Total #
776
                            MERPAC Recommendation 
Status 

                                    Action
                                      by
                                 USCG Response
                                       
1-93
NMC
Institute procedures whereby all seamen are required to complete a physical examination including drug testing at the entry level.  6/93, revised 12/93
Closed


2-93
NMC
Seamen who are granted a physical/medical waiver should be required by the Coast Guard to undergo a medical review of the condition for which the waiver was granted.  The period of the waiver should be determined by the Coast Guard.  6/93, revised 12/93
Closed


3-93
NMC
Include a requirement for a physical examination as determined by the highest endorsement on a seaman's document at the time of renewal when the Coast Guard develops the regulations concerning renewal of documents.  6/93, revised 12/93
Closed


4-93
Revise the Committee's Charter to expand membership by allowing individuals from all marine industries to be eligible for membership.  12/93, revised 6/94
Closed


1-94
NMC
Licensing 2000 and Beyond Report recommendations are valid and should be acted on.  6/94.
Closed


2-94
NMC
Practical testing may be done by simulation as an improved addition to current testing.  The testing of knowledge should include the testing of practical skills demonstration.  6/94
Closed



3-94
Current Coast Guard Research and Development in simulation training should be shared with MERPAC.  6/94
Closed


4-94
NMC
License examination subject areas should be analyzed to determine which areas are suitable for approved courses.  Replace selected parts of the licensing requirements with approved courses.  6/94
Closed


5-94
NMC
Seek advice from education review bodies on course structure methodology and content for approved course.  Coast Guard personnel should be trained in what approved courses should contain.6/94
Closed


6-94
NMC
Radar courses should integrate river navigation by radar into their curriculum. 6/94
Closed


7-94

Coast Guard should develop a position paper on designated examiners and approved instructors.  6/94
Closed


8-94
NMC
Coast Guard should undertake a study to review the fitness of the merchant marine to determine if the current medical requirements are effective for ensuring a safe industry.  6/94
Closed


9-94
The report Review of marine safety issues related to Uninspected Towing Vessels report recommendations is valid and should be acted on as it applies to merchant mariners.  6/94
Closed


10-94
NMC
The Coast Guard should keep MERPAC aware of developments in the process of course approvals that significantly impact the role of MERPAC.
Closed


1-95
NMC
A greater emphasis should be placed on developing a centralized approval and oversight team to ensure consistent application of the established guidelines of approved courses.
Closed


1-96
With regard to regulatory project 79-116, revise definition of "line of sight to be "in direct line of sight of the person-in-charge, and/or maintaining direct, two-way communications on a pre-determined working frequency by a convenient, reliable means, such as a hand-held radio." (5-96)
Closed


2-96
With regard to regulatory project 79-116, all communications should be required to be in English. (5-96)
Closed


3-96
With regard to regulatory project 79-116, a pre-determined radio frequency must be agreed upon by both parties at the pre-transfer meeting. (5-96)
Closed


4-96
With regard to regulatory project 79-116, the Coast Guard should require training in the proper use of radio communications as part of the tankerman endorsement course.(5-96)
Closed


5-96
With regard to regulatory project 79-116, if an interpreter is used, the Coast Guard should require the interpreter to have basic knowledge regarding PIC duties and responsibilities. (5-96)
Closed


6-96
With regard to regulatory project 79-116, the Coast Guard should withdraw all provisions concerning the use of a Tankerman-Restricted endorsement; OR utilization of the Tankerman-Restricted endorsement should be denied to those seeking an original endorsement. (5-96)
Closed


7-96
With regard to regulatory project 79-116, the Coast Guard should not permit marine chemists to operate as person-in-charge of a marine transfer. (5-96)
Closed


8-96
With regard to regulatory project 79-116, 33 CFR 155.710(e) should be amended as follows: The operator or agent of each vessel to which this section applies shall verify to his or her satisfaction that the person responsible for the transfer of fuel oil, where a DOI is required, shall be licensed or shall hold an endorsement as tankerman-PIC unless specified elsewhere in these regulations. On uninspected vessels not requiring a licensed person aboard, the person responsible for the transfer of fuel oil must be instructed by the operator or agent of the vessel both in his or her duties and in the Federal Statutes and regulations on water pollution that apply to the vessel.  On uninspected vessels requiring a licensed person aboard, the person responsible for the transfer of fuel oil must be instructed by the licensed operator or agent of the vessel both in his or her duties and in the Federal Statutes and regulations on water pollution that apply to the vessel.  That individual so instructed may then act as person-in-charge of the fuel oil transfer. (5-96)
Closed


9-96
With regard to the proposed regulations for the Implementation of the 1995 STCW Amendments, any certified licensed officer (Deck, Engine, or Radio) should have the GMDSS endorsement (either as Operator or Maintainer) printed on his or her license, and any certified unlicensed seafarer should have the GMDSS endorsement printed on his or her merchant mariner's document. (5-96)
Closed


10-96
With regard to the proposed regulations for the Implementation of the 1995 STCW Amendments, the USCG should eliminate its proposed rating for Electronic Technician (GMDSS) and Electronic Technician (non-GMDSS).  This rating should be replaced with an endorsement as GMDSS Maintainer for which both licensed and unlicensed personnel will be eligible. (5-96)
Closed


1-97
NMC
With regard to CG approved training, a remission ratio of 6 days of sea service for 1 day of CG approved simulator training on visual simulators, manned models, and training vessels, with a maximum of 25% of the required sea service, should be allowed. (3/97)
Closed


2-97
NMC
The remission ratio of 6:1 mentioned in Recommendation 1-97 can be increased if justified.  However, a maximum of 25% of the required sea service would still be allowed.(3/97)
Closed



3-97
NMC
Marine simulation should be used in conjunction with other training methodologies during routine training, including cadet training at the maritime academies, for the development and qualification of professional mariner knowledge and skills. (3/97)
Closed


4-97
NMC
The U.S. Coast Guard should oversee and guide the establishment of nationally applied standards for all simulator-based training courses within its jurisdiction.  Standards developed should include consultation with, and perhaps use of, outside expertise available in existing advisory committees, technical groups, forums, or special oversight boards.  If the CG relies on outside bodies, the process should be open and include interdisciplinary consultation with professional marine, trade, labor, and management organizations; federal advisory committees; professional marine pilot organizations; and marine educators, including state and federal maritime academies.  Whatever process the CG chooses to use should be acceptable from a regulatory standpoint.  (3/97)
Closed


5-97
NMC
U.S. licensing authorities should require that instructors of simulator-based training courses used for formal licensing assessment, license renewal, and training for required certifications (i.e. liquid natural gas carrier-watchstander, offshore oil port mooring masters) be professionally competent with respect to relevant nautical expertise, the licensing process, and training methods.  The professional qualifications of the lead instructor should be at least the same as the highest qualification for which trainees are being trained or examined.  Criteria and standards for instructor qualification should be developed and procedures set in place for certifying and periodically re-certifying instructors who conduct training.  (3/97)
Closed


6-97
Marine pilotage authorities and companies retaining pilot services should encourage marine pilots, docking masters, and mooring masters who have not participated in an accredited ship-bridge simulator or manned-model course to do so as an element of continuing professional development.  Marine Pilot organizations, including the American Pilots' Association and state commissions, boards, and Associations should, in cooperation with companies retaining pilot services, establish programs to implement this recommendation.  (3/97)
Closed


7-97
Use of simulators for professional development should be fully implemented on an international scale to enhance the professional development of all mariners who operate vessels entering U.S. waters and to reduce the potential for accidents.  The CG should advocate this strategy in its representation of marine safety interests to the IMO and other appropriate international bodies.
Closed


8-97
NMC
The U.S. Department of Transportation should selectively sponsor development of interactive courseware with embedded simulations that would facilitate the understanding of information and concepts that are difficult or costly to convey by conventional means. (3/97)
Closed


9-97
NMC
The CG should develop a detailed plan to restructure its marine licensing program to incorporate simulation, including visual simulators, manned models, and training vessels, into the program and to use simulation as a basis of other structured assessments.  In development of the plan, the CG should consult with all parties of interest. (3/97)
Closed


10-97
NMC
Licensing authorities should require that license assessors of simulator-based licensing examinations be professionally competent with respect to relevant nautical expertise, the licensing process, and assessment methods.  Assessors should hold a marine license at least equal to the highest qualification for which the candidate is being tested or should be a recognized expert in a specialized skill being trained.  Specific criteria and standards for assessor qualification should be developed, and procedures should be set in place for certifying and periodically re-certifying assessors who conduct licensing assessment with simulators.  (3/97)
Closed


11-97
NMC
The CG should grant remission of sea time for the third-mate's license for graduates of an accredited, professional development program that includes bridge watchkeeping simulation.  The ratio of simulator time to sea time should be determined on a course-by-course basis and should depend on the quality of the learning experience as it applies to prospective third mates, including the degree to which the learning transfers to actual operations.  Research to establish a more formalized basis for these determinations should be implemented without delay (recommendation 16).  (3/97)

Closed


12-97
NMC
The CG should establish minimum standards for the use of marine simulation as an alternative to sea service for recency requirements for license renewal of deck officers and vessel operators.  Remission of sea time should be granted for renewal purposes to individuals who have successfully completed an accredited and CG approved simulator-based training course designed for this purpose.  The course should be of sufficient length and depth and include rules-of-the-road training, bridge team and bridge resource management, and passage planning.  The ratio of simulator time to sea time should be determined on a course-by-course basis and should depend on the overall learning experience insofar as this learning transfers effectively to actual operations.  (3/97)
Closed


13-97
Deck officers and licensed operators of oceangoing and coastwise vessels who can demonstrate recent shipboard or related experience, but who have not completed an accredited simulator-based training course, should be encouraged to complete an accredited simulator-based bridge resource or bridge team management course before their license renewal.  Those seeking to renew licenses who cannot demonstrate recent shipboard experience should be required to complete such a course before returning to sea service under that license.  (3/97)
Closed


14-97
Chief mates should be required to complete an accredited hands-on shiphandling course prior to their first assignment as masters.  The license should be endorsed to certify that training has been successfully completed.  Either a manned-model or a computer-based, accredited shiphandling simulation course, including visual simulators, manned models, and training vessels, should be established as the norm for this training.  (3/97)
Closed



15-97
Currently serving masters who have not completed an accredited shiphandling simulation course should be required to do so prior to their next license renewal.  In addition, masters should be encouraged to attend an accredited shiphandling simulator-based training course, including visual simulators, manned models, and training vessels periodically thereafter.  (3/97)
Closed


16-97
NMC
The CG should enlist the assistance of standards setting and other interested organizations and sponsor and support a structured process for validating and revalidating simulators, simulations, and assessment procedures.  In developing these standards, all parties of interest should be consulted.  (3/97)
Closed


17-97
NMC
Staff at simulator facilities should have objective knowledge of the capabilities and limitations of the hydrodynamic models on which their simulations are based.  Modifications of the coefficients to address real or perceived deficiencies should only be performed based on competent oversight by a multidisciplinary team.  Procedures should be developed to ensure that no such changes are documented and that notification is given to the original vendors of the data and to the cognizant authorities.  (3/97)
Closed


18-97
NMC
The CG and US Maritime Administration, in consultation with maritime educators, the marine industry, and the piloting profession, should sponsor a cooperative research program to establish a quantifiable basis for measuring the effectiveness of simulator-based training.  (3/97)
Closed


19-97
NMC
The DOT and the maritime industry should assess the impact on training effectiveness of apparent limitations in simulator visual systems.  If these limitations have a negative impact on training effectiveness, DOT should encourage development of visual systems that overcome or minimize the negative aspects of current systems.  (3/97)
Closed


20-97
NMC
The DOT should undertake structured assessments of the need for simulation of vibration, sound, and physical movement.  These assessments should include consideration of the possible differential value of these various sources of information in different types of training scenarios.  (3/97)
Closed


21-97
NMC
Because there are no manned-model training facilities in the US, and because of the usefulness of these models in familiarizing pilots and others with important aspects of shiphandling, DOT should study the feasibility of establishing or re-establishing a manned-model shiphandling training facility in the US, to be operated on a user-fee basis.  (3/97)
Closed


22-97
The American Towing Tank Conference (ATTC) and International Towing Tank Conference (ITTC) should be advised of the need to extend the database of ship maneuvering coefficients.  ATTC and ITTC should be encouraged to investigate possible development of procedures that would allow the exploitation of existing proprietary data without source disclosure.  Where data are not available from these sources, funds should be allocated to perform new tests, especially in very shallow water and in close proximity to channel boundaries or other vessels.  (3/97)
Open



23-97
NMC
The DOT should develop minimum standards for the simulation of ship maneuvering.  The fidelity of the models should be validated through a structured, objective process.  Standard models should be selected and tested in towing tanks and the results compared to selected full-scale real-ship trials of the same ships to provide benchmark data for validation and testing of simulators.  (3/97)
Closed


24-97
NMC
The DOT should initiate research to integrate computational hydrodynamics analysis with simulators in real time.  (3/97)
Closed


25-97
NMC
The CG and US Maritime Administration should assess the options for funding simulator-based training and licensing.  (3/97)
Closed


26-97
NMC
Use marine simulation for inland water operations as a method of determining competence for license, document, or endorsement provided that the simulation training program meets the following guidelines: (a) inland simulation training that leads to an assessment of competence for license, document, or endorsement utilizing simulation should include: (1) approved training curriculum; certified instructors and designated examiners as detailed in NVIC 6-97; certified simulator equipment; and (4) a Quality Standards System that employs an external audit process. (9/97)
Closed


27-97
NMC
Coast Guard should establish a reference source to provide information on marine simulation research and development to avoid duplication of effort.  This should be posted on the Coast Guard home page of the Internet. (9/97)
Closed



28-97
NMC &
MSO-1
At the request of the Coast Guard, the marine simulation working group ranked the 23 recommendations (3/25/97): Within 6 months: #3-97, 4-97, 5-97, 10-97, 11-97 12-97, and 17-97.  Within 12 months: #9-97.  More than 12 months: #6-97, 7-97, 8-97, 13-97, 14-97, 15-97, 16-97, 18-97, 19-97, 20-97, 21-97, 22-97, 23-97, 24-97, and 25-97.  (9/97)
Closed


29-97
NMC
NMC should establish a policy to notify course submitters upon receipt of their submissions. (9/97)
Closed


30-97
NMC
Recommendation 8 of  "Licensing 2000" pg 46 should be implemented.  Rotate more junior officers through RECs, preferably at evaluator/ASIP levels. Minimum length of time in an REC should be one year. (9/97)
Closed



31-97
NMC
NMC should examine potential use of automatic scoring devices such as scantron machines.  Trial tests should be done with this type of machine at academies and an REC to determine their feasibility.(9/97)
Closed


32-97
NMC
Workload analysis needs to be done to determine the impact of the new offshore/inland licensing and documentation requirements on the RECs. (9/97)
Closed


33-97
MERPAC endorses the submission of the proposed guidance on shipboard assessments of competence to the IMO. (9/97)
Closed


1-98
It is recommended that MERPAC endorse the U.S. submission to MSC - (MSC 69/21--Mar 1998).
Closed


2-98
MERPAC believes that the concept and practice of solo watchkeeping during the hours of darkness is inconsistent with IMO's role in improving safety and the protection of life, property, and the marine environment.  The equipment and guidelines offered to support the trials and present practices are inadequate.  In addition, the methodology used was flawed, many issues were addressed incorrectly or not at all.  Improved technology should only be utilized to support a trained and qualified bridge team, rather than replace its members.
Closed


3-98
Task Statement 19
MERPAC supports the new task statement submitted by Bill Eglinton, with the following alteration to Paragraph V--"Tasks:  Develop model performance measures and standards for each area of knowledge and proficiency in Table A giving priority to those proficiencies best assessed on board ship (based on prior review of TRB) using the example provided in the reference material noted as a model format.
Closed


4-98
MERPAC does not recommend the use of a NVIC as the format to promulgate a glossary of STCW terms.  MERPAC recommends that the NMC broadcast these STCW definitions through their publications (i.e. Proceedings, Marine Safety Newsletter, and the USCG web page), with the introduction that these guidelines were developed by MERPAC to assist in the implementation of STCW.  Definitions must be included at such time as the Final Rule is published.
Closed



5-98
MERPAC accepts the NVIC on Refresher Training Courses for license renewal by those lacking sea time.  The committee recommends that as this NVIC is only a guideline, it can be modified for mariners renewing limited licenses.  Note that the hours are listed as a guideline only.   The following footnote was added in the NVIC under Column #4, allocated time: "The time frames in this column are preliminary estimates of the time needed to provide instruction and establish that students have met course objectives.  These times may be adjusted on the basis of course entry requirements, delivery methods, and specific performance standards and measures employed."
Closed


6-98
MERPAC should be introduced to the existence of established standards for educators, the American Society for Quality Control that produced the guideline for the application of International Organization for Standardization guidelines for Education and Training Institutions for guidance of definition and implementation guidance.  American Society for Quality Control, 611 East Wisconsin Ave., Milwaukee, WI  53202.
Closed


7-98
NMC
MERPAC believes that the LRT Report is a bold and worthwhile effort that merits further efforts by the Coast Guard.
Closed


8-98
NMC
Recognizing the current problems faced by the NMC and RECs, MERPAC strongly recommends that the USCG temporarily increase funding and staff to improve the performance until the LRT plan is implemented.
Closed


9-98
NMC
A trial privatization of certain exams should be undertaken to determine costs and limitations of the proposal.  MERPAC has concerns that privatization may result in excessive costs to the mariner and lack of competition.
Closed


10-98
NMC
MERPAC recommends that a determination by legal consul should be made as soon as possible on which of the Coast Guard's MLD functions can be privatized.
Closed


11-98
NMC
MERPAC recommends that prior to implementation of the LRT Plan, the Coast Guard determine how it will measure customer satisfaction.
Closed


12-98
NMC
MERPAC recommends that tasks of the MPS personnel be carefully analyzed to determine if they will be able to perform the proposed workload.
Closed


13-98
NMC
Considering the magnitude of the proposed changes in the LRT report, the Coast Guard should aggressively seek additional public comment.
Closed


14-98
NMC
Recommendations made for changes to update NVIC 5-95:
1.  All references to submitting course to an REC for approval should be changed to read NMC.  NMC will fax receipt of the course to the applicant and will notify the appropriate REC to inspect the facility. (Pg 2)
2.  Schools may not alter a course because of failure of equipment necessary for the presentation or operation of the course.  A school has the responsibility not to hold the course if the required equipment is broken down. (Pg 3 - Operation of the course)
3.  Qualifications of additional or replacement faculty must be submitted to and reviewed by NMC prior to the conduct of the course. (Pg 3, paragraph (B)(2))
4.  Request for approval of site and instructors must be submitted at least 15 days prior to commencement of training.  The training site must be approved by the Coast Guard before the training is conducted.  (Pg 4, paragraph (B)(4)(a)(1), Satellite Training Site)
5.  Change REC to read NMC.  Add the following to Pg 4, paragraph (B)(4)(b), Schools Purchasing Course From Schools That Are Licensed to Offer Previously Approved Courses:  "Course approval will be based on current guidelines."
6.  Add the following sentence to the second paragraph of Pg 5, paragraph (B)(5):  "Course completion certificates will be valid for five calendar years unless otherwise provided.
7.  Add the following to Pg 9, paragraph (D)(2), Renewal: "Course approval will be based on current guidelines.
8.  Make the following change to the last sentence of the answer to Question 5 on Pg 12:  "Course completion certificates issued by the third party trainer are to reflect both the name of the presenter and the name of the originator's organization.
Closed


15-98
NMC
MERPAC endorses the work for STCW Chapter VI: Basic Safety Training.
Closed


16-98
NMC
MERPAC strongly recommends that the Coast Guard accept the STCW Chapter VI model performance measures and standards package.
Closed


17-98
NMC
MERPAC recommends that the Coast Guard verify the validity of the STCW Chapter VI assessment package.
Closed


18-98
NMC
MERPAC recommends that the Coast Guard report the validity test results to MERPAC no later than its next scheduled meeting, and; (a) based upon positive validity test results, MERPAC urges the Coast Guard to accept the STCW Chapter VI: Basic Safety Training model assessment package as a minimum standard for assessing those proficiencies; (b) that the US consider retroactively accepting the assessments conducted using this proposed package, provided no substantive shortcomings are noted in the validity tests; and (c) in order to provide a complete and comprehensive assessment package, the Coast Guard should consider including the language contained in STCW Section A-I/6-6, (Assessment of Competence) in order to provide further guidance to those individuals using this assessment package.
Closed


19-98
NMC
Recommendation made to accept the entire NVIC 5-95 on training record books since all recommendations were approved.
Closed


20-98
NMC
MERPAC endorses the Coast Guard's efforts to combine all marine credentials into one document.
Closed


21-98
NMC
Despite various electronic records of training, each mariner should have his own record of training.
Closed


22-98
NMC
When the position description for Maritime Personnel Specialist is formulated and before it is accepted by the Coast Guard, MERPAC requests that it be made available to them.  
Closed


23-98
NMC
MERPAC recommends that the following text be added to the general paragraph at the top of the STCW certificate:  "This document confirms that the mariner has achieved the required standards of competence set out in Tables A-VI/1-1, A-VI/1-2, A-VI/1-3 and A-VI/1-4 of the STCW 95 code within the previous five years."
Closed


24-98
MERPAC endorses the Coast Guard's efforts to establish specific Part B STCW 95 guidance to the IMO on physical abilities for entry-level seafarers.
Closed


25-98
NMC and MSO-1
MERPAC believes that additional effort will be needed to develop a comprehensive list of shipboard tasks, functions, event or condition and related physical ability standards, and recommends that an immediate working group be established to advise the Coast Guard on entry level physical standards.
Closed


1-99
NMC and MSO-1
MERPAC recommends that the Medical Standards for Seafarers be amended as follows:
(a) These guidelines apply to any mariner assigned duties on the muster list (station bill);
(b) The shipboard task, "making rounds..." be corrected to read, "able to stand a watch for a period of not less than four (4) hours" and the corresponding measurement corrected to read "continuously walk for twenty (20) minutes;"
(c) These standards need to be "completed by a designated examiner at an approved site;" and 
(d) MERPAC recommends that the Coast Guard ascertain that all weights and measures conform to ANSI standards, or other industrial standards.
Closed



2-99
NMC and MSO-1
MERPAC recommends that the following text be inserted as new paragraphs 8 to 10 in section B-VI/1 of the STCW Code:
(a) Paragraph 8: Documented training or assessment relating to any one of the four elements of basic training is considered to remain valid for five years from the date of the most recent assessment, provided the assessments in all four elements have taken place within a twelve month period.  In other words, the five-year cycle for demonstrations of competence under paragraph 2 of Section A-VI/1 of the STCW Code can be measured from the date of the final assessment associated with the four elements of basic training when the assessment activities for all four elements have occurred within one year.
(b) Paragraph 9: A suitably worded document, confirming that the condition described above in paragraph 8 has been met, may be accepted as "evidence" that the holder has achieved the standard of competence for the four areas of basic training for purposes of meeting the requirement of paragraph 2.2 of Section A-VI/1 of the STCW Code; and this form of evidence may be accepted as valid for a period of five years from the date of issuance of the document.
(c) Paragraph 10: In accordance with Regulation I/8, Parties should have a process for monitoring implementation of this provision to ensure that the underlying objectives of section A/VI/1 are achieved.
Closed


3-99
NMC

T.S. 19
Bridge Team Resource Management performance assessment guidelines package
Closed


4-99
NMC

T.S. 19
Designated Duty Engineer / Officer in Charge of Engineering Watch performance assessment guidelines package.  There were six items for which no consensus could be reached:  taking over the watch; performing watch duties; using the log book; handing over the watch; starting a steam boiler; and monitoring a steam boiler.  How will mariners with prior military service demonstrate proficiency or get credit?  Is there a need to distinguish between steam and/or diesel and gas turbine practical experience and demonstration? 
Closed


5-99
NMC

T.S. 19
Advanced firefighting performance assessment guidelines package.  
Closed


6-99
NMC

T.S. 19
Master / Chief mate > 500 gross tons performance assessment guidelines package.  Some guidelines in this group require service on ISM or ISO vessels.  Why, especially when there are not many vessels so designated at the present time?  Why does the performance objective for bridgework procedures require that the applicant pass an approved bridge team management course, yet does not give the option for onboard assessment.
Closed



7-99
NMC

T.S. 19
Officer in charge of a navigation watch performance assessment guidelines package.
Closed


8-99
NMC

T.S. 19
Ratings forming part of an engineering watch performance assessment guidelines package. The performance measures submitted by this subcommittee are very detailed in nature, and it is recommended that the Coast Guard evaluate this detail and possibly remove some of the specificity.
Closed


9-99
NMC

T.S. 19
Ratings forming part of a navigation watch performance assessment guidelines package. The knot tying section calls for a written test, while the STCW Code calls for a practical demonstration.  It is recommended that practical demonstration should also be required.
Closed


01-00
NMC

T.S.
19
Chief Engineer/2[nd] Engineer on vessels > 3000 Kw performance assessment guidelines package.  
Closed


02-00
NMC

T.S.
19
GMDSS operator/restricted operator and Maintainer performance assessment guidelines package.  
Closed


03-00
NMC

T.S.
19
Officer in Charge of Navigation Watch/Master of vessels < 500 gross tons performance assessment guidelines package.
Closed


04-00
NMC

T.S.
19
Tankship/Ro-Ro Vessel performance assessment guidelines package.
Closed


05-00
NMC

T.S.
19
All Survival And Rescue Boat performance assessment guidelines package.  It is recommended that the Coast Guard consider rigid inflatable boats as fast rescue boats.
Closed


06-00
NMC

T.S.19
All medical care/First Aid performance assessment guidelines package.  
Closed


07-00
NMC

T.S. 19
Offshore Vessel Competencies performance assessment guidelines package.
Closed


08-00
T.S.
20
The Coast Guard should not require the use of an actual ship for practical demonstrations to complete the assessment of seafarers satisfying the requirements in Table A-V/2, Sections 1-5.  See the recommendations on the attached Table (enclosure 5).
Closed


09-00
T.S. 20
The Coast Guard should require practical demonstrations to complete the assessment of seafarers satisfying the requirements in Table A-V/2, Sections 1-5.  See the recommendations on the attached Table (enclosure 5).
Closed


10-00


T.S.
20
The Coast Guard should not develop performance measures and standards for practical demonstrations to complete the assessment of seafarers satisfying the requirements in Table A-V/2, Sections 1-5.  Members believe that this responsibility should remain with the training institution.  This will allow greater flexibility in achieving training and assessment objectives.  The NMC still retains oversight and final approval of the training program and assessment criteria.
Closed


11-00


T.S.
20
The sub-committee recommends that in addition to the minimum standards for Qualified Instructors and Designated Examiners contained in NVIC 6-97, all Qualified Instructors and Designated Examiners involved in Table A-V/2 training and assessment should:
(a) have relevant shipboard experience in conducting emergency procedures and drills;
(b) have relevant experience in leadership; stress handling, human behavior                    
     and response as well as effective communications; and
(c) have relevant shipboard experience aboard Ro-Ro passenger or passenger vessels.  The   
     standard for the relevant shipboard experience requirement will consist of observation 
      or participation in a minimum of ten emergency procedures and drill aboard Ro-Ro  
      passenger or passenger vessels.
Closed


12-00

T.S.
21
In response to the CG question, "What size vessel is appropriate to conduct training in accordance with Table A-II/4?"  MERPAC recommends that fifty percent of the training should be conducted on a vessel over 100 gross tons.
Closed


13-00

NMC

T,S,
21
In response to the CG question, "What size vessel is appropriate to conduct the assessments required by Table A-II/4?" MERPAC recommends that if assessments are conducted on vessels of less than 200 gross tons, those vessels must;
(a) permit a candidate to steer by a fixed object and ranges;
(b) have a standard (magnetic) compass and a gyrocompass with 1 degree increments that   
      change readings as the heading changes (digital readout is not acceptable);
(c) have the ability to steer using either magnetic or gyro compass;
(d) have a rudder angle indicator and rudder order indicator;
(e) have realistic replication of the hydrodynamic properties of vessels of at least 200 gross tons throughout the speed and draft changes;
(f) have realistic steering stands that replicate those found on modern merchant vessels 
    and allow switching steering gear from hand to gyro to non-follow up steering and 
    allow switching steering pumps/motors;
(g) have the capability to simulate steering failure including control and actuator systems; (h) have sufficient behavioral realism to allow candidates to exhibit the required  
     competency;
 (i) have the capability to simulate gyrocompass failure;
 (j) have all navigational equipment required on a vessel of greater than 200 gross tons; 
     and
(k) have all steering alarms required on a vessel of greater than 200 gross tons.
Closed


14-00

NMC
T.S.
21
In response to the CG Question, "What equipment, as a minimum, should the vessel have to conduct Table A-II/4 training and assessment?" MERPAC makes the same recommendations as in recommendation 13-00 above.
Closed


15-00

NMC

T.S.
21
In response to the CG question, "What minimum equipment and performance standards must a simulator have to permit assessments of Table A-II/4 practical demonstrations?"  MERPAC recommends that the minimum standards and performance standards should be:
(a) a visual scene which permits a candidate to steer by a fixed object and ranges;
(b) a standard (magnetic) compass and a gyrocompass with 1 degree increments that    
    change readings as the heading changes (digital readout is not acceptable);
(c) the ability to steer using either compass;
(d) a rudder angle indicator and rudder order indicator;
(e) realistic replication of the hydrodynamic properties of vessels of at least 200 gross tons 
    throughout the speed and draft changes;
(f) realistic steering stands that replicate those found on modern merchant vessels and 
    allow switching steering gear from hand to gyro to non-follow up steering and allow 
    switching steering pumps/motors;
(g) the capability to simulate steering failure including control and actuator systems;
(h) sufficient behavioral realism to allow candidates to exhibit the required competency;
(i) the capability to simulate gyrocompass failure;
(j) all navigational equipment required on a vessel of greater than 200 gross tons; and
(k) all steering alarms required on a vessel of greater than 200 gross tons.
          
