we are working toward finalization.

The appeal process for denied mariner credential

Regulations spell out the process of denying a mariner’s credential. The denial starts with receiving a decision from the National Maritime Center. The mariner applying for application may or may not agree with the NMC’s decision, in which case you may appeal.

Steps in the appeal process:

  • First, you ask NMC to reconsider their decision
  • If you don’t agree with that second decision, send an appeal to Coast Guard Headquarters at this email address:
  • Coast Guard Headquarters reviews the appeal and renders a final decision which is the final answer from the Coast Guard on that issue

Appeal trends

So far, for 2015, we are on a downward trend in appeals received. For 2015, we have looked at 90 appeals so far. In years past, we receive somewhere over 200 annually.

Generally, about 35 to 40 percent of appeals are granted. The other appeals are either denied or receive other outcomes, such as partial granting of an appeal. One of the biggest trends we see is that medical appeals used to be at an approval rate of about 65 percent; as policy has changed that number has been reduced.

We have about 208,000 active mariners in the system. About 10 to 11 percent are currently on a waiver. Over the last several years, denials for medical reasons are less than one half of one percent of all applications that come in. The number of denials is way down. In 2011, we received 300 appeals where now, we are looking at 90 for the entire year. I would just point out that 90 appeals out of 60,000 is a much smaller number.

In addition to this post, be sure to read the other posts from the National Maritime Center open house and information sessions.

Part 1: Update from the National Maritime Center
Part 2: Update from Commercial Vessel Compliance, Mariner Credentialing Division
Part 3: Update from Operating and Environmental Standards, Maritime Personnel Qualification Division
Part 4: Update from the Office of Investigations and Casualty Analysis and Suspension and Revocation NCOE

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

 

mailto: STCWask@uscg.mil