September’s regularly scheduled Merchant Marine Personnel Advisory Committee (MERPAC) meeting was cancelled. The Coast Guard cites failure to have a “signed” charter as the reason. With MERPAC committee members in the dark about MERPAC’s future the Coast Guard can make key STCW decisions without important stakeholder input. Does the Coast Guard have the expertise and/or the best interests of our U.S. mariners at the heart of their decision-making process? Established in 1992 at the request of the Coast Guard Commandant, the MERPAC advises the Secretary of the Department of Homeland Security (DHS). There is a fire of doubt of a possible hidden agenda fueled by the removal of the exam questions and answer database from the National Maritime Center’s web page and the concealing of Coast Guard policy letters from the public. Their tight-lipped approach to issuing the proposed new sub-chapter M towing vessel regulations reveals a philosophy of “no information is good information.” This does not sit well with mariners who expect the Coast Guard to operate within the traditions of our free and transparent society.
After hearing about a recent article at MaritimeProfessional stating that the Coast Guard had signed on to the STCW revisions at the June IMO meeting in Manila, I called Ms. Mayte Medina at the Coast Guard to reaffirm their intent to publish a Supplemental Notice of Proposed Rulemaking (SNPRM) as a next step to STCW as was promised in April. This “supplemental” notice would describe any proposed changes from the original notice and seek comments from the public on those proposed changes. The Coast Guard decided to go back to the drawing board after an outcry from industry during the last NPRM comment period. Ms. Medina explained that the STCW process requires the Coast Guard to review anything done at the international level before it can become part of the Code of Federal Regulations (CFR’s). She assured me that we would see a notice on the revisions sometime in the future opening them up for public comment.
The new additions to STCW could have a far reaching effect in the United States. As such, the Coast Guard will have a host of issues on their plate, because the sweeping overhaul of the rules include, among other things:
Improved measures to prevent fraudulent practices associated with certificates of competency and strengthen the evaluation process (monitoring of each country’s compliance with the Convention).
Revised requirements on hours of work and rest and new requirements for the prevention of drug and alcohol abuse, as well as updated standards relating to medical fitness standards for seafarers.
New certification requirements for “able seafarers.”
New training requirements for modern technology such as electronic charts and information systems (ECDIS).
New requirements for marine environment awareness training and training in leadership and teamwork.
New training and certification requirements for electro-technical officers.
Updating competency requirements for personnel serving on board all types of tankers, including new requirements for personnel serving on liquefied gas tankers.
New requirements for security training, as well as provisions to ensure that seafarers are properly trained to cope if their ship comes under attack by pirates.
Introduction of modern training methodology including distance learning and web-based learning.
New training guidance for personnel serving on board ships operating in polar waters.
New training and guidance for personnel who operate “Dynamic Positioning Systems.”
It is always a significant event when the Coast Guard cancels any advisory committee meeting. Each meeting is one of the most direct ways for the public to provide their input to the Coast Guard. In this case input from our mariners would have been very important because MERPAC had some tasks relating to the implementation of the 2010 amendments to the STCW Convention that will come into force on Jan. 1, 2012. Timing of the meeting’s cancellation is both curious and potentially crippling to the interests of our mariners.
The Shipping Operations Cooperative Program (SOCP) offered to step in and meet at MITAGS (on Sept. 8 & 9) to discuss the full range of subject matter related to the so-called “Manila” STCW amendments. SOCP addresses and promotes commercial development of new methods, procedures, and technologies, and this effort makes sense in the absence of MERPAC. How the SOCP rescue effort will be received by the regulatory part of the U.S. Coast Guard has yet to be determined. I asked Ms. Medina why MERPAC members and SOCP could not continue their work through TSAC work groups to give the uncompleted tasks an official capacity, as that could be a possible solution in filling the void.
The National Mariners Association has been around long enough to witness “end runs and broken promises” by the Coast Guard so there is sound reasoning behind our paranoia. There still remains an important question unanswered: has the Coast Guard met the legal conditions of the treaty that requires taking the “new” 1005 amendments back to the United States Senate for formal ratification. We see their failure to do this as an “end run” and something they should have done fifteen years ago. As a military force given sweeping powers of law enforcement and supervision over the U.S. Merchant Marine by Congress, there are serious implications if the Coast Guard goes ahead with an international treaty that walks all over our “limited-tonnage” mariners who represent a majority of all merchant mariners.
Mariners who work on tugs and towboats must keep their eyes on the ball and speak out on these STCW revisions. How much will it cost to advance and maintain your credentials, especially those with obtuse STCW wording, if the Coast Guard plows ahead without ensuring that these revisions are fair and backed by the mariners who work in the industry? Haven’t we had enough crammed down our throats in the last five years? Since 2006 the Coast Guard has been telling us that the “hawsepiper” was an important part of the training process. The folks at the National Maritime Center promised a distance-learning program for the hawsepipe mariner that would guarantee them an equal opportunity. Between the chatter the Coast Guard continues to partner with the schools and create policies that block our working mariner’s career path. They have built a cottage industry around the licensing and training process with the cost placed on the backs of our mariners. Hawsepipers are simply being priced out of the market. Is it simply a coincidence that these approved schools are filled with retired Coasties who just happen to be making big bucks as a result of these Coast Guard policies? Without proper revision and oversight of the STCW rulemaking, our hawsepipers are doomed. For the price of a cup of coffee mariners could keep it open.
Captain Joe Dady President, National Mariners Association Towing Safety Advisory Committee Member
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