FOR A LOOKOUT:
(a) a visual scene from dead ahead to 2 points abaft the beam on either side; and
(b) directional speakers or equivalent able to produce sound from a specific direction 
     anywhere from dead ahead to 2 points abaft the beam on either side.
Closed


16-00
NMC

T.S.
21
In response to the CG question, "Do desktop PCs have sufficient physical and behavioral realism to satisfy this requirement?"  MERPAC recommends not at this time due to the required equipment listed in recommendation 15-00 above.
Closed


17-00
NMC

T.S. 22
In response to the CG question, "Which knowledge, understanding and proficiencies require training and education at an approved course?"  MERPAC states that the modules as defined in the model course are sufficient.

The required approved courses for an Officer in Charge of a Navigation Watch should be:  Basic safety training; Bridge resource management; GMDSS; Advanced fire-fighting; Radar; ARPA; and Medical provider.  All other subjects, as defined in the task statement, should be made available either as an approved course, or as modules in an approved training program, such as a company training program or a national training program using a training record book.  Training program modules should be structured so that a mariner can complete all requirements in more than one program.
Closed


18-00
NMC

T.S. 22
In response to the CG question, "Can these courses be taken from any training provider with the relevant approved course?"  MERPAC recommends yes, the courses should not all have to be taken at the same facility, or in consecutive order.

Closed


19-00
NMC

T.S. 22
In response to the CG question, "Is there a minimum tonnage for vessels that is acceptable for the approval of the required sea going service?"  MERPAC responds that the current sea service requirements, as defined in 46 CRF Part 10, should remain in effect.

Closed


20-00
NMC

T.S. 22
In response to the CG question, "Is there a minimum time that the seafarer must serve on vessels equipped with equipment listed in Table A-II/1?"  MERPAC responds  no.  A mariner could train in a classroom on equipment, and not have any time on a vessel with that equipment.

Closed


21-00
NMC

T.S. 22
In response to the CG question, "How should seafarers document that they performed, during the required seagoing service, bridge watchkeeping duties under the supervision of the master or a qualified officer for a period of not less than six months?"  MERPAC responds that the USCG should produce a standard letter of sea service, following the guidelines defined in STCW, for watchkeeping duties.  The letter should be completed by a company representative or the vessel master, and should be included in the training record book.
Closed


22-00
NMC

T.S. 22
In response to the CG question, "Should there be a maximum time period during which all of the requirements must be met?"  MERPAC responds that there should be no restrictions on time.

CG - Request clarification from the committee.

MERPAC - 5 years should not be the maximum.  In order to complete the training, and earn a living at the same time, a more favorable time period should be allowed.  It would be easy for a mariner to be not working or training for a year (family problems, health problems,) or the mariner could run out of money to spend on training, etc. have to take a break from the program and should not be punished for that.  Having said that, MERPAC didn't envision that the mariner would sit around and just not get it done.  Possibly NMC would feel comfortable saying that there is no time limit as long as a mariner was actively sailing. MERPAC would be comfortable with an upper limit, but couldn't come up with one that they would agree on.  

CG - Do not agree that it should be open-ended, a time limit is needed.  USCG would suggest 10 years.  Alternatively, no time limit on training, but assessments should be within 5 years.

MERPAC - A mariner has ten years to complete all training, as long as he or she has one year's sea time in the previous five years.

Closed


23-00
NMC

T.S. 22
In response to the CG question, "If onboard assessment is envisioned, would the qualifications for an onboard assessor be any different than those outlined in NVIC 6-97 for a Designated Examiner?  MERPAC responds that the NVIC needs to be adjusted, removing items that are bulleted, that are needed for course design and implementation, but not for assessment on board.  MERPAC envisions that the assessor is following an already approved training program.  Therefore remove:
  identification of training needs;
  learning processes;
  course design;
  teaching methods;
  presentation techniques;
  role of incentive and motivation in learning;
  use of feedback; and
  course evaluation.
Closed


24-00
NMC

T.S 22
The USCG needs to develop and distribute a standard training record book.  All mariners, using whatever method to obtain training and competence, should have a training record book, consisting of columns listing first the competencies as required by the applicable table, 2nd to list either the training facility at which the training was completed or the approved company training program that the mariner participated in, and a final column providing the assessor's name and signature.  Having obtained this information, the process at the REC would be a matter of verifying the information in the training record book against a list of approved courses and assessors, as provided by the REC.
Closed


25-00
NMC

T.S. 22
To facilitate the advancement of mariners outside of the formal training system, the USCG needs to establish a method to determine equivalency by alternative assessment for the applicable sections of Table A-II/1 and A-II/3.  Using Table II, the USCG may establish other recognized training as equivalent, as evaluated by a qualified review board.

Closed


26-00
NMC

T.S. 22
The USCG needs to assign sea service credit for approved shoreside training programs, in addition to credit for STCW, to facilitate a mariner outside of a traditional training program.
Closed


27-00
NMC

T.S. 23
In response to the CG question, "Which knowledge, understanding and proficiencies require training and education at an approved course?"  MERPAC responds that  BST, Advanced firefighting, First Aid Provider, Emergency Procedures, and Lifeboat Proficiency should remain as listed.  See #17-00, task statement 22
Closed


28-00
NMC

T.S. 23
In response to the CG question, "Can these courses be taken from any training provider with the relevant approved course?"  MERPAC responds that any approved course is acceptable.
Closed


29-00
NMC

T.S. 23
In response to the CG question, "Is there a minimum tonnage and/or horsepower for vessels that would be acceptable for the approval of the required sea going service?" MERPAC responds that minimum tonnage is not required for an engineer's license.  The minimum horsepower should be 750 as per STCW.

Closed


30-00
NMC

T.S. 23
In response to the CG question, "Is there a minimum time that the seafarer must serve on vessels equipped with equipment listed in Table A-III/1?"  MERPAC responds that the six-month sea time is still required.  An additional 30 months is required but any approved training time meeting STCW Knowledge, Understanding, and Proficiencies of Table A/III-1 may count towards the 30 months.

Closed
                                       

31-00
NMC

T.S. 23
In response to the CG question, "How should seafarers document that they performed the engine room operation and watchkeeping duties during the required seagoing service under the supervision of the chief engineer or a qualified officer for a period of not less than one year?"  MERPAC recommends that the USCG start a rulemaking to require Chief Engineer, First Assistant Engineer, or the company to document all service (supervised/unsupervised) and remove the reference to 1 year.
Closed


32-00
NMC

T.S. 23
In response to the CG question, "If onboard assessment is envisioned, would the qualifications for an onboard assessor be any different than those outlined in NVIC 6-97 for a Designated Examiner?"  MERPAC responds yes.  The onboard assessor should be provided with an approved guide and assessment guidance if not a designated examiner.

Closed


01-01
NMC
T.S. 24
In response to the CG question, "At which levels in a mariner's career progression are examinations required to assess the mariner's competence?", MERPAC recommends that the existing four (4) grades of upper level license be continued (Third Mate, Second Mate, Chief Mate, and Master).  Two written examinations would be administered, one for the operational level (3rd & 2nd Mate), and one for the management level (Chief Mate and Master).  At the Master level courses in management and leadership, as well as ship handling, would be required.  
Closed


02-01
NMC
T.S. 24
In response to the CG question, "If the United States adopts testing at the operational level and management level, are there unique qualifications for either a second mate's license or for a master's license that would require additional limited testing and/or practical assessments?  If so, what areas should be tested/assessed, and what is the scope of the tests/assessments in those areas?," MERPAC recommends that fifty percent of the required one year sea service must be in grade at the next lower level of license.  Sea service recency for upgrade should be 90 days within the past five years.
Closed


03-01
NMC
T.S. 24
The Committee strongly believes that a job task analysis (JTA) should be conducted to determine the specific skills required at the operational and management level.  With regard to modular structure file for master/chief mate oceans, the W/G recommend that the Coast Guard use the latitude provided by section A/II-2, paragraph 5, to make the level of theoretical knowledge, understanding, and proficiency appropriate to vessels of less than 1600 gross tons or 3000 gross tons.  The purpose for this is to establish a difference in the degree of difficulty between ocean master and 1600 gross ton master as it is in our system.  
Closed
                                       

04-01
NMC
T.S. 24
The working group was instructed to "vet" and make recommendations on the exam module structures provided by the Coast Guard.  MERPAC did so and they are extensive.  These recommendations were forwarded to NMC.
Closed


05-01
NMC
T.S. 24
The Coast Guard should develop a structure of deck licenses that shows the past and exchange points of the various levels of license in compliance with U.S. Code and STCW. 
Closed


06-01
NMC
T.S. 25
In response to the CG question, "At which levels in a mariner's career progression are examinations required to assess the mariner's competence?",  MERPAC recommends that the US mariner's career progression should attempt to conform to the STCW structure as much as possible without sacrificing the current US system.  The 4 levels of U.S. licenses should be retained, but competency requirements should emphasize the difference between Operational and Management levels.  Current 3rd A/E and 2nd A/E licenses should remain in place, with the initial course work and testing for a 3rd A/E license aimed at the 2nd A/E level of knowledge.  Once a person has obtained a 3rd A/E license, with one year's sea time, they should be able to upgrade to 2nd A/E with an additional exam. The subjects of this exam are spelled out in question #3.  The step from 2nd A/E to 1st A/E is a major one, which entails going from the operational level to the management level.  Several courses will be required for this step (see MERPAC recommendations of Dec. 1999).  In addition to the required courses, USCG exams should still be given at the 3rd A/E and 1st A/E levels.  The one-year sea service for this step should include at least 6 months at the 2nd A/E level.  The last step, from 1st A/E to Chief Engineer, should be obtained with one year's sea time, 6 months of which should be in the 1[st] A/E position, and one additional Leadership and Management course.
Closed


07-01
NMC

T.S. 25
In response to the CG question, "For each level where it is determined that a mariner should be tested, what should be the scope and depth of the examinations?, MERPAC recommends that there should still be exams, but the focus should be on the theoretical, rather than the practical.  MERPAC assumed that for the initial license (3rd A/E) a training record book was used and that the practical demonstrations recommended by MERPAC in Task Statement #19 will be in place The working group went over the specific exam subjects and made recommendations for each one.  This list has been forwarded to NMC.
Closed


08-01
NMC

T.S. 25
In response to the CG question, "If the U.S. adopts testing limited to the operational level and management level, are there unique qualifications for either a 2nd A/E license or for a Chief Engineer's license that would require additional testing?  If so, what areas should be tested, and what should be the scope of the tests in those areas?", MERPAC recommends that at the 2nd A/E level there should be assessment on the following subjects:
Water testing: practical demonstration and written exam (steam and motor);
Fuel oil combustion and control principles: written exam  (steam and motor);
Fuel oil management: written exam  (steam and motor);
Combustion control systems: written exam (steam only); and
Troubleshooting auxiliary and waste heat boilers: written exam (motor only).
At the Chief Engineer level there should be an additional Leadership and Management course that addresses current regulations and personnel management issues.  These subjects are spelled out in detail in the MERPAC recommendation submitted in Dec. 1999.
Closed


09-01
NMC

T.S. 25
In response to the CG question, "What are the relationships, if any, between the testing at one level as compared to the testing at another license level?  Once tested, are there any portions of the test that should be repeated?  For example, should questions relative to watchstanding at the operational level be included on examinations at the management level?", MERPAC recommends that generally, the testing at the management level should focus more on regulatory, troubleshooting, and maintenance issues.  There will be some redundancy, which is spelled out in the list of specific exam subjects.
Closed 


10-01
NMC

T.S. 26


In response to the CG question, "At which levels in a mariner's career progression are examinations required to assess the mariner's competence?",  MERPAC recommends that the US mariner's career progression should attempt to conform to the STCW structure as much as possible without sacrificing the current US system.  The current sea service requirements should stay the same, with the progression being as follows:  Limited Assistant Engineer, Limited Chief Engineer (near coastal)/Second Engineer (STCW) Oceans, Limited Chief Engineer (Oceans).  There should be an initial exam to obtain the limited assistant engineer license, and another exam to obtain the Limited Chief Engineer (near coastal) license.  Sea service would be the only requirement to obtain the Limited C/E ocean license.
Closed


11-01
NMC

T.S. 26
In response to the CG question, "For each level where it is determined that a mariner should be tested, what should be the scope and depth of the examinations?," MERPAC  went over the specific exam subjects and made recommendations for each one.  This list closely parallels the testing subjects for unlimited licenses, with some subjects eliminated due to the nature of lower horsepower vessels.  The list has been forwarded to NMC.
Closed


12-01
NMC

T.S. 26

In response to the CG question, "If the U.S. adopts testing limited to the operational level and management level, are there unique qualifications for either a 2nd A/E license or for a Chief Engineer's license that would require additional testing?  If so, what areas should be tested, and what should be the scope of the tests in those areas?, " MERPAC reported that this question does not apply with the recommended licensing scheme.
Closed


13-01
NMC

T.S. 26
In response to the CG question, "What are the relationships, if any, between the testing at one level as compared to the testing at another license level?  Once tested, are there any portions of the test that should be repeated?  For example, should questions relative to watchstanding at the operational level be included on examinations at the management level?," MERPAC recommended that generally, the testing at the management level should focus more on regulatory, troubleshooting, and maintenance issues.  There will be some redundancy, which is spelled out in the list of specific exam subjects.
Closed


14-01
NMC

In the interest of reducing ship-strike mortalities, all approved courses for original license or raise-in-grade as well as the social responsibility element of the Basic Safety Training Course should include instruction and assessment in the following subjects:

   1. legal statutes pertaining to endangered species;
   2. mariner awareness of endangered species habitats, migratory patterns, and behaviors;
   3. watchkeeping procedures including crew vigilance, surveillance techniques, and collision avoidance maneuvers;
   4. mandatory Reporting System;
   5. voyage planning and awareness of endangered species incidental to the vessels route; and
       6.           bridge procedures or protocols consistent with the provisions of  
                     the International Safety Management Code (ISM).
Open
                                       

15-01
NMC

TS 33
All USCG approved schools should be required to submit the names and any other pertinent information of all prospective students to the USCG.  The USCG will inform the school as soon as possible as to the status of each student's ability to attend that course.
Closed
                                       

16-01
NMC

TS 33
For both original documents and/or licenses as well as renewals, much more stringent background checks (both national and international databases) should be completed.  In order to facilitate this for both the mariner and the USCG, a one-time allowance for the synchronization of the renewal dates for a person's MMD and license should be authorized.  Mail in renewals should be replaced by "drop off" renewals.  This would entail the use of all USCG offices, passport centers, passport windows at US post offices, and other appropriate Federal locations (enough so as not to place a burden on the mariner) where once the person's identification has been verified, the application would be in the custody of the Federal government and forwarded to the appropriate REC for processing, then returned to the mariner by mail.
Closed
                                       

17-01
NMC

TS 33
The USCG should institute a security awareness campaign involving HSC's, unions, schools, industry, and professional organizations/associations, etc. and a central call in number to report security concerns or incidents (oil spill number).  We also believe security courses for shipboard and shore side workers should be encouraged.
Closed


18-01
NMC

TS 33
The MMD, license, and STCW certificate should be redesigned to make the copying and forgery of these documents more difficult.  We also recommend the use of smart card technology be integrated into these documents in order to ascertain a more positive ID.
Closed


19-01
NMC

TS 33
For investigative purposes, logbooks, crew manifests, and cargo manifests should be required and maintained on board all vessels.
Closed
                                       

20-01
NMC

TS 33
Passenger manifests should be maintained for all vessels if feasible (ferries?).  Possibility- the INS could issue smart ID cards to all at entry points
Closed
                                       

21-01
NMC

TS 33
The issuance of temporary MMD's should be terminated.  The USCG would then need to direct extra assets to reduce the backlog at the affected REC's.
Closed


22-01
NMC

TS 33
The USCG should submit to the IMO a requirement for minimum security background checks for all mariners and the internationally recognized documentation of such.
Closed


01-02
T/S 30
Naval or U.S.C.G. personnel or ex-Naval or ex-U.S.C.G. personnel who have completed PQS for Helmsman (Watch Station 305) and PQS for Lookout (Watch Station 302) and show documentation either on a Navy "Page 4" or other appropriate official Naval or U.S.C.G. documentation should be deemed to have met the STCW standard for a Rating Forming Part of a Navigational Watch. 
Closed
                                       

02-02
T/S 30
Navy personnel or ex-naval personnel who have completed Basic Training and show documentation either on a Navy "page 4" or other appropriate official Naval documentation should be deemed to have met the STCW standard for BST except for donning and jumping in the water with an immersion suit.  If the applicant shows that he/she has completed immersion suit training from a certified training institution, such certification in conjunction with the documentation of Navy Basic Training should be accepted as equivalent to STCW for BST.
Closed
                                       

03-02
T.S. 31
The U.S.C.G. should continue to develop safe manning requirements based on function, operation, and job analysis rather than tonnage, i.e., vessels of similar size engaged in different service may be manned at different levels.
Closed
                                       

04-02
T.S. 31
Safe manning requirements should apply to all commercial domestic vessels, both inspected and uninspected.
Closed
                                       

05-02
T.S. 31
The U.S.C.G. should consider flexible safe manning minimums for an individual vessel based on the function the vessel is performing.
Closed
                                       

06-02
T.S. 31
The U.S.C.G. should involve industry experts in developing specific crew size models for various segments of the maritime industry.  These experts should be comprised of mariners, vessel owner/operators, and members from other advisory committees as appropriate.  
Closed
                                       

07-02
T.S. 32
The current levels of Radar Observer should be continued.
Closed
                                       

08-02
T.S. 32
The current curriculum course hours for the various grades of Radar endorsements are adequate to develop the skills necessary to be both certified and qualified provided that the prerequisite knowledge of Rules of the Road and rudimentary navigation already exist.
Closed
                                       

09-02
T.S. 32
The current curriculum course hours for ARPA endorsements are adequate to develop the skills necessary to be both certified and qualified provided that the prerequisite knowledge of radar, Rules of the Road, and rudimentary navigation already exist.
Closed
                                       

10-02
T.S. 32
Approved Radar/ARPA training and assessment should be conducted on actual or mock-up Radar/ARPA equipment to ensure the validity of functional skills.
Closed
                                       

11-02
T.S. 32
PC-based software training systems may be utilized as viable supplemental training aids for Radar/ARPA training when they meet IMO standards for such training devices.
Closed
                                       

12-02
T.S. 32
Paper plots are feasible alternatives to reflection plotting.  Paper plots can be utilized to effectively assess the radar observer's skills in vector analysis and collision avoidance.
Open
                                       

13-02
T.S. 32
MERPAC encourages the U.S. Coast Guard to require reflection-plotting capabilities for all approved Radar/ARPA equipment.
Open
                                       

14-02
T.S. 32
Radar skill assessments should include transfer-plotting demonstrations when required by the course approval for that level radar endorsement.
Open
                                       

15-02
T.S. 32
Radar training and assessment should include navigation exercises in addition to collision avoidance techniques for all levels of radar endorsement.
Open
                                       

16-02
T.S. 32
The STCW Certificate renewal should include ARPA skill demonstrations on ARPA endorsed certificates.  ARPA assessments should be limited to a demonstration of the use of required ARPA functions only.
Open
                                       

17-02
T.S. 32
No minimum hours should be prescribed for radar and/or ARPA renewal exercises.  It is the assessor's responsibility to determine the competence level of the candidate, and to spend as much time as necessary to meet the approved standard.
Open
                                       

18-02
T.S. 34
The Coast Guard should accept the two tables, entitled KUPs required of shipboard personnel and KUPs required of the ship security officer, as written for their use in developing shipboard security training for SSOs and crew.  
Closed
                                       

19-02
T.S. 37 
The temporary suspension of paragraph 3(d) of Policy Letter 09-01, dated 26 April 2001, should be rescinded.  
Closed
                                       

20-02
T.S. 35
Applicants for licenses authorizing service on ocean-going and near-coastal vessels of more than 1,600 gross registered tons should be required to pass a practical signaling examination in accordance with 11.309  


Closed
                                       

21-02
T.S. 35
The Coast Guard should ensure that the test of the International Code of Signals (HO 102) requires at least 1, 2, and 3 letter groups including a medical signal code.  
Closed
                                       

22-02
No T.S.
The Coast Guard should re-submit its STW29-9/2 paper to STW34 in light of the proposed collateral duties as ship's security officer and other duties and new responsibilities.
Closed
                                       

01-03
MSO-1

T.S. 45
Radar endorsements
MERPAC recommends that 46 CFR Part 10 and Part 15 be revised to allow the mariner to possess a currently valid Radar Training Certificate in lieu of an endorsement to his license.
Closed
                                       

02-03
NMC

T.S. 41
Mariner written exam administration
MERPAC believes that the proposed change in examination administration will not adversely affect merchant mariners
Closed
                                       

03-03
NMC

T.S. 41
Mariner written exam administration
During a transition period, test candidates should be afforded the option for computer or written test format
Closed
                                       

04-03
NMC

T.S. 41
Mariner written exam administration
After the successful assessment and evaluation period, the option for a written test format should not be available.
Closed
                                       

01-04

T.S. 38
Improve-ments to STCW Certifi-
cates
The National Maritime Center staff has drafted a new STCW certificate that meets the STCW guidelines.  MERPAC approves of this certificate.  It is understood that the Coast Guard will phase out recording the applicant's social security number on the new certificates.
Closed
                                       

02-04

T.S. 37
Credit for sea service on vessels with no, or limited, underway time
If a vessel's manning document and/or the Coast Guard requires that an individual hold a certain license or certificate to actually serve in a specific billet, then all of that service should be considered to be acceptable service for service evaluation purposes.  Concern for underway time should not be an issue.
Closed
                                       

03-04

T.S. 37
Credit for sea service on vessels with no, or limited, underway time
If there are types of vessels and/or operators that are so unique as to require unique training and/or evaluation criteria, then such criteria should be jointly developed by the Coast Guard and the operators concerned with the relevant unique or non-traditional operations.
Closed
                                       

04-04

T.S. 37
Credit for sea service on vessels with no, or limited, underway time
MERPAC's recommendations are based on the historical interpretation of a mariner's service as time employed in a specific capacity aboard a vessel as well as the general spirit of the STCW Convention.

Closed
                                       

05-04

T.S. 42
Recomm-endations on actual demon-
strations of skill for masters and chief mates on ships of between 500 and 3,000 gross tonnage (ITC) on interna-
tional and near-coastal voyages
It has been noted that the draft NVIC to which the assessments  are appended has an apparent oversight that should be reviewed.  Paragraph 11(a) of enclosure (1) to the NVIC describes the requirements for a person licensed under the old system to increase in scope from 500 gross tons to 1,600 gross tons, stating that the applicant must meet the service requirements, complete the practical assessments, and pass an exam.  A similar provision to increase the scope from mate 500 gross tons to mate 1,600 gross tons was changed in Policy Letter 01-02 to require service only.  We believe this Policy Letter should be consistent with the Policy Letter for Officer in Charge of a Navigation Watch (Mate) in this regard.
Closed
                                       

06-04

T.S. 42
Recomm-endations on actual demon-
strations of skill for masters and chief mates on ships of -between 500 and 3,000 gross tonnage (ITC) on interna-
tional and near-coastal voyages
MERPAC recommends that the attached Table (NOTE: the Table attached with the Task Statement) be accepted as written for master 500-1,600 gross tons oceans.  For master 500-1,600 gross tons coastwise, we recommend that the same Table be accepted, with the understanding that the proficiencies for celestial navigation do not apply.

Closed
                                       

07-04

T.S. 36
Recom-
menda-
tions on a training program
for 
officers in charge
of an en-gineering
watch 
coming up 
through
the hawse-
pipe
In response to the question, "Does the knowledge, understanding and skill encompassed by the proposed training and education at an approved course satisfy the requirements for OICEW?", MERPAC says that if we follow a its recommended training program covering all of the subjects, the requirements would be satisfied.
Closed
                                       

08-04

T.S. 36
Recom-
menda-
tions on a training program
for 
officers in charge
of an en-gineering
watch 
coming up 
through
the hawse-
pipe
MERPAC recommends that the additional subjects required by STCW (thermodynamics, physics, marine chemistry, material science, ship construction and stability, and mathematics) at the management level should be covered as a single course at the beginning of the training program.
Closed
                                       

09-04

T.S. 36
Recom-
menda-
tions on a training program
for 
officers in charge
of an en-gineering
watch 
coming up 
through
the hawse-
pipe
MERPAC recommends that a person be allowed to prove that they have acquired the knowledge contained in the course by undergoing an effective screening process.  This may be accomplished by taking the final exam including labs for the course as well as performing any assessments that may be required.

Closed
                                       

10-04

T.S. 36
Recom-
menda-
tions on a training program
for 
officers in charge
of an en-gineering
watch 
coming up 
through
the hawse-
pipe
MERPAC recommends that the Coast Guard publish a NVIC to inform the maritime community of the date on which this new training will go into effect.  MERPAC recommends that there be a two-year period from the time the NVIC is published until the implementation of the new OICEW training program.  
Closed
                                       

11-04

T.S. 36
Recom-
menda-
tions on a training program
for 
officers in charge
of an en-gineering
watch 
coming up 
through
the hawse-
pipe
In response to the question, "Can these courses be taken from any training provider with the relevant approved course?" MERPAC responds yes.  
Closed
                                       

12-04

T.S. 36
Recom-
menda-
tions on a training program
for 
officers in charge
of an en-gineering
watch 
coming up 
through
the hawse-
pipe
In response to the question, "Should a minimum tonnage and/or horsepower for vessels be acceptable for the approval of the required sea going service and training?" MERPAC responds that the Coast Guard should stick with the traditional horsepower and tonnage requirements for these courses, 1600 GRT and 4,000 horsepower.  
Closed
                                       

13-04

T.S. 36
Recom-
menda-
tions on a training program
for 
officers in charge
of an en-gineering
watch 
coming up 
through
the hawse-
pipe
In response to the question, "Should there be a maximum time period during which all of the requirements must be met?" MERPAC responds that there should be no maximum time period.  While it is anticipated that many mariners will advance through the program in the quickest time available to them, some may take longer due to financial or other reasons.  
Closed
                                       

14-04

T.S. 40
Qualifi-cations in
Basic Safety
Training
(BST)
The renewal date of the STCW BST certification should be concurrent with the renewal date of the license and/or mariner's document
Closed
                                       

15-04

T.S. 40
Qualifi-cations in
Basic Safety
Training
(BST)
The U.S. should not require a five-year renewal period in any form.
Closed
                                       

16-04

T.S. 40
Qualifi-cations in
Basic Safety
Training
(BST)
This is a time sensitive issue that requires the immediate attention of the Coast Guard.  If the Coast Guard insists upon a refresher course and update of training or assessment, MERPAC stands ready to assist in the development of training models.
Closed
                                       

17-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "What are the minimum requirements that a candidate must meet (i.e. age, education, training, sea time, etc), if any?" MERPAC recommends that a candidate should fulfill the requirements laid out in CFR's: (46CFR12.05-3): Certification of Seamen - Able Seamen.  
Closed
                                       

18-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "What are the competencies for certification?" MERPAC refers to the Able Seaman Proficiency Tables attached as enclosure (3) to the minutes from this meeting.
Closed
                                       

19-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "What are the knowledge, understanding, and proficiencies (KUP's) which meet the competencies?" MERPAC refers to the Able Seaman Proficiency Tables attached as enclosure (3) to the minutes from this meeting.  
Closed
                                       

20-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "What, if any, KUP's require training and education at an approved course?" MERPAC refers to the Able Seaman Proficiency Tables attached as enclosure (3) to the minutes from this meeting.  However, in no case should a person be required to perform both classroom training and onboard demonstration for the same knowledge, understanding or proficiency. The committee wishes to stress that in most situations assessments can be completed through either demonstration of proficiency or approved training.
Closed
                                       

21-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "Can these courses be taken from any training provider with the relevant approved course?" MERPAC responds that yes, this is what it wishes to see.  
Closed
                                       

22-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "How should seafarers document the practical assessments they performed?" MERPAC responds that this should be recorded in an approved record of training or approved assessment sheet.  
Closed
                                       

23-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "Should there be a minimum time period during which all of the requirements must be met?" MERPAC responds that in line with the U.S. Code and STCW Convention, it recommends five (5) years.
Closed
                                       

24-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
With regard to the question, "If onboard assessment is envisioned, would the qualifications for an onboard assessor be any different than those outlined in NVIC 6-97 for a Designated Examiner?" MERPAC responds that no, it believes that the assessor has sufficient experience and training to do the assessment consistent with NVIC 6-97.
Closed
                                       

25-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
The proficiencies that are required of an Able Bodied Seaman should be evaluated through processes of demonstration.
Closed
                                       

26-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
Classroom training should be required only when necessary because methods of demonstration are not possible, or may endanger the safe operation of the vessel (e.g.: fire fighting).
Closed
                                       

27-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
In no case should a person be required to perform both classroom training and onboard demonstration for the same knowledge, understanding, or proficiency.
Closed
                                       

28-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
Changes in technology have outstripped current assessment standards in the U.S. coastal trade for life rafts.  Therefore, the committee encourages the Coast Guard to establish assessment standards for life rafts.
Closed
                                       

29-04

T.S. 43
Recom-menda-
tions on a training
and ass-
essment program for able-
bodied
seamen on sea-
going
vessels
Regarding the scope of the present U.S. Coast Guard written test for Able Bodied Seaman, the committee feels that it is sufficient as it is presently presented to evaluate those areas of knowledge, understanding, and skill that should be evaluated in a written or testing format.

Closed
                                       

30-04

T.S. 44
Security
training
and cert-
ification
for vessel
person-
nel  - 
vessel
security
officer &
other vessel
personnel

The Tables entitled Knowledge, understanding, and proficiencies required of shipboard personnel having specific security duties are MERPAC's recommendations.
Closed
                                       

31-04

T.S. 44
Security
training
and cert-
ification
for vessel
person-
nel  - 
vessel
security
officer &
other vessel
personnel

The Tables entitled Knowledge, understanding, and proficiencies required of all other shipboard personnel are MERPAC's recommendations.  
Closed
                                       

32-04

T.S. 44
Security
training
and cert-
ification
for vessel
person-
nel  - 
vessel
security
officer &
other vessel
personnel

MERPAC reiterates our recommendation 22-02 and as far as recommendation 3-02, the crew's security duties need to be considered when conducting a job task analysis into the traditional duties.  
Closed
                                       

33-04

T.S. 46
Review of draft
NVIC
concern-
ing the
medical
standards
appli-
cable to
merchant
mariners
It is the committee's position that the REC's need to be given authority to use their discretion to apply local waiver processes on all potentially disqualifying medical conditions listed in enclosure (3) Part 1 of the draft NVIC and rely on submission to the NMC only for those conditions that are not defined for additional guidance or require review by the U.S. Coast Guard physicians.  Mariners should feel comfortable that medications that do not have side effects that may adversely affect the mariner's ability to perform their duties will not be an automatic disqualifier.
Open
                                       

34-04

T.S. 46
Review of draft
NVIC
concern-
ing the
medical
standards
appli-
cable to
merchant
mariners
In the draft NVIC, waiver for monocular vision is only addressed for original issue license and should be revised to include granting this waiver for all renewals and raises in grade for all levels of license.  Conflicts within enclosure (3) part II paragraph (a), (c), and (d) of the draft NVIC need to be resolved and technological advances in vision correction need to be recognized before stating that monocular vision is automatically grounds for denial.
Closed
                                       

35-04

T.S. 46
Review of draft
NVIC
concern-
ing the
medical
standards
appli-
cable to
merchant
mariners
Page 3 of enclosure (3) paragraph (9) of the draft NVIC needs to have the words "medical review board" removed and the words "the issuing officer shall with due regard to any medication listed below" inserted.
Closed
                                       

36-04

T.S. 46
Review of draft
NVIC
concern-
ing the
medical
standards
appli-
cable to
merchant
mariners
MERPAC would like the Coast Guard to consider the following -- MERPAC would like to see the physical form modified to ensure that the examining physician sees each page of the form including the instructions to the physician by initialing each page of the form.
Closed
                                       

37-04

T.S. 46
Review of draft
NVIC
concern-
ing the
medical
standards
appli-
cable to
merchant
mariners
MERPAC strongly supports the continuation of the requirement for licensed doctors of medicine, physicians assistant, or nurse practitioner to complete and sign the medical form for the mariner.

Closed
                                       

01-05
T.S. 48
Recommendations to develop training and service requirements for personnel with limited engineer licenses to obtain STCW OICEW and unlimited third assistant engineer licenses
In answer to the question asked by the Coast Guard, "Should an engineer with a limited license be able to eventually obtain an unlimited engineer's license and OICEW endorsement?  If yes, provide guidance on how this could be accomplished," MERPAC responds that, yes, they should be able to accomplish this.  
Closed
                                       

02-05

T.S. 48
Recommendations to develop training and service requirements for personnel with limited engineer licenses to obtain STCW OICEW and unlimited third assistant engineer licenses
In answer to the question asked by the Coast Guard, "Should a person with previous experience in any of the 10 QMED ratings be required to take the course for that rating as part of the OICEW program?," MERPAC responds, No, but there should be a time during which this exemption is allowed.  MERPAC feels that 5 years is a reasonable amount of time within which the mariner must commence his/her pursuit of an OICEW endorsement.  There needs to be a safeguard to prevent people from taking advantage of this potential loophole.  The intent is for experienced mariners who have worked in a particular QMED rating to get credit for that experience and not have to take a course for something they have been doing for a long time.  They would still be required to do the sea projects in order to meet the STCW requirements for "approved sea service."
Closed
                                       

03-05

T.S. 48
Recommendations to develop training and service requirements for personnel with limited engineer licenses to obtain STCW OICEW and unlimited third assistant engineer licenses
In answer to the question asked by the Coast Guard, "Should a person with previous training in a particular subject (i.e. welding, machine shop, electricity, HVAC, etc) be able to get a USCG approval for that training as it applies to the OICEW training program?," MERPAC responds, yes, if they have a recognized industry certificate, they should be evaluated on a case-by-case basis and given credit for the training that applies.
Closed
                                       

04-05

T.S. 48
Recommendations to develop training and service requirements for personnel with limited engineer licenses to obtain STCW OICEW and unlimited third assistant engineer licenses
In answer to the question asked by the Coast Guard, "Should a person be allowed to receive credit for training required for any of the ratings identified in the hawsepiper to OICEW/unlimited 3[rd] assistant engineer program, such as by completing the final exam and successfully demonstrating any required lab test and/or assessments?," MERPAC responds, yes, MERPAC feels strongly that a person should be able to get credit for a course if they take the exams and pass any practical tests included in the course.  They would still need to complete the sea projects.

Closed
                                       

05-05

No Task Statement
With regard to the briefing by the Pacific Coast Maritime Consortium seeking funding for a hawsepipe educational loan project, MERPAC recommended that:

Since the new STCW training requirements for hawsepipers are causing a significant reduction in the number of people who are choosing to advance from unlicensed to the rank of Licensed Officer; and since there is concern that there may actually be a shortage of Licensed Officers if this trend continues; and since an informal survey last year showed that most unlicensed mariners are willing and even eager to get training, but cost prevented them from doing so;

Therefore, MERPAC endorses the concept of Federal funding for mariners to pay for the cost of attending USCG approved training. 

Closed
                                       

06-05

T.S. 47
Recommendations on knowledge and practical qualifications for engineers at the operational and management levels to serve on steam propelled vessels
In answer to the question asked by the Coast Guard, "To what extent should training be used in the process:

a. to recertify an engineer who does not have recent sea service; 
         
b. for an engineer licensed in an alternative propulsion mode to obtain a steam license   
 at the same and/or lesser level; and 

c. to qualify a steam engineer to obtain an upgrade to his/her existing license?,"

MERPAC recommends that training is suggested as the best method and utilized to the fullest extent, provided the facility offers a USCG approved course including classroom and simulator training as well as field trips to modern steamships.

Closed
                                       

07-05

T.S. 47
Recommendations on knowledge and practical qualifications for engineers at the operational and management levels to serve on steam propelled vessels
In answer to the question asked by the Coast Guard, "To what extent can service and experience in other power generation and/or transportation industries be used to qualify for an original, renewal, upgrade, or cross-over steam license?," MERPAC recommends:

Stationary Power Generation Plant
       For upgrade and crossover only / 20% of overall time required
       Minimum 500 PSI plant
       Plant shall include a steam driven prime mover
     
Other Transportation Industries

     NAVY, USCG and other branches of the military services, providing the training & operational service is generalized enough to cover typical merchant marine training and operation

Rail industry should not be an equivalent for steam experience

No time equivalents for non-seafarers


Closed
                                       

08-05

T.S. 47
Recommendations on knowledge and practical qualifications for engineers at the operational and management levels to serve on steam propelled vessels
In answer to the question asked by the Coast Guard, "Should the Coast Guard continue to require the amount of sea service described in 46 CFR 11.502(b), or accept less sea service if the focus to qualify an engineer for cross-over service is obtained as approved sea going service, which would include being assessed in the performance of identified practical demonstrations?," MERPAC recommends that the Coast Guard continue as described in 46 CFR.11.502 (b).

Closed
                                       

09-05
Re-Opening
of 
T.S. 19,
Practical Assess-ments for OICEW, RFPEW, & Manage-ment Level Certifica-tion
MERPAC recommends that the changes indicated in enclosures (2), (3), and (4) to the minutes of meeting 24 serve as its recommendations to the Coast Guard.  These recommendations may be viewed at MERPAC's website located at
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 24 Minutes"
Closed
                                       

10-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regard to the question, "What are the minimum requirements that a candidate must meet (i.e. age, education, training, sea time, etc), if any?", MERPAC recommends that: (a)  a candidate should be not less than 18 years of age; (b) they must have approved seagoing service of not less than 9 months (from entry level as defined by the administration); and (c) they must meet the requirements for certification as an RFPEW (Grade 2).
Closed
                                       

11-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regard to the question, "What are the competencies for certification?", see the tables attached as enclosure (5), which may be viewed at:
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 24 Minutes"
Closed
                                       

12-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regard to the question, "What are the knowledge, understanding, and proficiencies (KUPs) which meet the competencies?", see the tables attached as enclosure (5) , which may be viewed at:
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 24 Minutes".
Closed
                                       

13-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regard to the question, "What, if any, KUPs require training and education at an approved course?", MERPAC recommends that there be none.


Closed
                                       

14-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regard to the question, "Can these courses be taken from any training provider with the relevant approved course?", MERPAC recommends that Yes, this is what MERPAC wishes to see.


Closed
                                       

15-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regard to the question, "How should seafarers document the practical assessments they performed?", MERPAC recommends recording this in an approved record of training or approved assessment sheet.
Closed
                                       

16-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regard to the question, "Should there be a minimum time period during which all of the requirements must be met?", MERPAC recommends no time limit for meeting the requirements.
Closed
                                       

17-05
T.S.
50
Recom-
menda-tions for
QMED
program
on Sea-
going
vessels
With regards to the question, "If onboard assessment is envisioned, would the qualifications for an onboard assessor be any different than those outlined in NVIC 6-97 for a Designated Examiner?", MERPAC recommends that yes, the assessor should be required to meet the relevant requirements of  STCW section A-I/6.
Closed
                                       

N/A
The Merchant Marine Personnel Advisory Committee (MERPAC) supports the Coast Guard's intention to submit a legislative change proposal to Congress to eliminate 46 USC § 8905(b), which currently exempts towing vessels engaged in the offshore mineral and oil industry from being required to have a licensed operator.  This exemption, which was originally codified as 46 USC § 405(b)(3) in 1972, has outlived its intended purpose and now poses a potential threat to navigational safety and maritime security.  MERPAC further supports the Coast Guard's revision of 46 CFR § 15.610(a) to eliminate this same exemption from the manning regulations.
      
MERPAC encourages the Coast Guard to reduce the human impact. For instance, implementing an outreach campaign and establishing avenues by which affected mariners can access information and the means to obtain the necessary documentation."

Closed
                                       

01-06
T.S. 53
Medical Certifica-tion Standards and Disquali-fying Medical Condi-
tions for Merchant Mariners
MERPAC voted to accept the work group's recommendations which may be viewed at 
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 25 Minutes".
Open
                                       

02-06
T.S, 49
Recom-menda-tions for Use of a Model Sea Course Project in Conjunc-tion with an Approved Program for Officer in Charge of an Enginee-ring Watch Coming Up Through the Hawse-pipe
MERPAC voted to accept the work group's recommendations which may be viewed at 
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 25 Minutes".
Open
                                       

03-06
T/S 30
Utilizing Military Sea Service for STCW Certifica-tions

MERPAC voted to accept the work group's recommendations which may be viewed at 
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 25 Minutes".
Open
                                       

04-06
T.S. 52
Recom-menda-tions on the Coast Guard's Draft Proposals on Issues that will be Affected by the Revisions to the 1997 Interim Rule Imple-menting the 1997 STCW Conven-tion
MERPAC voted to accept the work group's recommendations which may be viewed at 
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 25 Minutes"
Closed
                                       

05-06
T/S 30, "Utilizing Military Sea Service for STCW Certifications"

The Coast Guard should forward to the Navy the recommendation that a billet be established that would act as the USCG/NMC Navy Training Liaison, who could work to continue to develop the processes for naval personnel to have a professional development path, and to assist the personnel strength of the Merchant Marine. The primary task of this person would be coordinate between naval training, and the rating and licensing requirements of the merchant mariner.

this recommendation should be sent to Commander, Naval Personnel Development Command, Norfolk, VA.
Closed
                                       

06-06
TS 57, "Recommendations on a Seamless National Program of Training and Education for Operational and Management Level Officers Including an Integration of the STCW Code into the USCG License Examination Process"
MERPAC recommends that all Task Statements be posted on the MERPAC web site, and that the complete text of MERPAC's recommendations, and the resulting USCG actions be posted with each Task Statement.
Closed
                                       

07-06
TS 59
Access to Shore Leave by Merchant Mariners
MERPAC notes the present section 307, entitled: SEAMEN'S SHORESIDE ACCESS in the proposed Coast Guard Authorization Act 2006 (H.R. 5681), which reads:

      "Each facility security plan approved under section 70103(c) of Title 46, United States Code, shall provide a system of seamen assigned to a vessel at that facility and representatives of seamen's welfare and labor organizations to board and depart the vessel through the facility in a timely manner at no cost to the individual."

MERPAC recommends that the Coast Guard vigorously support the enactment of this section of H.R. 5681.

Open
                                       

08-06
TS 62
Combination of Mariner Credentials
MERPAC recommends that the MMC shall be a booklet similar in size and design as a United States Passport.

Closed
                                       

09-06
TS 62
Combination of Mariner Credentials
MERPAC recommends that the cover shall be of a durable waterproof material, embossed with the U.S. Merchant Marine insignia.
Closed
                                       

10-06
TS 62
Combination of Mariner Credentials
MERPAC recommends that the pages be of a durable waterproof material and have built-in tamperproof and copy-proof characteristics.

Closed
                                       

11-06
TS 62
Combination of Mariner Credential
s
MERPAC recommends that the inside cover/first page contain the name, address, and photograph.
Closed
                                       

12-06
TS 62
Combination of Mariner Credentials
MERPAC recommends that the MMC contain no sensitive personal information such as social security number, date of birth, and medical conditions.

Closed
                                       

13-06
TS 62
Combination of Mariner Credentials
MERPAC recommends that the MMC can be opened to a page containing the license, that can be posted aboard a vessel, and that this page(s) contain no sensitive personal information.
Closed
                                       

14-06
TS 62
Combination of Mariner Credentials
MERPAC recommends that endorsements, upgrades, or amendments, be made by addition of pages inserted and held in place by adhesive strip.  Such additions shall be made available to mariners by mail or printable on demand at a local REC.

Closed
                                       

15-06
TS 62
Combination of Mariner Credentials
MERPAC recommends that the USCG provide several prototype MMCs to the committee for approval.

Closed
                                       

16-06
TS 62
Combination of Mariner Credentials
MERPAC recognizes that the current form of license has traditional and sentimental value to many mariners.  MERPAC recommends that a suitable for framing copy of the license remain an option that the mariner can choose.  This shall be an option that the mariner can choose and be made available for a nominal fee.

Closed
                                       

17-06
TS 63
Recommendations on General Areas to be Considered During the Comprehensive Review of the STCW Convention
MERPAC voted to accept the work group's recommendations which may be viewed at 
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "Meeting 26 Minutes"
Closed
                                       

18-06
T/S 56
TWIC/MMC RULEMAKINGS
MERPAC strongly recommends that TSA should remove mariners from the TWIC project.  The TSA should modify the existing credential that most mariners already have, as this document, with the photo of each mariner already meets the standards called for in MTSA.  By updating and creating new biometrics in the existing MMD, or creating a new MMC, mariners could meet the intent of TSA without the duplicative effort of the TWIC.
Closed
                                       

19-06
T/S 56
TWIC/MMC RULEMAKINGS

Given the size, complexity, and impact of these three rulemaking proposals, MERPAC recommends an extension of the comment period for at least another ninety days.  For example, many U.S. mariners are onboard vessels for over three months at a time.  They will not have an opportunity to comment under this truncated comment period.  U.S. mariners are low-risk, there does not seem to be any overriding national security interest that would necessitate such a short comment period.  It is better to implement it correctly the first time.
Closed
                                       

20-06
T/S 56
TWIC/MMC RULEMAKINGS
MERPAC recommends that the Coast Guard delay the implementation of the MMC, separating the implementation of the MMC from the TWIC implementation, until the TWIC program is deemed successful.  
Closed
                                       

21-06
T/S 56
TWIC/MMC RULEMAKINGS

The rulemaking uses as its foundation the regulations under DHS for a truck driver to be able to transport hazardous cargo, but there is one very large difference between the two applicants described.  The truck driver can decide he does not want to engage in carrying this material, and still maintain viable employment as a truck driver.  You have not given the maritime workers nor their employers the same option.  They must either comply or leave the industry completely.  MERPAC recommends that Coast Guard establish new criteria, based on the requirements of MTSA, not use this existing rulemaking that has different legislative origins and does not address terror threat as is required under MTSA.  
MERPAC recommends that this rulemaking must be expanded to include all sectors of the transportation industry.  The origins of this project were for an Intermodal card that would affect all modes of transportation in the United States. Now, it is just a maritime and mariner card.  The committee is concerned with this segmenting of the rulemaking on many levels, one of which is that this rulemaking has the potential to further acerbate the manpower shortages in our industry, since train operators, truck drivers and bus drivers that serve the waterfront can choose to continue their employment in other transportation sectors, The passenger bus company can stop service to the cruise ship dock, and will pick up charters at hotels, instead.  The truck company will haul air freight instead of getting TWICs for their drivers.  MERPAC is concerned that these services to the waterfront will cease to exist due to the additional costs and the administrative burdens associated with the rulemaking.  It was the intent of the 9/11 commission to have this be a Transportation Worker Identification, not a Maritime Worker card.  
Closed
                                       

22-06
T/S 56
TWIC/MMC RULEMAKINGS

MERPAC recommends that this rulemaking should also be expanded to every sector of transportation so that every sector can comment on the development of the TWIC standard that will eventually apply to all sectors.    If not done concurrently, then when, or if, this card does apply to every sector, additional rulemakings would be required.  TSA needs to detail how other transportation sectors will be brought into the TWIC program, and if each sector provides input on a rule that is "finished" for the maritime sector, TSA needs to explain how the government will avoid having different rules leading to the issuance of the same card that maritime workers have.  

Closed
                                       

23-06
T/S 56
TWIC/MMC RULEMAKINGS

MERPAC recommends that a "TWIC" be sector specific, and be complaint with ILO 185, FIPS 201 and HSPD 12. The mariners can still have the MMD (or MMC) that would be compliant with ILO 185, HSPD 12 and FIPS 201. The aviation, rail, highway, etc. sectors could also have their sector specific TWIC's. Just as the government ID's will be compliant but we are sure will not look exactly the same, even between different agencies.  If this is the case, that outcome should be included in this rulemaking.  
Closed
                                       

24-06
T/S 56
TWIC/MMC RULEMAKINGS

MERPAC would also like to comment in the lack of interest that the TSA has shown in the input of this committee.  Our charter is to provide feedback to the Secretary of the department on matters of importance to the mariners of our nation.  That department includes the Coast Guard, as well as TSA.  The committee feels that TSA's lack of interest is extremely disrespectful of the committee and their commitment.  Committee members all take valuable time from their workdays, time that they are not compensated for to participate in meetings and calls.  Considering the size, scope and complexity of this rulemaking, the committee must express its frustration with TSA, to publicly state in our meeting, as they were signing off one hour into both scheduled three hour calls,  that they had deliberately chosen to schedule other activities that they deemed more important than to answer our questions and receive our comments.  We recommend and encourage the team to show more care and concern for the mariners as they move from NPRM to final rule, and the committee hopes this is not a reflection of the service that applicants for a TWIC will receive.  
Closed
                                       

25-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, while millions of dollars are being spent coast to coast on security measures for consultants to tell ports authorities how to be more secure, and for marine terminals to add fencing and lighting and x-ray machines. Our government has now decided that the identification of waterfront workers is a significant addition to waterfront security, but not significant enough to invest in those workers.  Mariners are now expected to shoulder the cost of TWIC by themselves, with no government assistance.  The Coast Guard and TSA need to find other funding sources for the TWIC besides the individual mariners.  If that is rejected, then TWIC applicants should only pay the actual production costs of the cards, not the administrative costs of TSA.   Because TSA has chosen to apply the TWIC only to the maritime sector, and not the complete transportation system, as described on page 29400 of the rulemaking, maritime workers are being forced to shoulder an unfair portion of the administrative program costs, These costs should be and would be further divided if the cards were being mandated for trucks, trains, etc.  MERPAC recommends that the next round of Port Security Grants should be made available to every mariner, transportation worker and owner/operator to pay for this unfunded mandate.
MERPAC recommends that this program, from information collection to card activation, must be conducted by the US government, as are the credentials, not contracted out to a for-profit contractor. The language in the rulemaking that provides for this work to be done by a trusted agent should be removed.  MERPAC believes that this is not an appropriate function for a contractor, particularly in light of current privacy concerns.  Subpart E describes that DHS will review the fees charged to the applicant every two years but how can DHS determine the appropriate profit for a for-profit agent?  If there is a stated percentage of profit that is appropriate, that percentage should be included in the rulemaking for comment.  When the bi-annual review is published, the percentage of profit should again be broken out, particularly before any increase in fees is approved.
Closed
                                       

26-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, MERPAC recommends that TSA should facilitate the payment of any fees via the pre-enrollment web site. TSA should begin the vetting process with information submitted at this web site.   Mariners should be able to pay the fees required by credit card, not just money order, check or wire transfer.  Cash should be accepted at the TWIC enrollment centers.  
Closed
                                       

27-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, MERPAC recommends that the card and the readers must be required to meet the standards of ILO 185, so that mariners will be able to complete their tasks and functions when sailing on foreign voyages and will be allowed access to shore leave in foreign ports.  MERPAC also feels that the US Government needs to find resolution to the ILO 185 implementation issues. 
Closed
                                       

28-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, On pg 29403, section (e): This section states "After the individual has been granted access to the facility, the owner/operator may opt to notify the TSA system that access privileges have been granted to this worker at that facility."  MERPAC would like an explanation of this section, as it seems unnecessary. Is it to red flag a particular individual that is a concern for some reason?  If they are a concern, why would they be allowed access at all?  MERPAC recommends that this option should be removed.  
Closed
                                       

29-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC recommends that facilities and vessels should be allowed to use the TWIC as a "flashpass" if there are less than 100 employees.  Facial recognition should be sufficient, as long as the card's viability is confirmed. For many facilities and vessels, the "flashpass" system will be the backup system when the reader fails.  The statement in the rulemaking should be removed that states that the cost of the card is so high that use of the card in this manner should not be allowed. 
Closed
                                       

30-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC acknowledges the creation of a "passenger access area" and commends TSA for including this solution for passenger carrying vessels. We encourage the use of the vessel security plan to allow vessel owners to define a passenger area as appropriate for that vessel.  We recommend that clarification be provided to assure that an area that is secure underway from passengers for safety reasons, but is necessary for passengers to access during loading and disembarking, be defined as a passenger area.  
Closed
                                       

31-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, MERPAC recommends that TSA explain the two year redesign, mentioned on page 29429, and explain what is involved, and explain why the card holders should pay said redesign.
Closed
                                       

32-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, TSA should identify the potential locations of enrollment centers in the rulemaking, and should remove the reference to the TSA web site posting of the suggested locations, since they are not on the web site as stated.  Selection of these locations needs to be particularly sensitive to mariners who are located where travel is more difficult and more expensive, such as Alaska and Hawaii.  Mariners who may not be able to travel twice to the same enrollment center should be able to have their card mailed to their address, and then the applicant could bring the card to a convenient enrollment center for verification and activation, at their convenience. Since the system is electronic, an applicant should be able to use any location.   
Closed
                                       

33-06
T/S 56
TWIC RULEMAKINGS

With regard to docket number 24191, the Coast Guard needs to be ready to use TWIC cards to provide access of mariners to their vessels, where currently today, mariners are frequently charged for escort, or told that they cannot leave the vessel at all.  MERPAC believes both MTSA and ISPS both require access be provided to those with a justified need to access the facility and/or vessel.   Coast Guard should ensure that all facility plans submitted for approval of their TWIC addendum, specify the manner that mariners and those that serve mariners with counseling services, religious guidance, etc. are guaranteed access to vessels that dock at those facilities.  Plans that do not ensure shore leave, crew changes, stores delivery, visits by union representatives, seafarer welfare agents and shipping company representatives should not be approved. The facility plan should define how these activities are facilitated, and should ensure that mariners are not being charged fees for escorts or access to the above services.  
Closed
                                       

34-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC has worked with Coast Guard for many years to attempt to make the credentialing process faster, smoother and more customer-focused.  Now the TWIC process is written stating that the TWIC will require 30 days, and that the MMC process will begin after the TSA sends the necessary information to the Coast Guard.  Our fellow advisory committee, NMSAC, advised the agency that a timely processing of the TWIC cards was essential to the success of the TWIC program.  TSA needs to `sharpen its pencil' and recalculate the time necessary.  Everyone understands that an applicant with adverse information may require extra time to process, but the committee believes that the majority of cards will not need additional time, and encourages TSA to set a performance standard for their process that is customer based and meets their customer's needs. MERPAC recommends that an issue time of 96 hours  in page 29403, be added to the rule, as was discussed in the NMSAC working group meeting.  Procedures should be outlined for notification to the applicant when a timely processing cannot be accomplished, and alternative means of access should be provided, unless the applicant's background check has revealed evidence of terrorist activity.     
Closed
                                       

35-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, While MERPAC understands the reasons that Coast Guard has included the option for facilities and vessels to maintain their own badging system, MERPAC recommends that TWIC be recognized as the sole acceptable system.
Port and facility badges that are deemed necessary in addition to TWIC must be provided to the affected employees and mariners at no cost, and must be issued in a timely manner.  As an alternative, temporary, infrequent, occasional access, by TWIC holders such as mariners boarding or disembarking their vessels, should be immune from a secondary badging requirement.
Closed
                                       

36-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, RE: 33 CFR 104, 105, 106.260: TSA needs to elaborate on the procedure for providing a person with their PIN, as well as the process for receiving a new PIN should it be forgotten. According to this section, the PIN will only be used infrequently (at MARSEC level 3, or if there is a problem with the fingerprint), so presumably the person won't be using it very often.  The TWIC system needs to address this, and it needs to be something that can be done in a very short time.  
Closed
                                       

37-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, MERPAC recommends that those persons that need access to vessels subject to MTSA that provide council and religious guidance to seafarers should be required to obtain a TWIC, but be exempted from the fees for TWIC ensuring that mariners and maritime ministers are not prohibited from the free exercise of the religious rights, as provided under the first amendment.  
Closed
                                       

38-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, a test of this system has not been completed, and is essential.  The agencies need to conduct a full pilot test of this program, implementing the program from start to finish. The prototype testing to date has been grossly insufficient and has not tested the hardware, the software, the background checking procedure; nor has it tested the entire scope of the waterfront from longshore workers to mariners to vendors. The statement that the card production time was 10 days in the prototype test has absolutely no value, since TSA acknowledges that no criminal history checks were conducted.    The pilot tests also needs to include agency to agency information transfer, to demonstrate that TSA and CG can exchange information as seamlessly as described in this rulemaking.  Once a successful pilot program has been completed, TSA should then implement the rest of the program as described, from larger ports to smaller ports.  The results of this pilot program need to be published in the next phase of this rulemaking, either another NPRM or an Interim Final Rule (IFR).  
Closed
                                       

39-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, TSA needs to describe the process that the card holder will be subject to at renewal of their document. Currently, the rule is silent on this process. This rulemaking only addresses the time interval, and does not describe what level of background check will be conducted, or any other process that will be required.  
Closed
                                       

40-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC recommends that TSA review the list of disqualifying offenses.  We agree that an individual convicted of those crimes listed in section 1572.103(a)(1-4) should be permanently disqualified from receiving a TWIC.  However, while the offenses listed in (a) (5-10) are indeed very serious, they should not be permanently disqualifying.  Crimes should be reviewed to only be disqualifying if they indicate that the individual is a transportation security threat.   Additionally, items in 1572.103(b) may be inappropriate if held up to that standard, as well. This process is supposed to prevent a Transportation Security Incident (TSI), not reduce crime on the waterfront.  
Closed
                                       

41-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC appreciates the protection of applicants' personal information in the rulemaking.  However, MERPAC recommends that an additional section be included in the rulemaking that addresses the obligations and training requirements that should be necessary for the employees and managers of the enrollment centers, those employees activating and issuing TWIC cards and any other employees associated with this program.  This section should include training in recognition of fraudulent documents, software and hardware training including, but not limited to, the use of the TWIC equipment, the fee collection process and the equipment used for fee collection, and these employees should be trained in customer service.   This training must be completed before card issuance begins.  
Closed
                                       

42-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, MERPAC recommends that TSA remove the language that authorizes TSA inspections of documents.  Coast Guard is currently conducting security inspections, and they should be the sole authority arriving at vessels and facilities demanding documentation. 
Closed
                                       

43-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, MERPAC commends TSA for including a call center in the implementation process.  We believe this assistance will be crucial for implementation.
Closed
                                       

44-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC is concerned about the employment requirements in the application process.  Item 10 of 1572.17 requires a job description and listing of a primary facility where the card holder anticipates using the card.  We assume that if this information is not provided, a card will not be issued.  However, this does not allow for applicants and new mariners to enter the industry.  This information should be removed from the application, so that mariners are not accused again of submitting incomplete applications.  The purpose of the collection of this information could be accomplished by changing the attestation on page 29456, which should state that the applicant attests that they have a legitimate need for the card, that they understand its uses and obligations.  They should not be asked to attest that the card "as part of my employment duties' as for an applicant, that may not yet be true. 
Closed
                                       

45-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, 33 CFR 104.235: MERPAC believes that the 2 year record keeping requirement described on page 29413 is excessive and unnecessary.  Vessel logs, employee records, etc. contain the information that a running log provides.  This requires a burden that is not required of a foreign vessel in a US port, and will negatively impact port operations, require staffing that is not available currently, and cause sailings to be delayed: but only on US vessels.    
Closed
                                       

46-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, TSA addresses the need to have employers and their employees notify TSA of a security violation by a person attempting to access a facility with a fraudulent or tampered card.  TSA should also define what the procedures and penalties are for a violation.
Closed
                                       

47-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC recommends that riding gangs should be subject to the same requirements as US Mariners.  Congress recently passed a law that allows foreign riding gangs on US vessels.  These crews will not be eligible for TWICs, and these riding crews appear to undermine the security measures that are being put in place here.  These crews will be working alongside US crew members, and will likely have access to all parts of the vessel.  We believe these crew members will be allowed on board without any kind of background check and will be on board for up to 60 days.  They could not be `escorted' for the 2 months that they are on board.    TSA and Coast Guard should explain how these `riding gangs' will fit into the TWIC regime.  Additionally, these workers should be subject to all the same requirements of U.S. mariners: background checks, drug testing, etc. TSA needs to provide information on how these gangs will be accommodated.  
Closed
                                       

48-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC has concerns about the appeal process, and encourages the agencies to further define and explain this process.  We believe that the process as described will result in all of the expense and burden of proof being placed on the applicant, even if the information is found to be in error.  There should be a recovery process for expenses if the applicant is denied a document due to mistakes made by the government.  Additionally, the committee would like TSA to explain the appeal process if the applicant is denied a TWIC but the information involved is deemed classified.  
Closed
                                       

49-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, Foreign truck drivers and foreign technicians need to be specifically addressed in the final rule, providing detailed procedures to accommodate their presence in facilities and on vessels.   
Closed
                                       

50-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24191, MERPAC recommends that all TWIC holders be automatically enrolled in the Trusted Travelers Program
Closed
                                       

51-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, TSA has asked should all persons with access to Sensitive Security Information, such as Owner/operators have to obtain a TWIC. MERPAC supports the assumption, but recommends TSA assure that the language of the rule states this requirement.  
Closed
                                       

52-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, Extra knowledge should be required by those that will be implementing and involved in the program.  
Closed
                                       

53-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24191, Facial recognition software should be considered as a means of providing access with a TWIC. 
Closed
                                       

54-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24371, MERPAC believes that this rulemaking exceeds the authority of the Coast Guard to create a consolidated credential, eliminating the existing system of documents and licenses, without amending the existing US Code.  Last year, Coast Guard came to MERPAC with a legislative change proposal that the Coast Guard stated that they needed to clean up confusing and antiquated legislation that was causing the licensing and documentation program to be slow and inefficient.  Now, with no legislative change, the Coast Guard believes that it can create an entirely new system.  We believe that a more thorough review of this change and its effect on all aspects of licensing and application is needed.  Mariners should not be left in an uncertain legal authority in the Coast Guard's rush to move this regulatory change forward without sufficient time for the public to read, digest and comment on the changes. 

Closed
                                       

55-06

T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, Page 29464 tells us that there are no changes to the qualifications, experience, examinations, classes and other requirements needed, and that this is just a reorganization of existing regulations.  As there are new and changed requirements, such as physical standards and hearing standards, this statement should be honored and all changes be removed.  
Closed
                                       

56-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, the Coast Guard needs to protect mariner's financial information by removing the requirement to place the applicants Social Security Number on the face of the form of payment.  Fees should be collected by Credit card via mail or phone.  
Closed
                                       

57-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24371, Table 10.215(a), must be removed, as should the supporting text of 10.215.  If not removed, it must be corrected to assure that STCW standards are not incorrectly applied to domestic mariners.  With regard to docket number 24371, MERPAC has expressed to Coast Guard the problems of demonstration of physical ability, and Coast Guard should take this opportunity to correct this situation, not create new problems by publishing this table.  This committee has spent many hours and provided much input on a new medical NVIC to the Coast Guard. This work was done with the understanding, based on what Coast Guard has promised, to publish the final document in the Federal Register and receive public comment on the medical standards and procedures in their entirety.  Including this table, and the accompanying language, is not acceptable in this rulemaking.  MERPAC believes this guidance to be confusing, incomplete, incorrect and damaging to the domestic mariners as written.  
Closed
                                       

58-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24371, MERPAC suggests the removal of the language in section 10.211 (e).Since Coast Guard will not be conducting background checks for disqualification due to  security and terrorism, this paragraph seems inappropriate.  The language here states "The applicant will be notified in writing of the reason or reasons for disapproval, unless the Coast Guard determines that the disclosure of information is prohibited by law, regulation or agency policy, in which case the reason(s) will not be disclosed."  Mariners are entitled to due process, and denial based on the crimes in table 10.211(g) should be transparent to the mariner, to respond with the appeal that this rule authorizes.  
Closed
                                       

59-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, Section 10.217 allows for Coast Guard to designate other Coast Guard locations to provide service to applicants of MMC's, and MERPAC applauds this addition.  We ask that in Section 10.219 the language addressing fee payments be changed to concur with the previous section, allowing mariners to pay cash or credit cards at these alternate locations.  
Closed


60-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, Section 10.225 states that mariners must surrender their old MMC.  10.227 states that the mariner can retain an expired document.  Mariners should be allowed to keep expired documents and licenses, and this language should be corrected, and 10.225 should be corrected.  
Closed
                                       

61-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, MERPAC recommends that the Coast Guard create an MMC that is convenient for the mariner.  They should consider a small document that is either wallet sized, or resembles a passport, that is more durable and easier for the mariner to transport. 
Closed
                                       

62-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, MERPAC recommends that Coast Guard should begin a new rulemaking that would harmonize the criminal background checks with TSA standards so that Mariners are only subject to one background check, at one cost.   Coast Guard should use the same standards of criminal conviction as TSA.
Closed
                                       

63-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, MERPAC recommends that Coast Guard remove the self-disclosure portion of the application process.  The TWIC search will discover sufficient criminal convictions that should be applied by both agencies.  
Closed
                                       

64-06
T/S 56
TWIC/MMC RULEMAKINGS

With regard to docket number 24371, MERPAC has concerns about the appeal process, and encourages the agencies to further define and explain this process.  We believe that the process as described will result in all of the expense and burden of proof being placed on the applicant, even if the information is found to be in error.  There should be a recovery process for expenses if the applicant is denied a document due to mistakes made by the government.  Additionally, the committee would like TSA to explain the appeal process if the applicant is denied a TWIC but the information involved is deemed classified.  
Closed
                                       

65-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, MERPAC recommends that Coast Guard redesign the rulemaking to assure that mariners can make application for their TWIC and their MMC simultaneously, allowing the two processes to move forward concurrently, and not make the mariner wait for the delivery and activation of the TWIC card before applying for their MMC.
Closed
                                       

66-06
T/S 56
TWIC/MMC RULEMAKINGS
With regard to docket number 24371, MERPAC recommends that Coast Guard and TSA develop an interim clearance process be provided to a mariner, and they be allowed to train and work, while awaiting a final determination.  
Closed
                                       

67-06
No T/S
MERPAC endorses the passage by Congress of Section 308 of the Coast Guard Authorization Act 2006, that is titled Seaman Shoreside Access, guaranteeing the access to vessels of seafarer welfare agents and labor officials AND assures that seafarers have access to shore leave. 
Open
                                       

01-07
TS 61
Merchant Mariner Medical Waiver Evaluation Guidelines 
MERPAC voted to accept the work group's recommendations which may be viewed at 
http://homeport.uscg.mil/merpac
click on Meetings/Minutes
click on "Meeting 27 Minutes"
Open
                                       

02-07
TS 51
Minimum standard of competence on tanker safety
A recommendation was made to accept 2 familiarization tables and 2 specialization tables found on Homeport as one recommendation, as well as to move the issue of liquefied gas tankers training to Task Statement 64.

To view the Tables, go to
http://homeport.uscg.mil/merpac
click on "Meeting/Minutes"
click on "Meeting 27 Minutes"
Closed
                                       

03-07
TS 59
Access to Shore Leave by Merchant Mariners
MERPAC recommends that the Coast Guard review the ISPS Code, The Preamble to the
 ISPS Code, IMO Conference Resolution 11 entitled: Human-element-related aspects and
 shore leave for seafarers (12 December 2002), IMO MSC/Circ.1112 Shore Leave and 
Access to Ships Under the ISPS Code (7 June 2004), and IMO MSC/Circ.1132 Guidance 
Relating to the Implementation of SOLAS Chapter XI-2 and the ISPS Code, ILO 
Convention 185.
Following such review, the appropriate agencies within the Department of Homeland 
Security must undertake to change the relevant sections of 33CFR and bring them into 
conformity with the ISPS Code. Specifically that:
Ship owners or operators covered under 33 CFR, Ch. I, Sub-chapter H, Subpart B Part 104.200(b)(6) must ensure facilitation of shore leave for vessel personnel or crew 
change-out as well as access through the facility of visitors to the vessel (including 
representatives of seafarers' welfare and labor organizations), with facility operators in 
advance of vessel's arrival,
and
Facilities Security Requirements for Owners or Operators (33 CFR, Ch. I, Sub-chapter H, 
Subpart B Part 105.200(7)), must ensure the facilitation of shore leave for vessel personnel or crew change-out, as well as access through the facility to for visitors to the vessel (including representatives of seafarers' welfare and labor organizations), with vessel operators in 
advance of a vessel's arrival. In facilitating such leave, facility owners or operator may 
refer to treaties of friendship, commerce, and navigation between the U.S. and other 
nations.
by
Changing the present 33 CFR sub-chapter H sections 104.200 (b)(6) and 105.200 (b)(7) 
be amended from " . . . must ensure coordination of shore leave . . . " to " . . . shall ensure 
and facilitate access to shore leave..."
Such changes must adopt the same language as in the ISPS Code, section 16.3.15 that calls for facility security plans to address" procedures for facilitating shore leave for ship's 
personnel or personnel changes, as well as access of visitors to the ship including 
representatives of seafarers' welfare and labour organizations.
Any revision to existing regulations must also clearly provide for federal preemption of any state or local laws that would conflict with federal regulations.
Open
                                       

04-07
TS 59
Access to Shore Leave by Merchant Mariners
MERPAC recommends that the US Coast Guard shall not approve Facility Security Plans
 that do not include procedures for facilitating shore leave for ship personnel or personnel 
changes, as well as access of visitors to the ship, including representatives of seafarers' 
welfare and labor organizations. Presently par. 105.405 does not include Part A 16.3.15, 
which in the ISPS Code states every plan shall address this section.
Open
                                       

05-07
TS 59
Access to Shore Leave by Merchant Mariners
MERPAC calls on the Department of Homeland Security and the US Coast Guard to note the International Maritime Organization's clarification of the issues related to shore leave and access in MSC/Circular 1112 #4:
      "To address these concerns and principles, section A/16.3.15 of the ISPS Code provides that a port facility security plan (PFSP) must contain procedures for facilitating shore leave, crew changes and access (emphasis added) for visitors including representatives of seafarers' welfare and labour organizations. This should be construed as including shore-based ship support personnel and the taking onboard of ship's stores. The guidance contained in paragraph B/16.8.14 of the ISPS Code reinforces this requirement by providing that the PFSP should contain such procedures relating to all security levels."
MERPAC also notes #2 of this same MSC circular:
      "In this regard, it was recognized that there may be conflicts between security and human rights, as well as between security and the efficient movement of ships and cargoes in international trade that is essential to the global economy. There must be a proper balance between the needs of security, the protection of the human rights of seafarers and port workers, and the requirement to maintain the safety and working efficiency of the ship by allowing access to ship support services such as the taking on of stores, repair and maintenance of essential equipment, and other vital activities that are appropriately undertaken while moored at port facilities."
MERPAC recommends to the Department of Homeland Security and the US Coast Guard place the burden on the facility which wishes to deny shore leave and access to justify how their need for such denial exceeds the right of seafarers to shore leave and access to the vessel by those mentioned in Part A 16.3.15 of the ISPS Code.
Open
                                       

06-07
TS 59
Access to Shore Leave by Merchant Mariners
MERPAC noted that section 307, entitled: SEAMEN'S SHORESIDE ACCESS in the Coast Guard Authorization Act 2007 (H.R. 5681), which read:
      "Each facility security plan approved under section 70103(c) of title 46, United States Code, shall provide a system for seamen assigned to a vessel at that facility and representatives of seamen's welfare, labor organizations, and pilots to board and depart the vessel through the facility in a timely manner at no cost to the individual."
MERPAC recommends that the Coast Guard place this paragraph in the 2008 authorization act, and vigorously support the enactment of the section.
Open
                                       

07-07
TS 59
Access to Shore Leave by Merchant Mariners
Resolution 11, Human-element-related Aspects and Shore Leave for Seafarers#2
MERPAC believes that in the area of shore leave and access, the US Coast Guard has misinterpreted the spirit and the letter of the ISPS Code in developing the maritime security regulations. This misinterpretation has caused seafarers to be illegally denied shore leave, and those listed in Part A 16.3.15 of the ISPS Code to be illegally denied access. MERPAC takes note of Resolution 11 of the ISPS Code, which is entitled Human-element-related Aspects and Shore Leave for Seafarers. #2 states:
      "2. Encourages Contracting Governments, Member States of the Organization and non-governmental organizations with consultative status at the Organization to report to the Organization any instances where the human element has been adversely impacted by the implementation of the provisions of chapter XI-2 of the Convention or the Code;"
MERPAC recommends that the US Coast Guard begin an assessment process to determine instances where the human element has been adversely impacted by the present implementation of the provisions of chapter XI-2 of the Convention or the Code, and to report the findings to the IMO.
Open
                                       

GPM08-07
TS 60
Recommendations on Sea Service Required to Obtain Propulsion Mode Credit at the Operational and Management Levels
With regard to question 1:  Determine what minimum service would qualify a candidate as acceptable when applying for an original or a raise-in-grade of multiple engineer license propulsion modes:

a) How many hours of classroom and simulator training should be granted credit towards required sea service?  MERPAC recommends that for Steam and Motor propulsion modes, all required sea service should be done aboard a vessel.  For Gas Turbine, if the candidate has Steam and/or Motor sea service, then an approved course could be accepted for all but 2 months of the required sea service. 

Closed
                                       

09-07
TS 60
Recommendations on Sea Service Required to Obtain Propulsion Mode Credit at the Operational and Management Levels
With regard to question 1:  Determine what minimum service would qualify a candidate as acceptable when applying for an original or a raise of grade of multiple engineer license propulsion modes:

What should be the minimum amount of actual sea service obtained when applying for multiple propulsion modes of an original or raise-in-grade of an engineer license?  MERPAC believes that the requirement for sea service should remain as it is in 46 CFR 11.502 (a): For all original and raise of grade of engineer licenses, at least one-third of the minimum service requirements must have been obtained on the particular mode of propulsion for which applied
Closed
                                       

10-07
TS 60
Recommendations on Sea Service Required to Obtain Propulsion Mode Credit at the Operational and Management Levels
With regard to question 1:  Determine what minimum service would qualify a candidate as acceptable when applying for an original or raise of grade of multiple engineer license propulsion modes:

MERPAC also recommends that, for a Gas Turbine endorsement, regardless of the amount of sea service, a USCG approved Gas Turbine course should be required.

Closed
                                       

11-07
TS 60
Recommendations on Sea Service Required to Obtain Propulsion Mode Credit at the Operational and Management Levels
MERPAC recommends that for crossover licenses and endorsements, the requirement should remain as it is in 46 CFR 11.502 (b): If a licensed applicant desires to obtain an endorsement on an engineer license in the other propulsion mode  (steam or motor), the following alternative methods, while holding a license  in that grade, are acceptable:  (1) Four months of service as an observer in the same licensed capacity on  vessels of the other propulsion mode;  (2) Four months of service as a licensed officer at a lower license level  on vessels of the other propulsion  mode;  (3) Six months of service as oiler, watertender, or junior engineer on vessels of the other propulsion mode; or,  (4) Completion of a Coast Guard approved training course for this endorsement.

"observer" does not need a specific grade of Officer Endorsement, so what does this mean??  Should be "4 months as observer on vessels....etc."
Closed
                                       

12-07
TS 60
Recommendations on Sea Service Required to Obtain Propulsion Mode Credit at the Operational and Management Levels
MERPAC recommends that STCW endorsements be aligned with existing domestic licensing requirements (except for those mariners getting domestic licenses with no STCW endorsement) as recommended in this Task Statement.  It is understood that all required assessments for a particular propulsion mode will be completed for a candidate to receive an STCW endorsement in that mode.

Closed
                                       

13-07
TS 60
Recommendations on Sea Service Required to Obtain Propulsion Mode Credit at the Operational and Management Levels
With regard to question 2:  Evaluate the intent of training and the assessment of practical skills during the minimum seagoing service period.  What enhancements should be made to existing sea courses to ensure that the candidate will actually "absorb" the subject matter, and develop the intended practical skills (outcome performance)?, MERPAC notes that the intent of training and assessments are to ensure that the mariner has achieved a minimum level of knowledge and competency.  MERPAC therefore recommends that the USCG course approval process should ensure that the training providers have sea courses (i.e., on board training programs) that meet the relevant requirements of A-III/1. 

Closed
                                       

14-07
TS 65
Section 501 of the Coast Guard Authorization Act for fiscal year 2008
MERPAC does not support the following proposed revisions of Chapter 71 of title 46, United States Code contained in section 501 of  the Coast Guard Authorization Act for Fiscal year 2008:  sections 7106 (a), 7107 (a), and  7302 (f) (1).

It is MERPAC's position that a license, Certificate of Registry, MMD or MMC should be issued for periods of less than the current statutory period of five years only upon the request of the mariner.  
Rejected.
To achieve this goal, MERPAC recommends that the Coast Guard amend section 7106(a) to read: "a license issued or renewed under this part, is valid for five years, except at the request of the mariner.  In such instances, the Commandant shall allow a license to be issued for a period of less than five years". 

Sections 7107 (a) and 7302 (f) (1) should be amended with the same language for Certificates of Registry and for merchant mariner credentials, respectively.  

With the inclusion of this language, MERPAC endorses the legislative change proposal. 

As an alternative, MERPAC endorses a legislative change proposal which would not include sections 7106 (a), 7107(a) and 7302 (f) (1).  In place of section 7106(a), the following language would be inserted:  "A license issued under this part, is valid for 5 years and may be renewed for additional 5-year periods."

Sections 7107 (a) and 7302 (f) (1) should be amended with the same language for Certificates of Registry and for Merchant mariner documents, respectively. 
Closed
                                       

15-07
TS 65
Section 501 of the Coast Guard Authorization Act for fiscal year 2008
MERPAC recommends that the Secretary of the Department of Homeland Security direct that the appropriate agencies take whatever action is necessary to allow the extension of a Transportation Worker Identification Credential to align with the extension of the Merchant Mariner Credential as proposed in sections 7106(b), 7107(b) and 7302(f)(2).

Closed
                                       

16-07
No TS
MERPAC recommends that DHS assure that enrollment centers for the Transportation Worker Identification Credential be permanently located either within the 17 regional exam centers (REC) or within walking distance, so that a mariner can apply for both documents with the minimum inconvenience.  
Closed
                                       

17-07
TS 66
MMC Rulemaking
MERPAC presented a list of 20 recommendations with regard to the MMC Rulemaking.

To view the recommendations, go to:
click on "Meetings/Minutes"
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "MERPAC 2007 Intercessional Meeting"
Closed
                                       

18-07
TS 64
CG-5221
MERPAC presented a lengthy list of recommendations with regard to Task Statement 64, "Recommendations on areas in the STCW Convention and the STCW Code identified for comprehensive review.

To view the recomme3ndations, go to:
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
click on "MERPAC Meeting 28"
view dealing with Task Statement 64.
Closed
                                       

19-07
No task statement
Whereas MERPAC believes that the current deadline for Transportation Worker Identification Credential implementation cannot be met, and if met, will not be met without great inconvenience to the mariners and other waterfront workers impacted by the TWIC, MERPAC recommends that the Coast Guard undertake a new rulemaking to establish a new compliance date for enrollment.  At a minimum, the Coast Guard should establish through a rulemaking a rolling deadline, re-establishing as a MINIMUM a compliance date of 20 months after the date that enrollment begins.

By the time that the current deadline arrives, all mariners will have completed a background check and have demonstrated that they have no security issues.  To enable a smoother implementation, mariners should be removed from the rulemaking, accepting their Merchant Mariner Document/MMC as a TWIC equivalent or delaying the issuance of TWIC cards to these already vetted mariners. 

Closed
                                       

20-07
No task statement
The Transportation Worker Identification Rulemaking process outlined that 130 permanent enrollment centers would be established for the 1.5 million individuals who need to enroll for a TWIC.  Cost impacts for the final rule were estimated using a one-way travel time to an enrollment center of 22.49 minutes.  These same centers will be needed to apply for and receive the card and apply for a lost, stolen, or damaged card.   MERPAC believes that the demands of the card holders will not diminish significantly.  The Coast Guard, Transportation Security Administration and the Department of Homeland Security need to take whatever steps, statutory or otherwise, that will assure that the 130 centers continue to be a minimum, supported after the initial enrollment period is deemed to be completed.
Closed
                                       

21-07
No task statement
The pilot TWIC reader program needs a sufficient number of vessels in appropriately diverse operating areas to fully test this new technology and operating conditions and procedures.  
Closed
                                       

01-08
TS 55
With regard to Task Statement 55, "Recommendations to develop a voluntary training program for deck and engine department entry level mariners on domestic and seagoing vessels," MERPAC submitted a list of recommendations which may be viewed at:
http://homeport.uscg.mil/merpac
click on "Meetings/Minutes"
"MERPAC Fall 2007 Meeting 29"
Click on enclosure dealing with task statement 55.
Closed
                                       

02-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC believes that the development of the Draft NVIC and the accompanying draft CG-719K has not used good principles of risk-based decision making.  MERPAC recommends that the Coast Guard use all data available to them and reconsider the information contained in the NVIC.  Any requested information or medical conditions that are currently listed as a medical condition on the current draft that could prevent a mariner from receiving their credential, that is not specifically required by statutory or regulatory language and that is not supported by the casualty data or root cause analysis that the Coast Guard has in its database of accidents should be removed from the criteria listed in the NVIC.

   
We continue to be concerned that the list of medical conditions exceeds the defined goal of task statement 61, which was to "provide recommendations on medical waivers, functional tests for mariners and identify risks of sudden incapacitation".  MERPAC believes that many conditions listed in the draft NVIC continue to exceed the above described standard, and should be removed from the document.

Additionally, MERPAC recommends that the Coast Guard conduct a comprehensive risk based study to determine the causes of and contributing factors to marine casualties.  The study should identify data requirements and collection procedures, reports, and other measures that will improve the Coast Guard's ability -- 
(1) to evaluate future marine casualties;
(2) to monitor trends to identify causes and contributing factors; and
(3) to develop effective safety improvement policies, including: 
      workload;
      manning; and 
medical review provisions and programs.

Open
                                       

03-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:    Task statement 61 asked MERPAC to review the draft NVIC (enclosure (8)) as it existed when published in the Federal Register on 28 September 2006.  Should the Coast Guard choose not to undertake the risk-based assessment recommended above, MERPAC has provided comments to the NVIC, and submits together with these recommendations our version of the proposed NVIC.  We recommend that Coast Guard accept all proposed changes that have been made to the draft NVIC as compared to the draft NVIC attached to Task Statement 61 (enclosure (8)).  Our version of the recommended changes to the draft NVIC is enclosure (9).   
Closed
                                       

04-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends, as it has previously recommended, that the Coast Guard needs to make every effort to educate the mariners affected by this NVIC about its impact.  The Coast Guard should continue to make every effort to assure mariners that this NVIC will not result in a higher rate of disqualification for service.  A public relations campaign is past due to prevent a mass exodus from the industry, particularly those mariners who believe that because of their age, weight or medical condition that applying for a renewal is a waste of time and money.  The maritime industry cannot accept the loss of this manpower, expertise or experience, and the committee feels that we need to be concerned that this manpower shortage leaves the nation vulnerable.  

Secondly, this education campaign needs to address mariner's belief that they are better off not seeking medical attention when they require it and following the physician's advice and prescribed medications, than to risk jeopardizing their careers.
Closed
                                       

05-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC strongly objects to the insertion of the language in Item 5a of enclosure (3) of the draft NVIC (enclosure (8)), and have deleted that language from the draft reviewed for this meeting.  MERPAC has already advised the Coast Guard that this NVIC has had a chilling effect on the mariners in the industry.  It is not appropriate, in the opinion of this committee, to use a document put forward as a tool to assist mariners and their physicians to also spell out the procedures to accuse that same mariner of breaking the law, particularly since that procedure could be used in a nefarious manner against an innocent mariner.  The Coast Guard has many other tools in its repertoire to get this message out, and should use another tool.
Closed
                                       

06-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends that the Coast Guard allow physicians to accept as evidence of the requirement to demonstrate physical ability, a valid Basic Safety Training certificate.  Since the course is assessed  by a certified Assessor, as defined in STCW, that assessor has clearly seen the mariner demonstrate the requirements of firefighting, treading water, entering a liferaft, etc. that all the required tasks have been demonstrated.  The acceptance of BST would apply either to meet the requirements of STCW or to address the concerns of a physician who is concerned that the mariner has a physical condition that would restrict the ability to perform their job.
Closed
                                       

07-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC again recommends that the Coast Guard publicize to mariners that over-the-counter (OTC) medications and dietary supplements (vitamins, herbal supplements, etc) may impair their ability to perform the duties.  
Closed
                                       

08-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC strongly recommends that the USCG limit the disclosing requirements for prescription and OTC medication to the previous 30 calendar days, as MERPAC has inserted into the draft NVIC (enclosure (9)).  The requirement to disclose all prescriptions and OTC medications is unreasonable and places an unfair responsibility on the mariner to recall and record information that may not be relevant to the application for, or renewal of, their credential.  
Closed
                                       

09-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends that the Coast Guard designate certain medical practitioners as "trusted agents" to perform physical examinations on mariners.  Physical examinations conducted by trusted agents and/or their recommendations may be given more weight by the Coast Guard.  We believe that the utilization of these trusted agents will benefit the mariner by reducing the processing time and the cost.  We also believe the Coast Guard will benefit by this concept, because we believe that the planned staff of the NMC is insufficient to reach its stated goal of reviewing and approving all medical applications in a timely manner.  

The criteria to become a trusted agent would be developed by the Coast Guard, and should include training, certification and experience in the methods of conducting medical and physical examinations for mariners.  We have included our suggested language on trusted agents in enclosure (2) of our draft NVIC, which is enclosure (9) to these minutes.
Closed
                                       

10-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends that the Coast Guard review the medical and physical evaluations guidelines for applicability to limited licenses or for service on vessels of limited size, route or type, and as appropriate develop alternate evaluation guidelines for limited licenses or vessel service.  A testing standard needs to be developed.
Closed
                                       

11-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends that the Coast Guard develop appropriate medical and physical evaluation guidelines for candidates with learning disabilities.  
Closed
                                       

12-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  Throughout this process, MERPAC has consistently recommended that a mariner's renewal or raise in grade in their credential should recognize that all information regarding medical conditions and medications was requested and provided at that time.  Therefore, these recommendations include those conditions that are no longer relevant after a five year period has elapsed, and there has not been a change that would require additional medical attention.  The committee recommends that information that exceeds the 5 year life of the credential on non-relevant conditions should not be required to be disclosed again for those conditions.  Once the mariner has disclosed a medical condition, and has been cleared for the issuance of a credential, the mariner should not be required to provide information on that condition again.  Many conditions in the enclosure to the draft NVIC have clearly defined look back periods in the draft NVIC (enclosure (9) as submitted with these recommendations. 
Closed
                                       

13-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC does not believe that the proposed 719K meets the criteria that the committee sought when suggesting a new form.  The proposed form does not support the NVIC by seeking the same information that this committee has worked so hard to define.  While the committee has worked together to propose changes to the draft presented by the Coast Guard, we recommend that the CG continue to refine the proposed form to develop a document that matches the  defined medical conditions and their look back periods.

MERPAC recommends that one of the changes that Coast Guard should consider is a form where the medical history portion would be detached and returned to the mariner and/or retained by the VMP.  This detached portion would possibly include medical conditions that are not relevant to the performance of the mariner serving under the authority of their credential, or medications that have no relevancy to the mariner's performance.  This would allow the physician and the patient to have an open and honest discussion of the entire medical history without compromising the privacy of the mariner and disclosing medical information that is not relevant to the issuance of a credential.  
Closed
                                       

14-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  Should the Coast Guard choose to disregard recommendation #12 above, MERPAC recommends that the revised 719K, as completed at this meeting, (enclosure (10)) should be adopted with the revisions the committee made, including the recommendations modifying the requirements of reporting medications, prescription or over the counter.  MERPAC believes strongly that the Coast Guard should only seek information on medications that are pertinent to the matter of determining competency of the mariner, to protect public safety and the risk of sudden incapacitation.
Closed
                                       

15-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends as reflected in the draft form (enclosure (10)) that the NMC be allowed, at the mariners request, to contact the mariners personal physician directly.
Closed
                                       

16-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends that any references to Body Mass Index alone as a standard should be removed from both the NVIC and the draft 719K.
Closed
                                       

17-08
TS 61
With regard to Task Statements 61, "Merchant mariner medical waiver evaluation guidelines," Task Statement 68, "Review of draft NVIC concerning medical and physical evaluation guidelines for merchant mariner credentials," and Task Statement 69,  "Revision of CG-719K, Merchant Mariner Physical Examination Report, and CG-719K/E, Merchant Marine Certification of Fitness for Entry Level Ratings," MERPAC made the following recommendation:  MERPAC recommends that enclosure (6) of the Medical NVIC be revised as the committee has completed in enclosure (9) to include the correct application of the term "waiver". MERPAC has included an additional outcome to the medical review process for a mariner who should be issued a "conditional approval".   The term waiver is only correctly used when the mariner does not meet the medical or/and physical requirements, and is waived from meeting those requirements.
Closed
                                       

18-08
TS 64
With regard to the Tables of Competence contained in Section A-II of the STCW Code, 
MERPAC recommends that the Coast Guard remove the requirement for visual signaling.
Refer to Chapter II of the STCW and also IMO document IMO document STW 39/7/3,
 found in the meeting 30 minutes located at
http://homeport.uscg.mil/merpac
Closed
                                       

19-08
TS 64
With regard to the Tables of Competence contained in Section A-II of the STCW Code, MERPAC recommends that the celestial navigation table provided in the task statement (46 CFR 10.910-02) should be approved with the understanding that the examination would deal with sun and stars only for sight reduction and for determination of ship's compass error.
Refer to Chapter II of the STCW and also IMO document IMO document STW 39/7/3,
 found in the meeting 30 minutes located at
http://homeport.uscg.mil/merpac
Closed
                                       

20-08
TS 64
With regard to the Tables of Competence contained in Section A-II of the STCW Code, MERPAC recommends that the passing grade for celestial navigation modules should be reduced from 80% to 70%.
Refer to Chapter II of the STCW and also IMO document IMO document STW 39/7/3,
 found in the meeting 30 minutes located at
http://homeport.uscg.mil/merpac
Closed
                                       

21-08
TS 64
With regard to the Chapter III of the STCW, MERPAC recommends that:
   Regulation III/1: 
   - Use the language proposed by the EU: [2.2] and [2.2bis].  Additionally, we strongly recommend that the word "watchkeeping" be deleted from the proposed [2.2bis].
   - Keep 2.3 as currently written.
   - Use language proposed in 2.4, but add VI/1 as a requirement.
   
   Regulation III/2:
   - Use the proposed language as written.
   
   Regulation III/3:
   - Strike the words "assistant engineer officer" from paragraph 2.1.1.
   - Strike the last clause in paragraph 3 (removes requirement for person to have 12 months seagoing service as an engineer officer) only if III/2 is approved as written.
   
   Regulation III/6:
   - Use the language for electro-technical officer as written (both levels).
   - Addtionally, add requirement for meeting VI/1, VI/2 paragraph 1, VI/3 paragraph 1, VI/4 paragraph 1.
   
   Table A-III/1 (OICEW level): 
   - use new proposed language as written.
   
   Table A-III/2 (mgmt level): 
   - amend language as follows: Under "monitor & control compliance with legislative requirements and measures to ensure safety of life at sea & protection of the marine environment",  remove .1, .2, .5, .6. 
     Additionally, combine .4 & .7.
   - Use language in renamed Competence "Use leadership and managerial skill" as written.
   
   Table A-III/6 (electro-tech officer)
   - use proposed language as written
   
   Table A-III/7 (Sr. electro-tech officer)
   - Use proposed language as written, with the exception of the following: Under "monitor & control compliance with legislative requirements and measures relating to electrical and electronic equipment and systems to ensure safety of life at sea & protection of the marine environment",  remove .1, .4, .5, .7. 
      Additionally, combine .3 & .6.
   
   
   Section B-III/5:
   - Where it says "able seafarer deck", change to read "able seafarer engine".
   
   Section B-III/6:
   oo Use proposed language as written.

Refer to Chapter III of STCW and also IMO document STW 39/7/3, found in the
meeting 30 minutes located at
http://homeport.uscg.mil/merpac

Closed
                                       

22-08
TS 64
With regard to Chapter V of the STCW, MERPAC recommends that the term "Basic" as in "Basic Familiarization" be deleted or removed from use in all applications of Table A-V/1-2. The MERPAC Committee believes that the term "Familiarization" accurately describes the code requirements.
Closed
                                       

23-08
TS 64
With regard to Chapter V of the STCW, MERPAC recommends that the following statements be removed from the STCW code because seatime along without actual loads and/or discharges would not assure competence:
      a. V/1-1-4.2.1  -  at least three months approved seagoing service on oil tankers
      b. V/1-1-6.2.1  -  at least three months approved seagoing service on chemical tankers
      c. V/1-2.4.2.1  -  at least three months approved seagoing service on liquefied gas tankers

Closed
                                       

24-08
TS 64
With regard to Chapter V of the STCW, MERPAC recommends that the following statements be modified in the code to assure competence:
      a.    V/1-1-4.2.2  -  At least one month approved on board training on oil tankers [in a supernumerary capacity] which includes at least [five] loading and [five] discharging operations and documented in an approved training record book.
      b.    V/1-1-6.2.2  -  At least one month approved on board training on chemical tankers [in a supernumerary capacity] which includes at least [five] loading and [five] discharging operations and documented in an approved training record book.
      c.    V/1-2.4.2.2  -  At least one month approved on board training on liquefied gas tankers [in a supernumerary capacity] which includes at least [five] loading and [five] discharging operations and documented in an approved training record book.

Closed
                                       

25-08
TS 64
With regard to Chapter V of the STCW, MERPAC recommends that the following provisions be added to the Code as note to allow for effective transitions between types of tankers:
      a.  V/1-1-8 Each applicant already holding an STCW endorsement for "oil tanker familiarization or chemical tanker familiarization seeking an endorsement for liquefied gas tankers, or the converse, shall--
   (1)          Provide evidence of at least half of the required sea service (45 days) of this section; and
   (2)          Provide evidence of at least [five] loading and [five] discharging operations and documented in an approved training record book.

      b.  V/1-2-6 Each applicant already holding an STCW endorsement for "liquefied gas tankers" familiarization seeking an endorsement for "oil tanker familiarization or chemical tanker, or the converse, shall--
                  (1)          Provide evidence of at least half of the required sea service (45 days) of this section; and
                  (2)          Provide evidence of at least [five] loading and [five] discharging operations and documented in an approved training record book.

Closed
                                       

26-08
TS 64
With regard to Chapter I of the STCW, MERPAC submitted recommendations to the Coast Guard.  The list of recommendations is attached as enclosure (4) of the meeting 30 minutes which may be located at
http://homeport.uscg.mil/merpac

Closed
                                       

27-08
TS 64
With regard to Chapter VIII of the STCW, MERPAC submitted recommendations to the Coast Guard.  The list of recommendations is attached as enclosure (5) of the meeting 30 minutes which may be located at
http://homeport.uscg.mil/merpac

Closed
                                       

28-08
N/A
MERPAC submitted a resolution regarding R-1 visa holders' inability to obtain TWICs.  That resolution is attached as enclosure (6) of the meeting 30 minutes which may be located at
http://homeport.uscg.mil/merpac
Within that resolution is a recommendation that the Coast Guard should recommend to the Secretary of the Department of Homeland Security to instruct the Transportation Security Administration to rescind its final rule relating to R-1 visa holders.
Closed
                                       

29-08
N/A 
MERPAC recommends that the Transportation Security Administration recognize the important service R-1 visa holders perform in offering seafarer welfare in US ports, and include R-1 visas in the list of eligible visas for obtaining Transportation Worker Identification Credentials.
Closed
                                       

30-08
None
MERPAC commends the Coast Guard in the proposed consolidated campaign to educate the mariners about the impact and implications of the recently signed medical NVIC.  MERPAC recommends that the Coast Guard produce an explanatory document and a power point presentation, and undertake a mailing of the document directly to the mariners, in addition to the public relations release to trade publications and stakeholder communicators.
Closed
                                       

31-08
None
MERPAC is concerned about the data sharing coordination between TSA, the FBI and the Coast Guard that must transpire to assure that the mariners of the United States can receive their licenses, credentials and Transportation Workers Identification Credential (TWIC) without disruption.  Without this data sharing coordination, the Coast Guard will not receive the critical mariner information needed to produce the credential.  If this were to not occur, the mariner would be required to continue to submit this information at the Regional Examination Center.  This is urgently needed to relieve the mariners of the cost and difficulty of traveling to both agencies to be fingerprinted, identified, and photographed all of which are duplicative and wasteful for both the mariners and the government.  MERPAC recommends that the Secretary assure that the procedures necessary to make this communication seamless are being developed for implementation by 1 January 2009.
Closed
                                       

32-08
None
MERPAC urges the Coast Guard to allow credentials to be mailed to mariners ahead of the printed "date of issue" to ensure that mariners get the full span of their license that they applied for and paid for.  Currently, the life cycle of the mariner's credential is shortened with each renewal when that credential is processed earlier than the expiration of the credential.  This proposal is allowable within both the current and proposed MMC rulemaking.
Closed
                                       

01-09
T/S 30
MERPAC recommends that the Coast Guard/National Maritime Center be receptive to alternative methods for demonstrating or evidencing acceptable military service to fulfill requirements for STCW.  Alternative forms could include evaluation reports or ship logs, as well as certification from supervisors and/or shipmates.  In addition, the military services and the NMC should continue working with the Task Statement 30 work group to further develop alternative evaluation methods for persons leaving military service, and who wish to enter the merchant marine.
Open
                                       

02-09
T/S 30
The work group noted that 60% of military sea time is credited toward qualifying merchant marine sea time.  Military Sealift Command deck department personnel receive day for day credit when they are underway, but receive no credit for sea time after their vessels have been docked for more than seven consecutive days.  Conversely, crewmembers serving on liftboats, ROS vessels, and casino vessels receive one day of sea time credit for every three days they are docked or jacked up.  MERPAC recommends that the Coast Guard/National Maritime Center investigate the harmonization of how creditable sea time is calculated throughout the maritime industry.
Open
                                       

03-09
TS 58
MERPAC recognizes the improvements to the process of mariner credentials at the NMC.  We believe that the new centralized system and the new processes that have been established by the staff there will result in a faster, more consistent and more equitable system for all mariners.  However, mariners are still turning to unions, trade associations, employers and friends when the system fails them.  MERPAC believes that industry stakeholders need a mariner advocate at the National Maritime Center who can assist when things go wrong.  When there is a problem with a lost file, confusion with another mariner, records that are lost, communication problems with the Transportation Security Administration, stakeholders should have a place to turn to get assistance outside of the processes, timelines and procedures established.  The system should not lose the personal touch that will always be necessary.  

Therefore, MERPAC recommends that the National Maritime Center appoint/hire a mariner advocate to act on a mariner's behalf when problems in the application process occur. 
Closed
                                       

04-09
TS 58
Additionally, MERPAC members are concerned about the on-going training of the new assessors located at the National Maritime Center.  Familiarization with routes, seatime calculations, and STCW renewal are very complex issues and initial and recurring training must be emphasized with the staff at the NMC.  Therefore, MERPAC recommends that the NMC stress the importance of assessor knowledge of new issues by conducting frequent ongoing training.  This training should include new laws, regulations and policies. 
Closed
                                       

05-09
TS 58
MERPAC is concerned with the policy in effect at the RECs where a file that is "incomplete" after 90-days is returned to the mariner.  We believe that this 90 day limit is too short, and does not take into account the demands on the mariner's limited time off and need to schedule required appointments and classes in between work periods.
Therefore, MERPAC recommends that the 90-day time limit for a mariner to contact the NMC concerning questions on the application be amended to 180 days.
Closed
                                       

06-09
TS 58
MERPAC is concerned that mariners sailing on domestic voyages who are demonstrating the same proficiencies at drills on their vessels as those mariners working on seagoing vessels and are not being given credit for maintaining the skills relative to Basic Safety Training (BST).  MERPAC recommends that the guidance addressing the renewal of a mariner's STCW certificate through on-going demonstration of BST proficiency needs to be reviewed and corrected.  Mariners who sail on domestic voyages and participate in drills and exercises while assigned to that vessel should be considered as having demonstrated continued proficiency as long as the drills performed are appropriate to the certificate being renewed.
Closed
                                       

07-09
TS 58
MERPAC recommends that NMC establish a process for prioritizing mariners' applications when a delay (backlog) exists at the NMC.  When applications in any stage of the review process are being delayed for more than 30 days, actively sailing mariners should receive priority processing to assure that mariners are not leaving their vessels and going without income. 
Closed
                                       

08-09
TS 58
MERPAC recommends that the policy guidance established regarding application of STCW on vessels less than 200 GT need to be reviewed and developed to address smaller tonnage vessels on international voyages.  
Closed
                                       

09-09
TS 58
MERPAC recommends lost or stolen credentials need to be expedited and redundant background checks and reviews which are not necessary should be eliminated.
Closed
                                       

10-09
TS 58
MERPAC recommends that mariners be approved for testing prior to completion of all required approved training courses to allow flexibility in scheduling both the exam and the courses.  This approval would only be allowed after the security, PQE and medical evaluation have been completed. 
Closed
                                       

11-09
TS 64
With regard to Annex 3 of Task Statement 64, MERPAC recommends adoption of the revised Table covering firefighting for tanker personnel and placement of the table in Chapter V, Part A of the STCW Code.
NOTE:  the table may be found as enclosure (6) at the following link in the Meeting 31 minutes folder found under the heading "Meetings/Minutes 2".
http://homeport.uscg.mil/merpac
Closed
                                       

12-09
TS 64
With regard to Annex 3 of Task Statement 64, MERPAC recommends that the USCG accept those Basic Firefighting programs that address the training and assessment in this table as meeting the Tanker Shoreside Firefighting requirement in Reg. V/I of the STCW.
NOTE:  the table may be found as enclosure (6) at the following link in the Meeting 31 minutes folder found under the heading "Meetings/Minutes 2".
http://homeport.uscg.mil/merpac
Closed
                                       

13-09
TS 64
MERPAC recommends that the Annex 1 Table of Task Statement 64 be accepted as amended and that the table should remain in Part B of STCW and not be moved to Part A 
NOTE:  the amended table may be found as enclosure (7) at the following link in the Meeting 31 minutes folder found under the heading "Meetings/Minutes 2".
http://homeport.uscg.mil/merpac  
Closed
                                       

14-09
TS 64
With regard to Annex 2 of Task Statement 64, concerning standards of competence for ratings as able seafarer electro-technical, MERPAC recommended several changes to the table.
NOTE:  the amended table may be found as enclosure (8) at the following link in the Meeting 31 minutes folder found under the heading "Meetings/Minutes 2".
http://homeport.uscg.mil/merpac  
Closed
                                       

15-09
TS 70
With regard to Task Statement 70, and in response to the Coast Guard's question, Should the Coast Guard clarify that the Apprentice Mate/Steersman "License" is only a "Learner's Permit" and that it does not authorize underway service?  If so, should this new terminology appear in NVIC 04-01, Change 1, and later in the Code of Federal Regulations?  Should the term "Steersman" be changed to "Apprentice Steersman" in order to emphasize its "training" status?
     
MERPAC recommends that the existing documentation is sufficient to detail the authority of this license.  The current language of NVIC 4-01 item 5(K), 46 CFR 15.610 and 46 CFR 10.104 does not need revision. Under enclosure (1) NVIC 4-01 paragraph 2 C 4e specifies:  
(e) Apprentice mate (steersman) (under the direct supervision of a licensed officer).  In addition, 46 CFR 10.104 Definitions of terms used in this part states "Apprentice Mate (steersman) of towing vessels means a mariner qualified to perform watch keeping on the bridge, aboard a towing vessel, while in training under the direct supervision of a licensed master or mate (pilot) of towing vessels."  In summary, 46 CFR 15.610 states "every towing vessel...must be under the direction and control of a person licensed as Master or Mate (Pilot) of towing vessels...". 
Open
                                       

16-09
TS 70
With regard to Task Statement 70, and in response to the Coast Guard's question, Should the Coast Guard clarify that the Apprentice Mate/Steersman "License" is only a "Learner's Permit" and that it does not authorize underway service?  If so, should this new terminology appear in NVIC 04-01, Change 1, and later in the Code of Federal Regulations?  Should the term "Steersman" be changed to "Apprentice Steersman" in order to emphasize its "training" status?

MERPAC recommends that as NVIC 4-01 is revised by TSAC it should include a definition of "direct supervision" since it is used in the body of the NVIC.  In the preamble to the towing rule, direct supervision USCG-1999-6224 states "...means physically present and more directly supervising the apprentice mate (steersman)."
This language should be imported into the NVIC, to assure that it is understood that the licensed officer is physically in the pilothouse with the apprentice at all times. The training of an apprentice/steersman does not relieve the watch standing responsibilities of the licensed Master/Mate/Pilot. 
Open
                                       

17-09
TS 70
With regard to Task Statement 70, and in response to the Coast Guard's question:  In NVIC 4-01, Change 1, should the Coast Guard clarify the terms "Training Officer" and "Designated Examiner" and cite the relationship between them?

MERPAC believes that the regulations clearly state that the operating authority of the 
apprentice mate (pilot) must be under the direct supervision of the master or mate/pilot of  the vessel.  While this supervisor is referred to in practice as the `training officer' there is no definition for this term.  Designated Examiner (DE) is defined in 46 CFR 10.104 and NVIC 4-01 and does not need further clarification.  MERPAC recommends that the Coast Guard should continue to educate training facilities and mariners that only a DE has the authority to sign any proficiencies listed on the TOAR. 
Closed
                                       

18-09
TS 70
With regard to the Coast Guard's request that MERPAC review each of the four TOARs which are enclosures for task statement 70 and offer proposed revisions.

MERPAC replied that TSAC is in the process of reviewing NVIC 4-01. A review of the TOARs is a part of this review process. Two TSAC members were present at the working group's deliberations and it was agreed that these recommendations would be carried to TSAC.
Open
                                       

19-09
TS 70
With regard to the Coast Guard's recommendation that TSAC and MERPAC should work together and submit recommendations to assist the Coast Guard in resolving the Apprentice Mate/Steersman training problems as well as the towing industry's mariner retention problems, MERPAC agrees.
Open
                                       

20-09
TS 70
With regard to the Coast Guard's questions: Should pilothouse training "Best Practices" include carrying a licensed Apprentice Mate/Steersman as an "extra man?"; When a towing vessel is safely moored, should the Apprentice Mate/Steersman be trained (and allowed) to relieve the licensed watch stander, and maintain the radio and security watch from the pilothouse, according to company policies and the night orders left by the aster?; and Should MERPAC promote "best practices" to comply with Congressional intent found in Section 312 of H.R.-2830 that would require "every inspected vessel to maintain an "Official Logbook" to be kept available for review by the Coast Guard on request?

MERPAC believes that best practices should be left to individual associations or companies.  
Open
                                       

21-09
MERPAC recommends that the U. S. Coast Guard investigate what has happened with the application of Captain John Lynskey to renew his license.  In addition, the Coast Guard should investigate why Captain Lynskey was told that he needed medical tests which are not enumerated in the recently revised Medical NVIC (04-08), specifically asking for family history.
Closed
                                       

22-09
TS 64
With regard to Task Statement 64, MERPAC recommends that no changes need to be made to existing tables of competence A-VI/1-5, VI/5 and VI/6, which are Maritime Security Awareness, Ship Security Officer and Persons with Designated Security Duties, respectively. We believe that the tables contain sufficient language to address the piracy threat.
Closed
                                       

23-09
TS 64
With regard to Task Statement 64, MERPAC feels that suppressing acts of piracy is not a merchant mariner responsibility, but rather a flag state's. If flag states abrogate that responsibility then we recommend that revisions to IMO Model Course 3.19 be made including description of the threat and reference to best management practices to respond to piratical threats and attacks.
Closed
                                       

23-09
TS 58
With regard to Task Statement 58, MERPAC repeats its recommendation that the time limit for mariners to submit additional information needs to be extended to 180 days.  We understand that this takes extra effort on the part of the Coast Guard, but believe that mariners, many who are away from home for extended periods, need to be given the extra time.
Closed
                                       

24-09
TS 58
With regard to Task statement 58, MERPAC recommends that the letters sent to applicants need to be revised to include the following suggestions:
   1. Letters requesting "additional supporting documentation and information" incorrectly state at this time that a "comprehensive review of safety/security, professional qualifications, and medical evaluation" has been completed, which is not correct.  The letter needs to either state a) which review has been completed, or b) needs to be sent to the mariner when all of the needed additional information is known.  The committee prefers that the mariner receive one letter, requesting all additional information needed resulting from all three reviews.
   2. Letters sent to first class pilots regarding their physicals submitted during the years between license renewals should state that their submitted physical requires additional information.  It should not state, as it does now, that their "application" has been reviewed, because they have not submitted an application at all.  
   3. Put requested information in the body of the letter, as an opening statement, rather than as an attached 2[nd] page.  The information requested should then be followed by the details of how to provide it, and the timeline.
   4. Last paragraph needs to make it clear that time extensions are welcomed, either in writing, or by phone or email for reasonable requests such as time to acquire information from physicians or mariners that are at sea.	
All requests for medical info should reference NVIC, sighting the medical condition and the medical tests results for that condition in the NVIC
Closed
                                       

25-09
TS 58
With regard to Task Statement 58, MERPAC recommends that the Coast Guard respond to mariners in a timely manner as the Coast Guard requires of the mariner.  When the Coast Guard receives a request for reconsideration or appeal, a letter should be sent to the mariner acknowledging receipt of request.  Follow up after 30 or 60 days stating that the review is still underway should be also sent.    

Closed
                                       

26-09
TS 58
With regard to Task Statement 58, MERPAC recommends that the Coast Guard should develop an equivalency for BST renewal for mariners that work on inland voyages that could meet the standards required by STCW to maintain competency in BST.  It is not acceptable to simply require the completion of a course when the mariner completes the same tasks as his seagoing contemporary.

   NMC should not be confusing a rating with the STCW certificate.  There is no reason to confuse the mariner's ratings with the limiting language when they do not have STCW.  A mariner's credentials should never be reduced because they do not have STCW; the mariner is already restricted from sailing on the STCW voyage by NOT having a STCW endorsement. A mariner that has received an Ocean license should never lose that ocean license because they choose not to renew a STCW certificate.    
Closed
                                       

27-09
TS 58
With regard to Task Statement 58, MERPAC notes that Capt. Stalfort mentioned in his responses that company and union physicians are being recognized by NMC employees as those who understand the medical concerns of the Coast Guard and demands on the mariners.  Using this knowledge, Coast Guard should move forward in recognizing certain physicians as "trusted agents", expediting the process, and establishing a realistic work load for the NMC.    
Open
                                       

28-09
TS 58
With regard to Task Statement 58, MERPAC notes that information posted on the NMC web site is very helpful to applicants.  NMC needs to post the missing checklists on NMC web site; i..e. 500 ton Mate Inland.
Closed
                                       

29-09
TS 58
With regard to Task Statement 58, MERPAC notes that paper applications need to be retained as an option, even after on-line applications, the "turbo tax" model, becomes viable.  Mariners should not be forced to use computer applications as their only option.  
Closed
                                       

30-09
TS 58
With regard to Task Statement 58, MERPAC appreciates that creation of the "Customer Service Center" as an alternate to the committee's suggestion of a mariner advocate.  We would like to receive a report at the next meeting regarding the success in customer satisfaction.  
Closed
                                       

31-09
TS 58
With regard to Task Statement 58, MERPAC feels that while the Medical NVIC is posted and available, there is insufficient explanation of the benefits of the NVIC, and no language to direct mariners to view it.  
Closed
                                       

32-09
TS 71
In light of the anticipated changes to 46 CFR Part 10 and STCW-78 as amended, MERPAC recommends postponing the review of the U.S. Coast Guard license examinations for 3[rd]/2[nd] Assistant Engineers until the new regulations come into force and effect. This postponement does not indicate MERPAC's belief that such a review is unnecessary nor is there an inference that the same methodology for review and analysis should be utilized.

The MERPAC working group will analyze 46 CFR Part 10 (Table 46 CFR 10.910-02, Deck Subjects) for alignment with the STCW-78 as amended. Discrepancies between the tables will be identified and detailed in an effort to improve the 3[rd]/2[nd] Mate examination modules considering current operating procedures, new technology and job task analysis.

Every effort will be made to identify subject areas in the NMC data bank that need to be enhanced while removing or modifying obsolete or outdated questions, as well as redundant subject areas.
Closed
                                       

33-09
TS 71
MERPAC recommends that the National Maritime Center in consort with the Maritime Academies and approved training facilities embrace electronic testing. The benefits to license candidates, the NMC, and training institutions are significant enough to commence beta testing at the earliest possible date. Benefits include but are not limited to: more diverse testing sites, improvements in testing formats and content, immediate examination results with tremendous accuracy and the possibility of reduced testing costs to the mariner and the Coast Guard.

Open
                                       

34-09
TS 71
MERPAC recommends that a regimented TQM process be utilized to maintain the relevance and accuracy of the data base. Participants in the TQM should include NMC, maritime educators and industry representatives observing the principles of PTP.
Open
                                       

01-10
NPRM T/C
Why are we commenting at this late date?
Over the years policy has been developed thru NVICs and policy letters to support the unfinished implementation of STCW.  MERPAC appreciates that this course may have been necessary and unavoidable, but the committee does not feel that any event in the past should limit our comments arising from our efforts to make the regulations correct in their application and harmonization with STCW now. I In addition, this is the first time that the committee has seen the proposed rule due to confidentiality of the regulatory process. We hope in the future that the advisory committees will be included earlier to help facilitate the process. 
Closed
                                       

02-10
NPRM T/C
MERPAC recommends that this rulemaking be merged, to include the results of the Comprehensive Review which will be concluded by the IMO in June 2010.  Rulemaking and regulation development is very difficult and time consuming. Unfortunately, this rulemaking has been overcome by events, namely the Comprehensive Review of the STCW, the changes that are about to be completed.  Time, money and personnel would be maximized by this delay.  This would also prevent the public and this committee from commenting on items that will immediately be modified by further revisions to the Code, such as medical provisions.  
The merger is recommended as a means of avoiding the potential waste of time and resources that would take place for government, industry, and training providers as these older amendments to STCW are implemented at the same time that new ones (2010 Amendments) are being finalized.
Closed
                                       

03-10
NPRM T/C
If the STCW NPRM rulemaking is merged with another rulemaking to include the results of the Comprehensive Review which will be concluded by the IMO in June 2010, MERPAC recommends that sea service should be accepted based on the applicability to the credential being sought rather than for a geographical area (for example service on a large laker on the Great Lakes should be deemed equivalent to service on a large vessel on the open ocean).
Closed
                                       

04-10
NPRM T/C
If the STCW NPRM rulemaking is merged with another rulemaking to include the results of the Comprehensive Review which will be concluded by the IMO in June 2010, MERPAC recommends that the medical certificate described in the 2010 amendments should only apply to those required to hold an STCW endorsement. (valid for only two years)
Closed
                                       

05-10
NPRM T/C
If the STCW NPRM rulemaking is merged with another rulemaking to include the results of the Comprehensive Review which will be concluded by the IMO in June 2010, MERPAC recommends that all methods for demonstrating competence listed in column three of the Tables in Part A of the STCW Code should be accepted, not just training--- the Convention is  COMPETENCY based.
Closed
                                       

06-10
NPRM T/C
If the STCW NPRM rulemaking is merged with another rulemaking to include the results of the Comprehensive Review which will be concluded by the IMO in June 2010, and In order for the regulations to be implemented quickly and smoothly, MERPAC recommends that the Coast Guard needs to make sure that those that will implement these regulations be involved in the process to make sure the new regulations can be implemented.
Closed
                                       

07-10
NPRM T/C
If the STCW NPRM rulemaking is merged with another rulemaking to include the results of the Comprehensive Review which will be concluded by the IMO in June 2010, and in order for the regulations to be implemented quickly and smoothly, MERPAC recommends that the amended STCW Code be used as the base language for the new regulations and amended as needed to fit US needs.
Closed
                                       

08-10
NPRM T/C
The following changes should be made to the definitions section of the STCW NPRM:
"Assistance Towing".  The addition of "for hire" is not clarifying as intended and should be deleted.  
 "Chief Mate".  Concern re: two watch system. Language too specific to large vessels with multiple mates and many smaller vessels do not actually carry a Chief Mate thus causing a myriad of problems including truncated career paths  -  delete new language
"competent" is not defined, and the Coast Guard should add this to the definitions.  
"competent person".   Definitions should be spelled out, not referenced to another section. There are other definitions where similar correction should be made.    
"Day" 100 ton not given 12 hour credit.  While possibly outside the scope of this project, the 12 hour policy of issuing 1 (1/2)  day credit should be extended to all mariners.  
"Designated examiner".  Should state "observed demonstration of proficiency and other assessments required for MMC's"  Should strike "training or" and leave "of assessment".  
"Domestic voyage"  Definition does not allow for domestic voyages that enter Canadian/Mexican waters.  Great Lakes voyages need to be included here as well.   
"Dual Mode/ATB/ITB" these definitions do not add clarification about which type of vessel is intended.  The Coast Guard should use industry verbage.  From one of the large tow companies, the following language seems appropriate:  Articulated Tug Barges (ATB) consist of a tank vessel (barge) and a large, powerful tug that is positioned in a notch in the stern of the barge. The tug propels and maneuvers the barge. Unlike an ITB (Integrated Tug/Barge) where the tug and barge are locked together in a rigid connection and became for practical purposes one unit, the ATB has an articulated or "hinged" connection system between the tug and barge, which allows movement in one axis, or plane in the critical area of fore and aft pitch. No such movement is possible with an ITB unit.
"1[st] Asst. Engineer" Delete 2[nd] engineer officer per STCW.  The committee feels that the effort to harmonize domestic and international terminology and standards is only causing more confusion.  The committee recommends that the Coast Guard return to the policy of completely separate structures of domestic and STCW. Create separate definitions for 2[nd] engineer and other STCW only terminology. Also delete "and who holds a valid officer endorsement as first assistant engineer"   
"Horsepower" definition needs clarification. See comment under "propulsion".
ITB/ATB definitions.  See above  
Invalid credential.  Coast Guard has not specified what deems a credential valid/invalid. The Coast Guard uses this term in many ways.  
"Lifeboatman" We believe that the term should be deleted and "Survival Craft Operator" would be more appropriate.  Two levels of "survival craft operator" should be created for 1) all survival craft or 2) limited to those vessels without lifeboats.  
"Lower level" Since the term "lower level" is only used to assess fees, the Coast Guard should either delete this term or find a more appropriate, less demeaning term.  The only licenses not covered under this term are unlimited.  Licenses are either unlimited or limited.    
"Management level" means "a level of responsibility within STCW" and should state as much..
"Near Coastal"  add "and its possessions" after ... waters off the United States.
"Operational Level". Should say vessel not ship to be inclusive of all vessels affected by STCW.  Should be consistent throughout this document, removing other "ship" references.  
"Oral assisted" MERPAC believes that only Coast Guard personnel at an REC approved and trained to administer these tests should provide an oral exam.  We do not believe this language "by CG examiner" captures the intent.  This language needs to assure that this can not be interpreted to include "CG approved examiner".
"Overriding Operating condition: needs to state "could not have been reasonably anticipated"
"Propulsion" needs to state that the manufacturers rating of the engine is where the "continuous-rated output" is sourced (or some other source as agreed, as long as each vessel is consistent in the language)
"Qualified rating" lifeboatman is an endorsement and should be noted as such.  
"QSS" the 2[nd] sentence should be struck, keeping 1[st] sentence only.  Not appropriate in definitions.
"Rest" The language should be deleted from  ", is not....to...port entry documents)" "Seagoing" replace with  Sea Service as defined in STCW Convention Reg I/1 par 1.25
"Senior Company official "change "on file at the Coast Guard".  
Closed
                                       

09-10
NPRM T/C
With regard to the text of the STCW NPRM, the Coast Guard should review the usage of the terms and add definitions, which are currently lacking, for "valid" and "valid for service". 
Closed
                                       

10-10
NPRM T/C
With regard to the text of the STCW NPRM, break the tables of exam topics into STCW vs. applicable to all, or somehow designate with an asterisk, etc. to eliminate confusion.  Also, review contents for true harmonization with the STCW concepts of Operational and Management Levels. More specifically, in the case of the deck officer, the Operational Level is a watchstander concerned with the "passage" and the next four hours. The Management Level is concerned with the overall "voyage" and with managing the Operational Level Officers and Ratings.
Closed
                                       

11-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.109, Ratings:
Adjust lifeboatman, survivalman per other recommendations regarding survival craft operators.  Delete "ratings" in (c) that are endorsements.  For example, a lifeboatman is not a person and is not a rating, it is an endorsement applied to a credential held by a person.   Also (b) .  Should say rating endorsements.   
(d) delete `STCW' before endorsements.  Add part 13.  (both locations)
Closed
                                       

12-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.205(h)(i) should be changed to read "he or she must meet the requirement' instead of "will only need to" 
Closed
                                       

13-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.215 (b) delete loss of one eye from this section, already in text.  Same with hearing test text.  
Closed
                                       

14-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.219, the user fee should be increased for the oral exam, since it takes more time from a trained individual to administer.

In 10.219(d)(3), change to say that cash is not accepted, only checks, CC and money orders.
Closed
                                       

15-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.225(b)(2), should delete 30 days.  Proof of holding/applying for a TWIC is sufficient.  Not the mariners fault if they are hung up.   

In 10.225(b)(7), retain previous language of "CG approved form" which allowed mariners to submit other forms as appropriate.
Closed
                                       

16-10
NPRM T/C
With regard to the text of the STCW NPRM, , in 10.227(e)(8)(i)(D) add elaborating language on "position closely related to the operation..."  as current language is proving insufficient.  Concern for instructors/examiners as well as port captains/port engineers being recognized as providing "closely related service".

In 10.227(e), clarification of continuity document procedures is needed.  What exactly is in continuity anyway? It appears that the license is in continuity but the STCW certificate/endorsement goes up in smoke.  

In 10.227(e)(2)(ii), delete "An application including..."

In 10.227(d)(8)(D)(vi), clarification is needed on towing renewal language.

In 10.227(g), change reference (g) to (d) in text body.
Closed
                                       

17-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.229, delete reference to April 15, 2009, it is unnecessary.  Research and delete as appropriate April 15, 2009 reference.  Change to "demonstrate possession of a valid TWIC".
Closed
                                       

18-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.231(c), with regard to the  reference to physical in the last 3 years for renewal. Seems like this should be either 1 year, or 5 years, not 3.  
Closed
                                       

19-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.235(d), delete (2[nd] to last line) needs to read "...will be issued a replacement MMC reflecting the remaining endorsements".
Closed
                                       

20-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.302(d)(2), strike 12 month expiry.  5 year expiry is sufficient. 

In (d)(5), clarification is needed. Create a new section to address change in management and name change of school, notify NMC of changes.

In (b)(7)(iii) course surveys, delete "and employers".
Closed
                                       

21-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.303 (a)(3) should read "Give written examinations to each student appropriate for the course material and should be equivalent in scope and difficulty of an examination prepared by the Coast Guard based upon the knowledge requirements of the position or endorsement for which the student is being trained;"

In 10.303(a)(7), either move to QSS or delete

In 10.303(a)(8), either move to QSS, delete employer, or make optional

In 10.303(a)(9)(iv), delete "including the substitution of an applicable Coast Guard exam"  

Delete 10.303(b)(1)(vii).
Closed
                                       

22-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.304:

10.304 b this sentence conflicts with current practice and needs to be corrected.  There are exceptions, such as PIC can take course for recency and others.

10.304 (c) delete
       (d) (2)(3)  requirements are redundant with STCW code, and should be deleted. Should insert language that says training record book will cover knowledge, training, and proficiency on Part A. 

The committee suggests that 10.304 be rewritten, and that the following language be used:

§ 10.304  Substitution of training for required service, use of training-recordbooks, and use of towing officer assessment records.

(a)  Satisfactory completion of an approved training course may be substituted for a portion of the required service on deck or in the engine department for deck or engineer endorsements.  Satisfactory completion of an approved training program which includes sea service may be substituted for all of the required service on deck or in the engine department, except as limited by law for ratings.  The list of all currently approved courses of instruction, including the equivalent service and applicable endorsements, is maintained by the NMC.

(b)  Recency requirements may not be achieved by service granted as a result of successful completion of approved training or by training on a simulator; however, underway service obtained as a portion of an approved course or program may be used for this purpose. 

(c)  Training obtained before receiving an endorsement  should be used for any subsequent raises of grade, increases in scope, or renewals as appropriate.

(d)  A training-record book required as part of an approved training program for OICNW and OICEW must contain at least the following:

(1)  The name of the applicant;

(2)  The knowledge, understanding or proficiency (KUP)  to be assessed, with reference to the standards set forth in the tables of the appropriate sections in part A of the STCW Code (incorporated by reference in § 10.103);

(3)  A place for a qualified instructor to indicate by his or her initials that the applicant has received training  or demonstrated proficiency in the particular KUP; 

(4)  A place for a designated examiner to indicate by his or her initials that the applicant has successfully completed the relevant assessment, when assessment of competence is to be documented in the record books;

(5)  The name of each qualified instructor, including any MMC endorsements held, and the instructor's signature; and

(6)  The name of each designated examiner, when any assessment of competence is recorded, including any MMC endorsement, license, or qualifications, and the examiner's signature confirming that his or her initials certify that he or she has witnessed the assessment of knowledge and/or the practical demonstration of a particular task or skill by the applicant.

(e)  The training-record book referred to in paragraph (d) of this section may be maintained electronically, provided the electronic record meets Coast Guard-accepted standards for accuracy, integrity, and availability.

(f)  Each applicant for an endorsement as master or mate (pilot) of towing vessels, and each master or mate of self-propelled vessels of 200 GRT/500 GT or more, seeking an endorsement for towing vessels, must complete a towing officers' assessment record (TOAR) that contains at least the following:

 (1)  Identification of the applicant, including his or her full name, home address, photograph or photo-image, and personal signature;

(2)  The knowledge, understanding or proficiency (KUP)  to be assessed, with reference to the standards set forth in the tables of the appropriate sections in part A of the STCW Code (incorporated by reference in § 10.103);

(3)  A place for a qualified instructor to indicate by his or her initials that the applicant has demonstrated proficiency in the particular KUP; 

(4)  A place for a designated examiner to indicate by his or her initials that the applicant has successfully completed the relevant assessment, when assessment of competence is to be documented in the record books;

(5)  The name of each qualified instructor, including any MMC endorsements held, and the instructor's signature; and

(6)  The name of each designated examiner, when any assessment of competence is recorded, including any MMC endorsement, license, or qualification, and the examiner's signature confirming that his or her initials certify that he or she has witnessed the assessment of knowledge and/or the practical demonstration of a particular task or skill by the applicant.

(g)  The TOAR referred to in paragraph (d) of this section may be maintained electronically, provided the electronic record meets Coast Guard-accepted standards for accuracy, integrity, and availability.
Closed
                                       

23-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.305(b), insert "proper course for assessment".  Also how is the CG going to implement?
Closed
                                       

24-10
NPRM T/C
With regard to the text of the STCW NPRM, in 10.307, add to end "...or contact NMC."  
Closed
                                       

25-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.213, language in the proposal is too restrictive and does not give credit that is needed to allow military officers to utilize quality training and sea service. The Coast Guard needs to develop an equivalency table for military personnel to demonstrate equivalent service.  It will need to be sufficiently detailed to establish job tasks and actual underway time for application.
Open
                                       

26-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.401(h) the reference to 11.426 should be 11.424.
Closed
                                       

27-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.401(i), delete "practical".    
Closed
                                       

28-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.407(a)(1), "seagoing" vessels should be deleted. The language in this provision does not meet the language of the code.  Does not meet the requirement of the code that requires six months of  bridge Watchkeeping duties...should delete 6 months of time while holding an A/B time or hold the rating RFPNW.

(b) should state "seagoing service".  
Closed
                                       

29-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.467, Puerto Rico exception for OUPV should be required to know standard maritime phrases and communications in English.
Closed
                                       

30-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.502(d), delete or fix OR  delete 11.508/11.509 but leave vessels less than 10,000?
Closed
                                       

31-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.509, add text suggesting that language be inserted that amends (b) so that as soon as this provision is changed in the STCW Code that it will be changed here.  
      Or        3/1 para 2.3
      (b) insert language "as applicable"
      (b)(1)(x) and (xi) combined "basic working knowledge of  relevant international conventions".
Closed
                                       

32-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.505(a) there is an error.  Add path from DDE and Asst. Eng. into 4000. Should add 10,000 also. Invoke article 9 to resolve career path problems.  
Closed
                                       

33-10
NPRM T/C
With regard to the text of the STCW NPRM, Table 11.505(a) needs to be harmonized with the written text of 11.509, and currently it is not.
Closed
                                       

34-10
NPRM T/C
With regard to the text of the STCW NPRM, 11.507 is too detailed, please refer back to previous recommendation on content from MERPAC.
Closed


35-10
NPRM T/C
With regard to the text of the STCW NPRM, reiterate previous recommendation so that an engineering officer must have sea service as 1[st] asst. eng. prior to serving as chief.  (same on deck side)  Assure a path from engineering officer to chief.  
Closed
                                       

36-10
NPRM T/C
With regard to the text of the STCW NPRM, MERPAC believes that there should be consistency and a harmonization of standards between deck and engine that does not currently exist.
Closed
                                       

37-10
NPRM T/C
With regard to the text of the STCW NPRM, 11.520 needs some reference to non-STCW.  Add E/F vessels in a new (c)
Closed
                                       

38-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.525 reorder (b) and (c) for consistency.
Closed
                                       

39-10
NPRM T/C
With regard to the text of the STCW NPRM, 11.551 needs to be clarified in preamble on intent of meeting the language of 11.553(b)
Closed
                                       

40-10
NPRM T/C
With regard to the text of the STCW NPRM, in 11.901(c) delete "through practical demonstration of professional skills".
Closed
                                       

41-10
NPRM T/C
With regard to the text of the STCW NPRM, in Table 11.910-2, the Coast Guard should review to ensure that topics are separated appropriately for management vs. operational as per the STCW. 
Open
                                       

42-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.410, update the categories of A/B endorsements as per the statute.
Closed
                                       

43-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.412, delete "survivalman."

MERPAC believes that English language requirements and standard maritime communications should be required of all ratings and officers as stated in the A/B regulations.  

Closed
                                       

44-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.420, see previous language about difficulties in obtaining service to the requirement for seagoing service set by U.S., so inland service is disregarded: see definition of seagoing service in STCW where it is clear that inland or seagoing or tonnage is not discussed and not differentiated. This issue is global throughout this NPRM and is a barrier to entry that should be removed.
Closed
                                       

45-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.420, suggested language needed on seatime service.  "service on board a ship relevent to the issue of a certificate or other qualification'.

MERPAC recommends that (c)(1)(ii) be deleted.
Closed
                                       

46-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.610, the number of drills and in water requirements are excessive, and MERPAC recommends that they be reduced.

Delete (c)(2) which requires participation in abandon ship drills, which must include the boat being placed in the water and being exercised in all means of propulsion.  

(d) should say "course/program ....that includes a prescribed period of sea service and BST".
Closed
                                       

47-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.620(c) drop the required number of exercises.
Closed
                                       

48-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.630(c)(2), the number of drills and in water requirements are excessive, and MERPAC recommends that they be reduced.

(d) should say "course/program ....that includes a prescribed period of sea service and BST".
Closed
                                       

49-10
NPRM T/C
With regard to the text of the STCW NPRM, in 12.704, add steward department as an additional rating. First two sentences can be combined.
Closed


50-10
NPRM T/C
With regard to the text of the STCW NPRM, regarding 15.1103(b), 15.403(c), and 15.404(a), should read as follows: "All require a person serving as RFPNW to hold an STCW endorsement attesting to his or her qualifications to perform those functions.  Those qualifications require 6 months of service, which can be reduced to a minimum of 60 days if the person has completed an approved course.

In practice this means that a person seeking entry level employment cannot legally serve as a watchstander until he or she has obtained at least 60 days in a supernumerary position -- provided that they have completed a course which is difficult to find and expensive to attend.  This is not what you would call a job stimulus provision.

Adding to the barriers created by the STCW standards are interpretations imposed by the Coast Guard in Policy Letter 14-02 (which would be codified in proposed 12.420) that require at least one-half the sea time to be on vessels of at least 200 GRT.  Beyond that, the assessments for helm commands must now be performed on vessels of at least 100 GRT.  These provisions mean that individuals who already have considerable experience on smaller vessels cannot use their service to qualify as RFPNW and apply for positions on larger vessels.  Because qualifying service must be on seagoing vessels, mariners from the inland segment of the U.S. merchant marine are denied the opportunity to move offshore without having to go through the convoluted qualification process.  STCW states in Chapter I under definitions that  "Seagoing  service means service on board a ship relevant to the issue of a certificate or other qualification". Thus it is clear that the Administration can decide what is or is not relevant. We have seen too many careers thwarted or never started due to the interpretations and language used. Many other countries provide liberal interpretations and thus promote seagoing opportunities and careers. 

Recognizing the difficulties presented by these provisions and other aspects of the 1995 amendments, the Secretary of Transportation at the time of the implementation of the current regulations declared that the Coast Guard would utilize the flexibility afforded by the Convention to mitigate some of the adverse effects.  To that end, the Coast Guard stated that tonnages in the Convention would be applied as gross register tonnage for vessels in U.S. domestic service.  Accordingly, the "trigger tonnage" of 500 gross tonnage for applicability of Regulation II/4 was to be interpreted as 500 GRT, as confirmed in a letter signed by the Chief of Marine Personnel in 1999, which states:

   ...vessels of not more than 500 gross register tons on near coastal, domestic voyages will not be required to have seamen qualified as ratings forming part of a navigational watch because that STCW rating does not apply to vessels of less than 500 gross tons.

In view of the above, MERPAC recommends that the Coast Guard honor the agreement reached in 1999 and make the requirements for RFPNW applicable to vessels over 500 GRT/1200 ITC in domestic service.  Vessels in international service will be bound by the STCW standard set at 500 GT(200 GRT).

Closed
                                       

51-10
NPRM T/C
With regard to the text of the STCW NPRM, it is also recommended that 12.420(c)(1)(ii) be deleted, that the assessment of helm commands be permitted on any vessel of more than 50 GRT and service on inland waters be acceptable to qualify for an assessment.
Closed
                                       

52-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.404(i), add Stewards rating.
Closed
                                       

53-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.405, "crewmember" should be deleted and the term "credentialed crewmember" should be used. 
Closed
                                       

54-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.530(a), add language to assure citation stays current by altering as follows "ILO Convention or subsequent convention...."  There must be a means of referencing the latest amendments to or version of such international conventions without going through laborious and glacial rulemaking processes. Often enough the process takes so long that newer versions have already overtaken events, as in the case of the 2010 amendments to the STCW.
Closed
                                       

55-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.805(a)(5), change item to read "command as Master", vs. "under the command of."
Closed
                                       

56-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.815, clarify "Valid" endorsement for radar.  Add that school can send proof of completion.
Closed
                                       

57-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.845, lifeboatman and survivalman.  Global search for this term and remove and replace per previous recommendation.

Closed
                                       

58-10
NPRM T/C
With regard to the text of the STCW NPRM, in  15.915 (a)(2), reference to 15.103(2) is wrong: should be 15.103E and F

In 15.1101 Delete (c).
Closed
                                       

59-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.1103, second engineer needs to include "officer"  Correct typo first (e) should read (d).
Closed
                                       

60-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.1111, change title to Rest Periods, delete Work hours from title.  Work hours already addressed in 15.701 Work Hours.
Closed
                                       

61-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.1105, Master's obligation to check competency?  

In (b)(2), change "or" to "and".
Closed
                                       

62-10
NPRM T/C
With regard to the text of the STCW NPRM, in 15.1113, Delete 1 July 09 date.
Closed
                                       

63-10
NPRM T/C
With regard to the text of the STCW NPRM, in Part C, change title to "approved courses and programs.
Closed
                                       

64-10
NPRM T/C
                        Proposed Engineer Career Paths

We appreciate the opportunity to suggest an alternative to the Coast Guard's proposed qualification procedures for engineer officer endorsements at the 4,000 HP and 10,000 HP levels.  

Background Information

Our alternative is predicated on these issues:

   1.    A credential at the 4,000 HP level has no value and should be eliminated to reduce confusion and complications in the licensing scheme.  As proposed in the NPRM, a mariner seeking a "restricted HP" credential is forced to enter the advancement path by applying for assistant engineer 4,000 HP, a position for which there is little demand and even fewer billets.  The path from there to a useful credential at the 10,000 HP level requires 3 transactions and completion of as many as 3 training regimens to meet the standards of Regulations III/1, III/2, and III/3 of the Code.  We believe the OSV Engineer provisions and our proposed path to a 10,000 HP credential will satisfy anyone who might have found a 4,000 HP endorsement useful.  
   
   2.    At the very least, it is essential to permit mariners to enter the path to a 10,000 HP credential directly because vessels over 4,000 HP represent the overwhelming majority of the STCW impacted fleet.  That is where the jobs are, and those are the vessels that will provide the most relevant experience.  Accordingly, our proposal provides a path to an original endorsement at 10,000 HP.
   
   3.    Because very few of the vessels affected by the proposed structure are required to carry two credentialed engineers, it will be impossible for many applicants to document time "while serving as an assistant engineer."  To keep this from being an impenetrable barrier to employment and advancement merely because a person was performing OICEW duties on a vessel not required by the COI to carry an assistant engineer (or any engineer, in the case of towing vessel), we recommend inserting a statement in 11.502 stating something to the effect of:  "Sea service obtained while performing the duties of a engineer officer shall be accepted for any transaction whether the person was serving in a position required by a vessel's Certificate of Inspection or in excess of required staffing." 
   
   4.    It is essential to retain the existing qualification path to OSV engineer credentials as they are now authorized by the current regulations in 46 CFR 11.553 and 11.555 and by Policy Letter 07-00.  The existing paths to these credentials meet the intent of STCW through the equivalency provisions of Article IX, provide a practical way for mariners to pursue a career in the engine department of OSVs in domestic waters, and promote competence through a structured training and assessment program.  Retaining a viable route to OSV credentials will accommodate mariners on OSVs operating domestically without limiting horsepower.  We also see the OSV endorsement path as a "feeder" to 10,000 HP credentials.  (It is important to note that the current qualification requirements for OSV credentials are the same as the DDE standards in existing 46 CFR 11.524.  Some reference to those standards is needed in the final rules.)  
   
   5.    It is also essential that DDE and Engineer (Limited) credentials issued before the effective date retain the authority that was in force when the original endorsement was issued.  Proposed 11.501(j) appears to provide that protection for the existing pool of qualified officers, but a person reading proposed 15.915 in the future may question that authority.  To avoid confusion, we recommend strengthening 11.501(j) by adding the words, "Notwithstanding the provisions of 15.915(a)(2)" or clarifying the wording of 15.915 by repeating the intent of 11.501(j).  To further reduce confusion either the current DDE with STCW or the future non-STCW DDE should get a new credential title to allow obvious distinction between these similar sounding but radically different qualifications.  We recommend all holders of a DDE and STCW endorsement issued under the current requirements be issued an endorsement as Chief Engineer, limited to vessels less than 500 GRT/1200 GT with any HP or route limitation currently held at their next credential transaction.
   
   6.    These changes will have a massive impact on mariners, schools, and vessel operators.  Mariners who now hold credentials or who are nearing completion of their service requirements could be unjustly penalized for the career decisions and personal commitments they made based on the current rules.  Schools will likely need at least 18 months after the publication date to develop the multiple new courses and 6 months to go through the approval process; then students will need at least another 18 months to schedule and complete whatever training may be required.  That means it is probable that no one will be qualified for the issuance of an engineer credential for 4-5 years after the publication date.  Considering the long standing engineer shortage coupled with the aging (and retirement eligible) pool of current engineers, it is essential to minimize the hardship on mariners and the disruption of the industry.  We recommend that individuals whose service began before the effective date be eligible to apply for DDE along with STCW endorsements under existing regulations governing the qualification standards and the authority of the endorsement for a period of at least five years.  Other recommendations regarding conversions are listed in the qualification provisions section of this report.
   
   7.    With regard to the proposed engineer training and assessment, we assume and recommend that any topics that are appropriate for onboard training can be approved for delivery in that manner, vice formal classroom training, provided the material is presented in accordance with the standards of proposed Subpart C.

Training Requirements

We recommend the following topics for the operational level in the 10,000 HP category, which are drawn from Table A-III/1 of the Code:

   Use appropriate tools, including:
   Hoisting and pulling tools
   Power tools and equipment for repairs and fabrication
   Hand tools for dismantling, inspecting, repairing and reassembling equipment
   General and special measuring equipment
   
   Use machinery drawings and handbooks, including:
   Technical manuals and machinery drawings
   Locate and use relevant manuals and interpret drawings, diagrams, sketches and instructions.
   
   Use electrical and electronic measuring and test equipment, including:
   Follow lock-out, tag-out procedures and policies
   Use electrical measuring and testing devices 
   
   Maintain a safe engineering watch, including:
   Take over and accept a watch
   Perform routine duties undertaken during a watch
   Maintain machinery space logbook
   Watch change over procedures
   Safety and emergency procedures
   
   Operate main and auxiliary machinery
   
   Operate pumping system and associated controls, including:
   Fuel transfer
   Bilge, ballast, and cargo pumping systems
   
   Operate alternators, generators and control systems
   
   Maintain marine engineering systems, including: 
   Control systems
   Knowledge of machinery space and plant arrangements of components, equipment, associated piping and control systems
   Lock-out, tag-out procedures
   Maintenance of auxiliary machinery
   
   Control the operation of the ship and care for persons on board
   Stow and secure deck cargoes, including cargo-handling gear and lashing equipment
   Understand and apply relevant domestic regulations and international conventions

For the management level, we recommend making the following changes to the topic list of the 13 items in proposed 11.511.  

   1. Management skills  -  Delete because most of the subtopics are the purview of a company's shoreside HR department and are not germane to the engineering profession.  Items related to effective management of shipboard personnel in a working environment can be addressed more appropriately in the engineroom resource management subtopic of item 2.
   2. Application of principles in crisis management  -  Retain.
   3. Organizing and preparing for shipyard repairs and inspection  -  Retain.
   4. Preparing for regulatory and class society inspections and surveys  -  Retain.
   5. Assessing skills through performance-based demonstration  -  Delete because this would be addressed if the individual were to become a designated examiner.  If the individual or his company chooses not to make this a part of the individual's skill set, it should not be mandated.
   6. Implementing and updating a plan for engine-room operation and familiarization for new employees  -  Because this item had no subtopics in the proposed rule we assume that it was as confusing and ambiguous to the regulation writer as it is to us.  We think that whatever it might be can be addressed in item 7.  Delete.
   7. Developing and maintaining internal documents  -  Retain.
   8. International laws and conventions  -  Retain.
   9. Stability and damage control  -  Retain.
   10. Technical analysis -- operational condition of systems  -  Retain.
   11. Management/oversight of preventive and predictive maintenance  -  Retain.
   12. Principles of troubleshooting  -  Retain.
   13. Review of major engine-room casualties  -  This is an excellent subtopic for item 2.  We recommend that it be deleted as a separate item but addressed in item 2.

Qualification Standards

We recommend the following qualification standards (not including general requirements such as BST, Medical Care Provider, PSC, etc.)

For Assistant Engineer, 10,000 HP Near Coastal
36 months of engineroom service.
6 months of the service must be on vessels over 1,000 HP/750 kW.
Complete training and assessment in the operational topics outlined above.

For 1[st] Assistant Engineer 10,000 HP Near Coastal
12 months of engineroom service while holding an endorsement as Assistant Engineer, of which 6 months must be on vessels over 1,000 HP/750 kW.
Complete training and assessment in the management level topics outlined above.
The holder of this endorsement is also qualified for an endorsement as Chief Engineer Unlimited HP (OSV).
The holder of an endorsement as Chief Engineer Unlimited HP (OSV) may obtain this endorsement upon completion of training in the management level topics.  

For Chief Engineer, 10,000 HP Near Coastal
12 months of engineroom service performing the duties of an engineer at the operational or management level while holding an endorsement as 1[st] Assistant Engineer, of which 6 months must be on vessels over 1,000 HP/750 kW. 
The holder of this endorsement is also qualified for an endorsement as Chief Engineer Unlimited HP (OSV) on vessels of 3,000 GT or more.
The holder of an endorsement as Chief Engineer Unlimited HP (OSV) may obtain this endorsement with 12 months of service in a chief engineer capacity and completion of management level training.

Conversion provisions

A person holding an endorsement as Chief Engineer Limited (Oceans) based on service obtained before the effective date may qualify for Chief Engineer 10,000 HP by providing evidence of 12 months of sea service performing the duties of an engineer at the operational or management level OR completing training in management level topics.

A person holding a endorsement as Chief Engineer Limited (Near Coastal) based on service obtained before the effective date may qualify for 1[st] Assistant Engineer 10,000 HP by providing evidence of 12 months of sea service as an engineer at the operational or management level OR completing training in management level topics.

Holders of an endorsement as DDE Unlimited HP based on service obtained before the effective date should retain their endorsements and authority as per proposed 11.501(j) and should also be issued Chief Engineer, 10,000 HP upon obtaining 12 months of sea service as an engineer OR completing management level training.  This does not represent an increase in grade; it only increases the scope of their authority to vessels larger than 500 GRT/3000 ITC while limiting their route to near coastal waters.


Closed
                                       

65-10
T/S 30
In light of a new Commandant coming onboard this summer, it is once again a recommendation of this committee that a letter from MERPAC be sent to the Commandant highlighting the ongoing work to assist military veterans with meeting the requirements of the STCW Convention.  The Commandant needs to know of the great strides that have taken place within the Army's training system to enable their people to transition into the merchant marine industry.  In fact, the U.S. Army has Coast Guard approved programs for their people.  The Navy has had some success with this endeavor but the Coast Guard is not onboard
Closed


66-10
T/S 30
MERPAC encourages the new Commandant to initiate steps to bring the U.S. Coast Guard training (The Coast Guard Academy to be included) into compliance with the U.S. Coast Guard mandated training for the U.S. maritime industry.
Open
                                       

67-10
T/S 30
MERPAC further recommends that the new Commandant direct a contact within the Coast Guard to reach out to counterparts in the Marine Corps and Navy to bring their own maritime related training into compliance with Coast Guard approved training.
The outcome of this MERPAC request is to give U.S. service personnel, who are transitioning out of the military, credit for their military service and training towards receiving U.S. Coast Guard required training for a career in the merchant marine industry.
Closed
                                       

68-10
T/S 30
MERPAC recommends that all active duty military personnel holding a valid military ID be allowed to use this in lieu of a TWIC.
Closed 
                                       

69-10
T/S 64
MERPAC believes that the implementation of the 2010 Amendments to STCW must be accompanied by a comprehensive overhaul of the corresponding license examinations as the gap between the two will soon widen to the breaking point. For example, archaic (electronic) navigation questions need to be replaced by up to date ECDIS questions.  Grandfathering is necessary for a smooth implementation. Such grandfathering should include the sea service gained before the effective date of these 2010 Amendments.  There will be a number of problems experienced as seafarers now face assessments and sign-offs on vessels where no one has STCW certification and cannot really be considered qualified to assess or sign off. There will need to be liberal translations of this for some period of time to prevent a chicken and the egg dilemma.
Closed
                                       

70-10
T/S 64
With regard to Chapter II:  II/1 Celestial Navigation- MERPAC believes that a proper implementation of the 2010 amendments would call for the USCG to revise the celestial navigation requirements on the license exams so that they reflect the international decision to consider celestial as a "back-up" navigation method. This would include lowering the passing scores in this area, the allowance of solutions by navigation or programmable calculators and the reduction of questions to only those deemed critical given the guidance in Part B of the Code.
Closed
                                       

71-10
T/S 64
With regard to Chapter II:  II/1 and II/2 Resource Management- MERPAC believes that the new requirements concerning resource management can be implemented with little fuss. New assessment criteria and control sheets can be created to facilitate this process. Assessment methods given in the Code should all be acceptable to USCG. MERPAC still believes (as recommended once before) that resource management should include the whole vessel and not just the bridge.
Closed
                                       

72-10
T/S 64
With regard to Chapter II:  II/1, II/2 and II/3 ECDIS- MERPAC believes that the ECDIS requirements are reasonable and should be implemented as written. There are a wide variety of schemes to arrive at the necessary level of competence and the USCG needs to be flexible in their approval practices. More specifically, not every training program will have a stand-alone ECDIS course nor is one necessary to achieve the desired end. ECDIS can be taught in segments in a number of navigation and electronic navigation courses. The addition of this new material underscores the need to revise the license exam questions and bring them up to date while dropping archaic questions.
Closed
                                       

73-10
T/S 64
With regard to Chapter II:  II/5 Able Seafarer Deck- The tables of competence are straightforward and should be implemented through the creation of standardized assessment criteria and control sheets. However, the language concerning sea service gives rise to considerable concern. MERPAC believes that it is beyond unfortunate that the requirement for "qualification" as RFPNW must occur before the sea service clock toward Able Seafarer begins ticking. This requirement is totally at odds with current domestic regulation and practices making it easier to get such an endorsement in the inland service; thus penalizing those seafarers that sail beyond the boundary line. In particular, it will directly impact the ability of academy cadets to receive an able seafarer's endorsement without incurring additional sea service requirements, requirements that no academy can meet. Graduating without the endorsement is not an acceptable alternative. The increase in STCW sea service requirements over today's practices for a similar domestic endorsement is indefensible. MERPAC believes that the USCG must find a solution to the problems posed by the language in this part. Perhaps the USCG can start the AB sea time clock ticking based upon the "RFPNW limited to lookout only" that can be achieved through pre-sea training.
Closed
                                       

74-10
T/S 64
With regard to Chapter III:  III/1 Sea time for OICEW- MERPAC believes that the requirement for 6 months of engine room watchkeeping under the supervision of an officer is nearly impossible without a liberal definition of watchkeeping. It must be defined to include periodic monitoring as too many engine rooms are unmanned and a traditional watch is not being kept. Reference should be made to Section A-VIII/2 Part 4 para. 52.
Closed
                                       

75-10
T/S 64
With regard to Chapter III:  III/1 Resource Management, MERPAC believes that the new requirements concerning resource management can be implemented with little fuss. New assessment criteria and control sheets can be created to facilitate this process. Assessment methods given in the Code should all be acceptable to USCG. MERPAC still believes (as recommended once before) that resource management should include the whole vessel and not just the bridge.
Closed
                                       

76-10
T/S 64
With regard to Chapter III:  III/5 Able Seafarer Engine, the tables of competence are straightforward and should be implemented through the creation of standardized assessment criteria and control sheets. However, the language concerning sea service gives rise to considerable concern. MERPAC believes that it is beyond unfortunate that the requirement for "qualification" as RFPEW must occur before the sea service clock toward Able Seafarer-Engine begins ticking. This requirement is totally at odds with current domestic regulation and practices making it easier to get such an endorsement in the inland service; thus penalizing those seafarers that sail beyond the boundary line. In particular, it will directly impact the ability of academy cadets to receive an able seafarer's endorsement without incurring additional sea service requirements, requirements that no academy can meet. Graduating without the endorsement is not an acceptable alternative. The increase in STCW sea service requirements over today's practices for a similar domestic endorsement is indefensible. MERPAC believes that the USCG must find a solution to the problems posed by the language in this part. 
Closed
                                       

77-10
T/S 64
With regard to Chapter III:  III/6 and III/7- Training and certification for ETO and ETR should be optional for seafarers and a low priority for the USCG as there are few merchant vessel personnel in the U.S. that might need such certification. Given that there are no unique or odd assessment methods, there should be few problems in implementing the terms given in these sections. The development of assessment criteria and control sheets should be done but these should be delayed until all others are completed. A wide variety of courses, training programs and in-service experience should be accepted by the USCG. Again, however, MERPAC recommends that until all other portions of the 2010 Amendments are implemented, USCG resources should not be obligated to address these requirements. Instead, industry should submit training courses and/or programs for approval.  Finally, there is a concern by MERPAC members that implementation of these sections domestically and worldwide might, over time, give rise to manning requirements and/or Port State Control issues. MERPAC believes the USCG needs to make every effort to exercise the necessary vigilance to make sure neither of these scenarios happens.
Closed
                                       

78-10
T/S 64
With regard to Chapter V:  Tanker Personnel- MERPAC believes that the basic and advanced categories shown in the 2010 Amendments should be adhered to but that there is no need to change the present U.S. structure with only two categories; namely, DL or LG to the three categories proposed by STCW; the reason being that the differences in the proposed language of STCW Tables of Competence for Tanker Personnel is not substantially different from the present U.S. requirements.
Closed
                                       

79-10
T/S 64
With regard to Chapter V:  MERPAC should review the tables of competence for oil and chemical and provide the USCG with the delta so that the course providers can see what in their DL course might need to be changed to cover the STCW requirements. It is further recommended that the USCG accept the advanced level course (PIC) as subsuming the topics shown in the basic level (assistant) so that anyone successfully completing the advanced course would not have to go back to take the basic course.
Closed
                                       

80-10
T/S 64
With regard to Chapter V:  Sea time is a more disturbing topic and needs further discussion as does the matter of revalidation. Recommendations will be made at the Fall 2010 meeting.
Closed
                                       

81-10
T/S 64
With regard to Chapter V:  Tanker firefighting  -  accept the BST version.
Closed
                                       

82-10
T/S 58
MERPAC encourages the Coast Guard to continue to pursue a change in the policy which does not currently accept domestic (inland/Great Lakes) sea time for acquisition and renewal of STCW credentials.  MERPAC believes that this domestic sea time should be acceptable as long as it meets the standards of the credential being sought.  
Closed
                                       

83-10
T/S 58
MERPAC encourages the Coast Guard to prioritize the project to revise all the application form letters and assure that the information being sent to mariners is as accurate as possible.
Closed
                                       

84-10
T/S 58
MERPAC encourages the NMC and policy office to assure that mariners' domestic credentials are not being defined and limited by the possession of STCW endorsements.  We believe that the Coast Guard was incorrectly inserting this language onto licenses when the STCW certificate was a separate document, and this is not appropriate now that the credentials have been combined into one document.
Closed
                                       

85-10
T/S 58
MERPAC recommends that the NMC move forward to formalize the relationship between physicians who complete physicals and the physicians at the NMC.  A program should be developed to bring physicians together to provide training in: physical demands on the mariners; the difference between medical care for mariners and the concerns of the NMC with its obligation to assure public safety; and completion of the forms and communication with the NMC.  Once the program has begun, the NMC should include a list on its web site of those physicians who have agreed to have their information posted so that mariners have the option to seek out these physicians.  We believe that by training these physicians, the overall medical review system will be better.
Open
                                       

86-10
T/S 58
MERPAC recommends that a task statement be promulgated to activate the workgroup that drafted the Medical NVIC and begin a review and update of the documents.  This should be a standing task statement for continuous review.  The original task statement chose a NVIC as the tool for communication based on the assumption that it would be reviewed and updated.  Until the MMMAC is created, MERPAC should continue this work.  The NMC will provide data about the numbers of each condition applied for and the determination of those applications.  Additionally, a review should be conducted of medical tests being submitted at great cost to the mariners that resulted in an approved credential with no limitations, to determine if the request for those tests was appropriate, and justified the expense of the tests.  With this information, the working group could recommend the addition and/or removal of conditions.  MERPAC should also create a new tool, possibly an addendum to the NVIC, to provide further education to mariners and physicians on items that the NMC considers unallowable/unfavorable.  As a 3rd deliverable, the CG-719K and CG-719K/E forms need to be reviewed and amended, including specifically a review of the language that collects a "medical history" that conflicts with the parameters and "look back" period for medical conditions defined in enclosure (3) of the NVIC.  The work of this group should also ensure that letters to mariners requesting additional information reference enclosure (3) of the Medical NVIC.  Additional testing being requested that is currently NOT in the NVIC should be reviewed and included or stopped.  Include in discussion requests for pharmacy records and medications that are not acceptable.  Mariners need to know what medications may be substituted as acceptable.  
Closed
                                       

87-10
T/S 58
MERPAC recommends that the NMC review the current fee structure and consider whether mariners can be charged one fee instead of the `smorgasbord' of fees to choose from.
Open
                                       

88-10
T/S 58
MERPAC recommends that the Coast Guard advise mariners that they have stopped additional testing requirements based SOLELY on body mass index (BMI), other than the standards published in the Medical NVIC.  The Coast Guard needs to develop appropriate educational material for physicians and bring this issue to the work group established to review the medical NVIC.
Closed
                                       

89-10
T/S 58
MERPAC recommends that the Coast Guard resurrect the educational material that this committee developed for mariners for their education regarding medications and supplements, either prescription or OTC.  This needs to be given priority.
Open
                                       

90-10
T/S 58
MERPAC formally commends Captain David Stalfort on the excellent performance of his duties at the National Maritime Center.  Many Commanding Officers have stood before this body and explained why the requests and recommendations of the committee would not or could not be acted on.  Captain Stalfort came and accepted these recommendations and made great strides in enacting them.  Captain Stalfort has provided great service to the mariners of this country, and this committee formally thanks him for his work. 
Closed
                                       

91-10
T/S 72
Minimum amount of service, in (8-hour) days, to qualify for RFPNW for mariners who do not complete an approved program of special training.

MERPAC recommends that seagoing service be calculated in both 8-hour days and 12-hour days.
Closed
                                       

92-10
T/S 72
Minimum amount of service, in (8-hour) days, to qualify for RFPNW for mariners who do not complete an approved program of special training.

MERPAC recommends that the mariner shall complete not less than 180 8-hour days of seagoing service, or 120 12-hour days of seagoing service to fulfill the seagoing service for ratings forming part of a navigational watch.
With special training, the mariner shall complete not less than 60 8-hour days of seagoing services, or 40 12-hour days of seagoing service to fulfill the seagoing service for ratings forming part of a navigational watch.
Closed
                                       

93-10
T/S 72
Minimum amount of service, in (8-hour) days, to qualify for RFPNW for mariners who do not complete an approved program of special training.

MERPAC recommends that in establishing seagoing service, discharge slips, small vessel sea service forms, and letters of sea service issued by the master of the vessel and/or by the company be accepted as proof of seagoing service.
Closed
                                       

94-10
T/S 72
Tonnage of the vessels upon which qualifying service is obtained.

MERPAC recommends that qualified service on a vessel of any tonnage be accepted as seagoing service.  
Closed
                                       

95-10
T/S 72
Routes upon which the qualifying service is obtained.

MERPAC recommends that in light of the definition of seagoing service found in STCW Regulation 1/1.25:
      "Seagoing service means service on board a ship relevant to the issue of a certificate or other qualification;"
the Coast Guard should accept seagoing service which has been obtained on any navigable water.
Closed
                                       

96-10
T/S 72
Capacity in which the mariner serves and the scope of his/her duties during the qualifying service. This should specifically address the requirement in STCW Regulation II/4 that training and experience be "associated with navigational watchkeeping functions."

MERPAC recommends that the Coast Guard retain the language that is found in the STCW NPRM 46 CFR 12.420 (c)(1)(I):

      "... seagoing service that includes training and experience associated with navigational watchkeeping functions and involving the performance of duties carried out under the supervision of an OICNW or a qualified deck rating;"

The capacity in which the mariner serves and the scope of his/her duties would be performed during navigational watchkeeping functions and involving the performance of duties carried out under the supervision of deck watch officer or a qualified deck rating.
Closed
                                       

97-10
T/S 72
MERPAC recommends that in light of STCW Section A-I/6.6, assessment of competence can be performed by any licensed deck officer on the vessel.
Closed
                                       

98-10
T/S 72
MERPAC recommends that when assessing the rating according to Table A-II/4, the assessor should use the assessment forms contained in NMC Policy No. 14-02 or other approved assessment forms.
Closed
                                       

99-10
T/S 72
MERPAC recommends that in recognition of the mariner's experience, training and knowledge, on the issuance of his/her first license, and with the completion of STCW Basic Safety Training, the deck officer be issued an RFPNW endorsement on his/her STCW certificate.
Closed
                                       

100-10
T/S 72
In reference to the 1999 letter by the Chief of Marine Personnel which stated:

      "...vessels of not more than 500 gross registered tons on near coastal, domestic voyages will not be required to have seamen qualified as ratings forming part of a navigational watch because that STCW rating does not apply to vessels of less than 500 gross tons."

MERPAC recommends that the Coast Guard make the requirements for RFPNW applicable to vessels over 500 GRT/1600 GT ITC in near coastal service.
Closed
                                       

01-11
T/S 75
STCW
SNPRM
10.107 - MERPAC believes that any person serving as an assessor needs to be qualified with training in the skills required to assess competency and be approved by the Coast Guard, whether as a Qualified Assessor or as a  Designated Examiner.  Therefore, a definition of Qualified Assessor should be added as follows: "Qualified assessor or QA means a person who is qualified to evaluate, for STCW endorsements, whether an applicant has demonstrated the level of competence in the task for which the assessment is being made. This person must be approved by the Coast Guard or by a CG approved or accepted program of training."
Closed
                                       

02-11
T/S 75
STCW
SNPRM
10.107 - Coast Guard should work with MERPAC to develop the standards for a QA, including developing an approval process and an auditing and oversight program.  A task statement should be developed for MERPAC.  
Closed
                                       

03-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that a definition for "Certificate of Registry" needs to be added.
Closed
                                       

04-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the definition of a "Domestic" officer endorsement is confusing. Strike "domestic" and replace with "National". (Globally)
Closed
                                       

05-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends a change to the definition of "disabled vessel", that the Coast Guard should remove the last sentence of the definition and revert to the original definition.  As stated, we believe this definition would mean that any time a vessel maneuvering to and from the dock with an assist tug, or a vessel that takes an assist/escort tug, that that vessel would be deemed to be a disabled vessel.  
Closed
                                       

06-11
T/S 75
STCW
SNPRM
10.107 - MERPAC notes the absence of a definition for "direct supervision" and recommends that one is needed.
Closed
                                       

07-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the definition of "drug test" be amended to broaden the testing procedure.  See note below:

Title 49: Transportation

Subtitle A: Office of the Secretary of Transportation

PART 40: PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS

Subpart I: Problems in Drug Tests

40.195 - What happens when an individual is unable to provide a sufficient amount of urine for a pre-employment follow-up or return-to-duty test because of a permanent or long-term medical condition

(a) This section concerns a situation in which an employee has a medical condition that precludes him or her from providing a sufficient specimen for a pre-employment follow-up or return-to-duty test and the condition involves a permanent or long-term disability. As the MRO in this situation, you must do the following:

(1) You must determine if there is clinical evidence that the individual is an illicit drug user. You must make this determination by personally conducting, or causing to be conducted, a medical evaluation and through consultation with the employee's physician and/or the physician who conducted the evaluation under 40.193(d).

(2) If you do not personally conduct the medical evaluation, you must ensure that one is conducted by a licensed physician acceptable to you.

(3) For purposes of this section, the MRO or the physician conducting the evaluation may conduct an alternative test (e.g., blood) as part of the medically appropriate procedures in determining clinical evidence of drug use.
Closed
                                       

08-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that all manning documents and COIs should separately specify the STCW endorsements from the national endorsements that must be carried onboard for international voyages.
Closed
                                       

09-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the term "STCW endorsement" include additional language clarifying that the underlying domestic endorsement must be held by the applicant for an STCW certificate.
Closed
                                       

10-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that a definition for "medical certificate" be added.  Provide discussion of the use of the medical certificate in the appropriate section.
Closed
                                       

11-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the "coastwise voyage" definition encompass voyages to nations in which we have a treaty or other arrangements between nations that allow coastwise transit.
Closed
                                       

12-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the definition of "domestic voyage" language should delete the phrase that says "without entering waters under the jurisdiction of another country." 
Closed
                                       

13-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends adding a definition for ILO.
Closed
                                       

14-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the definition of "limited" include horsepower.

Closed
                                       

15-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the Coast Guard review the definitions of "self propelled tank vessel" and "tankship" to ensure inclusion of all vessels. 
Closed
                                       

16-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends correction of the definition for "utility towing".  We believe at this time that paragraph 2 conflicts with the proposed definition for disabled vessel.
Closed
                                       

17-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the Coast Guard amend the definition of "restricted" to read ...endorsement, for example, specific ...
Closed
                                       

18-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the definition of "safe and suitable person" needs to include "...safety and security of life or property..."

Closed
                                       

19-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the definition of "support level" should coincide with STCW Code (A-I/1)  -- management level and operational level, also.
Closed
                                       

20-11
T/S 75
STCW
SNPRM
10.107 - MERPAC recommends that the definition "vessel personnel with security duties" be revised. Currently, it does not accurately capture security duties and it should be changed to harmonize with text from B-VI/6 in STCW.
Closed
                                       

21-11
T/S 75
STCW
SNPRM
10.205 - Change the second sentence to read "Except upon a written request of the applicant, the Coast Guard will post-date the issuance of the MMC up to 12 months from the date that the Coast Guard accepts a complete application as defined on this part."  MERPAC recommends that the new credential validity date coincide with the expiration date of the active credential held by the mariner.
Closed
                                       

22-11
T/S 75
STCW
SNPRM
10.209 - MERPAC recommends that a copy of a radar course certificate should not have to be certified, as proposed in (d)(4).

Closed
                                       

23-11
T/S 75
STCW
SNPRM
10.209 - Coast Guard needs to add "if required" at the end of (f). All references to TWIC should be modified in this way because a TWIC is no longer required per U.S. statute to accompany all merchant mariner credentials.  (Global)
Open
                                       

24-11
T/S 75
STCW
SNPRM
10.219 - MERPAC does not support the payment of fees only electronically.  Mariners should not be forced to pay via credit card. Not everyone has a credit card. Allow for cash, certified/cashier's checks or money order payment.
Closed
                                       

25-11
T/S 75
STCW
SNPRM
10.221 - Coast Guard needs to add a new paragraph to address the means of proving citizenship since a TWIC is no longer required for all MMC's.
Open
                                       

26-11
T/S 75
STCW
SNPRM
10.223 - Delete (c)(2), since TWIC isn't required for everyone.

Open
                                       

27-11
T/S 75
STCW
SNPRM
10.225 - (a)(2)  conflicts with 10.227(b) and 10.227(i). Modify (a)(2) to say "except where provided for in 10.227(b) and 10.227(i)."

Closed
                                       

28-11
T/S 75
STCW
SNPRM
10.227(d)(6) - If there is going to be a national medical certificate, then de-link the medical certificate from the MMC and issue a separate medical certificate. The Coast Guard needs to check for consistency with other regulations (10.302 et al) and, if necessary, consider a Legislative Change Proposal to ensure that credentials are issued after evaluating a mariner's professional qualifications alone.
Closed
                                       

29-11
T/S 75
STCW
SNPRM
10.231(b) - Replace text to ensure evaluators issue a new 5-year credential (as a default) if all required documentation accompanies the application, even if the mariner does not select "renew' on the application form, or the evaluator should contact the mariner to inquire if they are requesting a raise in grade, which would not reset the expiration date.  Replace text as follows: " If an applicant for a new endorsement or a raise in grade meets the renewal requirements under 10.227 for the endorsements listed on the MMC, that applicant will receive a credential valid for 5 years.  Where an applicant does not meet the renewal requirements for an endorsement(s) such endorsement(s) may be issued with the expiration date that is the same as the current MMC."
Closed
                                       

30-11
T/S 75
STCW
SNPRM
10.232(a)(5) - Delete the word "direct" in the last line.  Replace reference to 11.328 with 11.329 and check all references to ensure there are no errors. (Supposed to be referring only to STCW).

Closed
                                       

31-11
T/S 75
STCW
SNPRM
10.232 (b) - Insert a new paragraph that would allow the issuance of an STCW-restricted certificate based on seagoing service on the waters of British Colombia and the inland passage. (as day for day service on inland waters).  To ensure continued service for seafarers working in this area.
Closed
                                       

32-11
T/S 75
STCW
SNPRM
10.235(h) and (i) - Change "will" to "may" since TWIC is no longer required for all mariners.  Should insert text directing mariner to appeal to TSA not USCG.
Closed
                                       

33-11
T/S 75
STCW
SNPRM
10.237 - Change in the red line of the SNPRM did not appear in the FR SNPRM.   Change is not significant.  
Closed
                                       

34-11
T/S 75
STCW
SNPRM
10.301(a) - MERPAC believes that the NMC process needs to refocus the medical review of mariners so that the process is risk based.  Additionally, MERPAC is concerned that the change to the medical review process requiring the implied issuance of a medical certificate will exceed the capabilities of the NMC because of the increase in the number of reviews necessitated by the proposed 1 and 2-year cycle of certificates, and an unacceptable backlog will be created.  Therefore, mariner's jobs would be jeopardized. 

Therefore;
Replace "operational limitations" with "limitations and/or other conditions......."   (to assure consistency with NVIC).
Open
                                       

35-11
T/S 75
STCW
SNPRM
10.301(b) - MERPAC believes that the NMC cannot adequately conduct or issue the certificates in a timely manner as laid out in this section.  We believe that the only long term solution is development of a designated medical practitioner issued certificate as an option for the mariner.  The designated medical practitioner should only be "an option" since there may not be enough mariners in an area to support this system.
open
                                       

36-11
T/S 75
STCW
SNPRM
11.709(b) - In addition to necessary amendments to 46 CFR § 10.301, in order to put into effect MERPAC's recommendation that first class pilots and mariners merely "serving as" a pilot be required to have 5 year medical certificates (instead of 1 year medical certificates), 46 CFR § 11.709(b) and (d) should be amended as follows:

    (b) Every person holding a license or MMC endorsement as first-class pilot must have a thorough physical examination each year, to be completed by the first day of the month following the anniversary of the individual's most recently completed Coast Guard required physical examination.  Every fifth year, as per the medical certificate/endorsement requirements in 46 CFR § 10.301(b),  the results of the physical examination must be recorded on a CG-719K form and submitted to the Coast Guard no later than thirty (30) calendar days after completion of the physical examination.  
    
 "PLAN B":  MERPAC feels strongly about the above recommendation.  However, as a "Plan B" in the event the Coast Guard does not accept MERPAC's recommendations that first class pilots and mariners merely "serving as" a pilot be required to have 5 year medical certificates, MERPAC recommends that first class pilots and "serving as" pilots be required to have 2 year medical certificates.  Under "Plan B", 46 CFR § 11.709(b) and (d) should be amended as shown below:

    (b) Every person holding a license or MMC endorsement as first-class pilot must have a thorough physical examination each year, to be completed by the first day of the month following the anniversary of the individual's most recently completed Coast Guard required physical examination.  Every other year, as per the medical certificate/endorsement requirements in 46 CFR § 10.301(b),  the results of the physical examination must be recorded on a CG-719K form and submitted to the Coast Guard no later than thirty (30) calendar days after completion of the physical examination.  
    (d) If a person holding a first class pilot license or endorsement does not submit his or her CG-719K form in accordance with 46 CFR § 11.709(b), the individual may not operate under the authority of that license or endorsement until the CG-719K form has been properly submitted to the Coast Guard.


(b)(3) 
If Coast Guard moves forward with a certificate for national mariners, pilots should be included in this group if applicable. 
Closed
                                       

37-11
T/S 75
STCW
SNPRM
10.304(b) What is a communicable disease? CG needs to define exactly what the concerns are.  Mariners that ONLY have a FH credential are receiving extensive, potentially unnecessary, medical testing. Clarification needs to be provided in guidance as there currently is no standard for  "communicable".    
Closed
                                       

38-11
T/S 75
STCW
SNPRM
10.304(d)(2) - Recommend dropping (d)(2) which has been imported from NVIC and STCW. Recommend leave it in guidance.
Closed
                                       

39-11
T/S 75
STCW
SNPRM
10.305 - (b) Amend redline to conform with SNPRM.

Closed
                                       

40-11
T/S 75
STCW
SNPRM
10.402 - Change "course approval" to mirror the IMO format to avoid confusion in the implementation.

Closed
                                       

41-11
T/S 75
STCW
SNPRM
10.402(e) - Add "significant" before the word "change" in course approval.

Closed
                                       

42-11
T/S 75
STCW
SNPRM
10.403 (a)(6)(i) - Replace "answers" with "scores"

Closed
                                       

43-11
T/S 75
STCW
SNPRM
10.403(a)(6)(iii) - Change to read "Compliance with attendance policy."

Closed
                                       

44-11
T/S 75
STCW
SNPRM
10.403(a)(7) - Add "significant" before "change".

Closed
                                       

45-11
T/S 75
STCW
SNPRM
10.404(a)(3) - After "allowed," add "substitution of required service as a result of ..."   (to avoid individuals from having to take the same class twice to maintain an endorsement when upgrading).
Closed
                                       

46-11
T/S 75
STCW
SNPRM
10.405 - Include a five-year renewal requirement for QA and DE, consistent with the five-year requirement for instructors.

Closed
                                       

47-11
T/S 75
STCW
SNPRM
10.405(a) (3) - After "a level of qualification", insert "being sought," and change "training objectives" to "tables of competence".

Closed
                                       

48-11
T/S 75
STCW
SNPRM
10.405 - Change paragraph (c) into new paragraph (b)(4). In new (b)(4), change "and/or" to "or"; and delete the final sentence.  The sentence is an IMO reference that is inappropriate for a domestic credential.
Closed
                                       

49-11
T/S 75
STCW
SNPRM
10.409(h)(2)(i) - MERPAC believes this language is unclear. Change the word "client" to insure that it reflects the intent that a QSS cannot approve courses for a subsidiary of its own organization.
Closed
                                       

50-11
T/S 75
STCW
SNPRM
10.410 - Include a requirement that if company training is included under the ISM, the Coast Guard should accept ISM to the extent that it meets the QSS requirements.
Closed
                                       

51-11
T/S 75
STCW
SNPRM
10.410(d) - change "national" to "nationally recognized".

Closed
                                       

52-11
T/S 75
STCW
SNPRM
10.410(c)(2)(v) - delete "training"

Closed
                                       

53-11
T/S 75
STCW
SNPRM
10.410(c)(3) - delete proposed language and insert "Organizations are subject to audits at least twice in a five-year period.  Organizations should cooperate with Coast Guard scheduled audits."
Closed
                                       

54-11
T/S 75
STCW
SNPRM
10.412  - Replace "A-1/6" with "B-1/6"

Closed
                                       

55-11
T/S 75
STCW
SNPRM
46 CFR 11
General Comment  --  Mariners should not be able to obtain an STCW endorsement without meeting the service requirements for the associated national endorsement.  This is not about qualification requirements, it IS about progression requirements.
Closed
                                       

56-11
T/S 75
STCW
SNPRM
11.102(a) - link is not helpful...
Somehow, make STCW available to the general public.  It is not sufficient to incorporate by reference, since the document is only available by purchasing it.  
Closed
                                       

57-11
T/S 75
STCW
SNPRM
11.201(a) - change "passage of a professional examination" to "demonstration of competence  (more encompassing of different methods).
Closed
                                       

58-11
T/S 75
STCW
SNPRM
11.201 (e)(2) - No STCW endorsements listed considering the title and the application of the entire section.

Closed
                                       

59-11
T/S 75
STCW
SNPRM
11.201 (f) - amend to be consistent with 10.301(a).

Closed
                                       

60-11
T/S 75
STCW
SNPRM
11.201 (h)(1) - recommend change "within the previous" to read "more than". 
Coast Guard needs to define "evidence" as detailed in the proposed language.  (global)
Closed
                                       
         1.  
61-11
T/S 75
STCW
SNPRM
11.201(j)(1)(iii) -recommend extend time from 3 months to 6 months.
Closed
                                       

62-11
T/S 75
STCW
SNPRM
11.301(i) - should extend grandfathering provisions.  (persons with an operational level endorsement upgrading to management level should not be required to do the assessments for operational level, since they were already completed)
Closed
                                       

63-11
T/S 75
STCW
SNPRM
11.305(a)(3)(ii) - Change language "if required" to read "if serving on a vessel..." consistent with STCW.
Closed
                                       

64-11
T/S 75
STCW
SNPRM
11.309 (b)(1) - but also global...  Leadership competency  -  how is it achieved? Specify in regulations or policy what kind of evidence will be used. 
Closed
                                       

65-11
T/S 75
STCW
SNPRM
11.323 (b)(2) - Change "completing Coast Guard approved or accepted training" to "demonstrating competence".

Closed
                                       

66-11
T/S 75
STCW
SNPRM
11.323(e) - Delete  -   this is inconsistent with 15.915.

Closed
                                       

67-11
T/S 75
STCW
SNPRM
11.325(a)(3)  and other  similar paragraphs are unnecessary. (This applies to all sections with the same language) and should deleted as it not reflecting the required competencies.
Closed
                                       

68-11
T/S 75
STCW
SNPRM
11.325(b)(2) - Why has this specifically been mentioned, when the STCW table mentions managing other items? (this function is not new to STCW). (This applies to all sections with the same language)
11.325(c) - Recommend that a working group be formed with Coast Guard HQ and NMC and industry to clarify and define the certification process for single or limited size engine staff.  In addition, this working group should also develop the same for vessels of limited size deck staffing.
Change the wording in the last sentence as follows: "Under these circumstances, the certificate may will include a corresponding limitation." (This applies to all sections with the same language).
Open
                                       

69-11
T/S 75
STCW
SNPRM
11.335(c) - Delete current text and replace with "An applicant who holds an STCW endorsement as OICEW, second engineer officer, or chief engineer officer will be allowed to receive the ETO endorsements upon completion of the requirements in Section A - III/6 of the STCW Code"
Closed
                                       

70-11
T/S 75
STCW
SNPRM
11.335(d) - Delete due to above recommendation.
Closed
                                       

71-11
T/S  75
STCW
SNPRM
Table 11.505(a) - Use attached table as needed (as modified in 4 year row between 2 A/E Unlimited and Chief Engineer Limited) and notes (Need to add appropriate Limited Chief Engineer, MODU and OSV Engineer Endorsements).  Effect is to eliminate engineer near coastal endorsement.  If working outside of boundary line, STCW applies.  If not, US endorsement applies.  (new crossovers)  Need better explanation of crossover from Unlimited DDE to OICEW within regulations (DDE to have x years as DDE = OICEW (after completing assessments).    Need to develop assessments for Limited Chief Engineer at STW 43
Closed
                                       

72-11
T/S 75
STCW
SNPRM
11.516(a)(3) - Replace "graduation from" with "completion of an Engineering Officer Qualification Course".  An EOOW letter from the Army, Coast Guard or Navy should be prima facie evidence of competence.  
Closed
                                       

73-11
T/S 75
STCW
SNPRM
11.403 Table - Insert exam between 2nd mate and C/M on far-left progression.
Also in Table, in far right progression, don't have to go through BCO/BS to get to OIM.  It is only one path.
Re-assess entire chart for accuracy, including the two above.
Closed
                                       

74-11
T/S 75
STCW
SNPRM
11.404(c) (et seq). - Great Lakes time is linked with inland time... need to break out, 12 months for GL and 24 months for inland.  All the way through, even in UIFVs and T/V. New policy recognizing GL time as equivalent to ocean not carried through in Section 11.
Closed
                                       

75-11
T/S 75
STCW
SNPRM
11.463 - Harbor assist license  -  creation of a new license would unnecessarily complicate the licensing scheme and potentially stovepipe mariners.  The current TOAR system allows mariners to complete applicable assessments and receive a restricted towing license.
Closed
                                       

76-11
T/S 75
STCW
SNPRM
11.470 - (b)(2)(iii)  -  check name (check to see if BOEMRE/MMS still exists)...recommend that correct name be obtained before publication.
Closed
                                       

77-11
T/S 75
STCW
SNPRM
11.480(d) - confusing... when renewing radar endorsement or credential endorsement?    Re-draft to ensure current practice of not putting radar endorsement on MMC is stated.
Closed
                                       

78-11
T/S 75
STCW
SNPRM
11.709(d) and 713(a) come up with a different term than "invalid."  

Closed
                                       

79-11
T/S 75
STCW
SNPRM
11.821 - Adding this standard extracted from a different (HSC) code is confusing and inappropriate. At a minimum add clarification about high speed craft code (reference the code) and to what vessels it applies to. 
Closed
                                       

80-11
T/S 75
STCW
SNPRM
11.900 tables are pre-STCW-95.  
MERPAC recommends that the tables be separated by operational and management levels.  Small group to discuss and to locate any Δ between national and STCW endorsements that occur in this table.

      1). Completely remove the table 11.910-2 & 11.950-2 from the SNPRM. 
      2). In lieu of the table, the USCG should issue documentation with considerable detail as to what is contained in each exam for each license level. 
      3). MERPAC should assist in the development of this documentation, which might take the form of a module description as has been used in the past. 
      4). MERPAC Task 71 regarding license exam questions cannot logically proceed until recommendations 1-3 are well underway
Open
                                       

81-11
T/S 75
STCW
SNPRM
Part 12 - Global  -  make endorsements comply with the titles in the law

Closed
                                       

82-11
T/S 75
STCW
SNPRM
12.409(a) - change  after "every person" to read "every person serving under the authority of a rating endorsement as lifeboatman-limited on any United States vessel fitted with liferafts but not fitted with lifeboats must hold an endorsement as lifeboatman or as lifeboatman-limited." (bad language in both 12.407 and 12.409).
Closed
                                       

83-11
T/S 75
STCW
SNPRM
12.601(c) - make identical to 11.301(b)(3).

Closed
                                       

84-11
T/S 75
STCW
SNPRM
12.601(b)(1)(i) - add text to require a QA.

Closed
                                       

85-11
T/S 75
STCW
SNPRM
Table 12.603(e)  - Able Seafarer Special.  Include a new footnote to allow for the reduction of sea service (6 months) by taking an approved course.

Closed
                                       

86-11
T/S 75
STCW
SNPRM
12.603(b) - first line  -  change "may" to "shall"  

Closed
                                       

87-11
T/S 75
STCW
SNPRM
12.605 -  Table 12.605(c) - Ordinary seamen.  Include a new footnote to allow for the reduction of sea service (6 months) by taking an approved course.
Closed
                                       

88-11
T/S 75
STCW
SNPRM
12.607(b) - first line  -  change "may" to "shall"

Closed
                                       

89-11
T/S 75
STCW
SNPRM
12.611(b) - Delete current text and replace with "An applicant who holds an STCW endorsement as able seafarer-engine and domestic rating endorsements as electrician, electrician/refrigerating engineer, or junior engineer will be allowed to receive the ETR endorsements upon completion of the requirements in Section A - III/7 of the STCW Code".
Closed
                                       

90-11
T/S 75
STCW
SNPRM
12.611(c) - Delete due to above recommendation

Closed
                                       

91-11
T/S 75
STCW
SNPRM
12.625 and 627 - re-draft to ensure that it provides all transitional provisions from STCW.  (check 15.1113 implementation date and make sure they're the same).
Closed
                                       

92-11
T/S 75
STCW
SNPRM
13.107(d) - revise text  -  remove " and for maintaining and operating the bunker systems including the fuel oil" (tankerman engineer is specifically for cargo operations.  Delete everything after the semicolon.)  and add "liquid cargo  in bulk".  Ensure that text does not apply to the transfer of other than bulk liquid cargoes and a tankerman endorsement is not needed.
Closed
                                       

93-11
T/S 75
STCW
SNPRM
13.117  -  1. revise to allow applicant to complete an approved course for renewal when expired for more than 12 months   see 13.120(a)(3).   Many mariners are not aware that taking a course counts towards renewal of tankerman endorsements.  This would allow the mariner the ability to maintain  their tankerman endorsement following expiration of greater than 12 months.
2. Change reference from rating to endorsement.  
Closed
                                       

94-11
T/S 75
STCW
SNPRM
13.120(a)(1)  - after tank vessel, insert "including service aboard a barge, as appropriate".  This is to enable mariners serving on towing vessels, with tankerman credentials, the ability to renew those credentials.
Closed
                                       

95-11
T/S 75
STCW
SNPRM
13.203  -  add text to give ATBs full credit for sea time and experience (loads/discharges) towards full tankerman-PIC endorsement.  Many new ATBs have identical cargo-handling equipment as tankships.  
Closed
                                       

96-11
T/S 75
STCW
SNPRM
13,203(c) - need to include a crossover program from different types of tankers.  Seafarers would already have tanker experience.  A shorter course consistent with the STCW could be appropriate.
Closed
                                       

97-11
T/S 75
STCW
SNPRM
   13.603  -  
Split oil and chemical tanker requirements into separate sections... can combine courses, but split sea time requirements.  Incorporate STCW code properly..  include fast track in regulation V/I-1.  Seafarers serving on board tankers certified to carry both oil and chemical should receive sea credit for both oil and chemical.

allow T/E to obtain this endorsement so C/E and 1st don't have to get tankerman-PIC endorsement...  Under this text engineers C/E and 1st will be unable to do the loading and discharges.    Include language to allow mariners with STCW management level engine endorsements and tankerman-engineer national endorsement to receive an STCW Advanced tanker cargo operations endorsement if they have completed the STCW assessments.  Changes may be accomplished by amending the domestic (13.201) requirements and the STCW requirements.

Create a new STCW section for Tankerman (Barge) to build on 13.301 for the service requirements but not the training requirements.  The training requirements would be the same as 13.201.  Include grandfathering provisions.
Closed
                                       

98-11
T/S 75
STCW
SNPRM
13.605 -- Apply comments from 13.603, as appropriate.

Closed
                                       

99-11
T/S 75
STCW
SNPRM
Part 15 - General comments - Add section about manning documents and COIs should also separately specify the STCW endorsements that must be carried onboard for international voyages.
Closed
                                       

100-11
T/S 75
STCW
SNPRM
Part 15 - Pilots  -  The statutory requirement does not require submission of the medical exam nor does it imply issuance of a new certificate.  Considering the high volume of medical certificates that will need to be processed to move to a 2 year medical certificate, the Coast Guard should continue a five-year certificate applicable to first class pilots and those serving as first class pilots. Amend 15.401(c)(3)  to include first class pilots and delete 15.401(c)(2) where the pilot would be subject to an annual medical exam and should make it available upon request.  Change 10.301 and 11.709 accordingly
Closed
                                       

101-11
T/S 75
STCW
SNPRM
Part 15 - The Coast Guard should issue a notice to all shipowners explaining the implementation of the US medical certificate to facilitate port state control inspections.
Closed
                                       

102-11
T/S 75
STCW
SNPRM
Part 15 - Add New 15.105(g)(3) Add:  Pilot vessels are not considered seagoing ships because they operate within, or closely adjacent to, sheltered waters or areas where port regulations apply.
Closed
                                       

103-11
T/S 75
STCW
SNPRM
15.401(c)  -  medical certificate, there is no effective date.  Add an additional sentence:  "Until such date as a separate certificate is issued, a valid MMC serves as the medical certificate."  
Closed
                                       

104-11
T/S 75
STCW
SNPRM
15.401(c)  -  Amend to ensure that is not meant to include uncredentialed mariners.  Amend "A person may not employ or engage an individual who is employed in a position required to hold an MMC..."
Closed
                                       

105-11
T/S 75
STCW
SNPRM
15.403(a) requirement to have a TWIC with an MMC is in conflict with the current statutes.  Amend by adding "if applicable"

Closed
                                       

106-11
T/S 75
STCW
SNPRM
15.403(b) requirement to have a TWIC with an MMC is in conflict with the current statutes.  Amend by adding "if applicable"
Closed
                                       

107-11
T/S 75
STCW
SNPRM
Part 15 - General comment  -  Text should honor original agreement with DOT that the STCW application in domestic trade would start at 500 GRT.  Amend text in Part 15 to apply this agreement.
         * Global change in Part 15 - add "or 500 GRT on a domestic voyage" wherever 200/500 tonnages are used.  This is per DOT agreement to use 500 GRT and on the application of the STCW.

         * Global change in Part 15  -  add " after seagoing vessel"  wherever  horsepower is mentioned, tonnage should be also mentioned 200 GRT/500 GT.  Example "seagoing vessel of 200 GRT/500 GT or more driven by main propulsion machinery of 1000HP/750 kW propulsion power or more..."
Closed
                                       

108-11
T/S 75
STCW
SNPRM
15.404(d)(3)     Recommend delete current language indicating that all ratings, including wipers, must possess endorsement as Able Seafarer  - Engine instead of QMEDs.  MERPAC needs to categorize what QMED categories should be RFPEW (watchstanding) (FWT, Oiler) and which QMED categories should be Able Seafarer  -  Engine (non-watchstanding) (all others) to reflect the rating who stands a watch and who does not.  

Requirements should reflect that all those watchstander ABs and QMEDS are required to hold RFPNW or RFPEW.  

"QMEDs serving on vessels in a non-watchstanding position, excluding wipers, oilers and FWT, must hold able seafarer-engine."
Closed
                                       


T/S 75
STCW
SNPRM
15.405 - Too broad, goes too far beyond what should be required.  Replace "on which he or she is engaged" with "appropriate to their duties and responsibilities".  Second sentence - After the word "these" insert "may".
Closed
                                       

110-11
T/S 75
STCW
SNPRM
15.515 (b)  -  overly restrictive and impossible during normal vessel operations.  Delete "made fast to shore".
Closed
                                       

111-11
T/S 75
STCW
SNPRM
15.816- change "competence" to "documentary evidence meeting the regulations as per 46 CFR 11.23xx". 
Closed
                                       

112-11
T/S 75
STCW
SNPRM
15.818  -  There are no guidelines for GMDSS maintainer courses in the U.S.  These need to be developed and provided to industry.

Open
                                       

113-11
T/S 75
STCW
SNPRM
15.860(i) to (j)  -  Amend paragraph (i) in accordance with the recommendation under Part 13 to include a new STCW endorsement for barge.Closed
Closed


114-11
T/S 75
STCW
SNPRM
15.860  -  Table 1
Place double or triple asterisks and associated note that an engineer who holds a tankerman PIC (XX) can be substituted for a tankerman-engineer.
Closed
                                       

115-11
T/S 75
STCW
SNPRM
15.901  -  conflict between redline and SNPRM.  Redline is correct version.

Closed
                                       

116-11
T/S 75
STCW
SNPRM
15.901(c)-  amend to be consistent with definition of self-propelled vessels.

Closed
                                       

117-11
T/S 75
STCW
SNPRM
15.905- conflict between redline and SNPRM.  Redline is correct version.

Closed
                                       

118-11
T/S 75
STCW
SNPRM
15.915 (a)- Return the conditions under which a DE can sail to the current regulations,  need to retain the 500 GRT limit.

Closed
                                       

119-11
T/S 75
STCW
SNPRM
15.1101  -  See recommendation regarding exemption of pilot vessels to STCW.  

After "of this subchapter," change comma to period and delete the remainder of the sentence.  This is done to increase the clarity of paragraphs 1 and 2.
Closed
                                       

120-11
T/S 75
STCW
SNPRM
15.1103(a)  -  add at the end of the paragraph "and other relevant national license requirements".

Closed
                                       

121-11
T/S 75
STCW
SNPRM
15.1103(b) and (c)  -  change the tonnage to 500 "GRT" and add tonnage to all HP references.
Closed
                                       

122-11
T/S 75
STCW
SNPRM
15.1103(e) (1) -  change to " serving on seagoing vessels, except those vessels listed in 15.1101 of this part".  Add also to implementation of medical certificate in earlier recommendations about implementation date.
Closed
                                       

123-11
T/S 75
STCW
SNPRM
15.1105  -  Subparagraphs written too broadly.  Add insertion referencing exempted vessels from paragraph (a) into paragraphs (b) and (c).

Closed
                                       

124-11
T/S 75
STCW
SNPRM
15.1105( c )(1)  -  change from "BST or safety familiarization" to "BST and safety familiarization specific to that vessel."

Closed
                                       

125-11
T/S 75
STCW
SNPRM
15.1109   -  add " serving on seagoing vessels, except those vessels listed in 15.1101 of this part".  

Closed
                                       

126-11
T/S 75
STCW
SNPRM
15.1111(i)  -  in SNPRM, but not in redline, match up redline to match SNPRM.
15.1111(j)  - delete from SNPRM (not in redline).

Closed


127-11
T/S 75
STCW
SNPRM
15.1111  -  add definition of "work" which includes drills not being counted as such.  Use an existing definition that is consistent with other regulations dealing with work and rest.  Concern expressed about meeting and logging OPA 90 work rules versus STCW rest rules. Outside of this rulemaking, Congress should revisit OPA 90 work rules and revise to be consistent with STCW.
Closed
                                       

128-11
T/S 75
STCW
SNPRM
15.1113(c)  -  Amend text to address the following issues:
   * Ensure (a), (b) and (c) apply only to vessels over 500 GRT;
   * Include all transitional provisions from STCW;
   * Account for existing mariner compliance by 2012;
   * Account for new mariners compliance by 2014;
   * Contractors and other personnel should not be required to obtain an endorsement  (additional burden); and
   * Individuals who have completed a USCG accepted VSO course or have been designated as VSO are considered as having met the requirements of training for personnel with or without security duties.
   Ensure that requirements take into account STCW.Circ 7(16) providing a compliance waiver until 2017. 
   
   MERPAC recommends that the text should be amended as follows:
§ 15.1113  Security personnel.
(a)  Onboard a seagoing vessel of 200 GRT/500 GT or more, all persons performing duties as Vessel Security Officer (VSO) must hold a valid endorsement as VSO.
(b)  Persons who hold an endorsement as VSO will be deemed to satisfy the requirements for vessel personnel with security duties in paragraph (c) of this section.
(c)  After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all personnel with security duties must hold a valid endorsement as vessel personnel with designated security duties, or a certificate of course completion from an appropriate Coast Guard-accepted course meeting the requirements of 33 CFR 104.220.
(d)  Persons who hold an endorsement as vessel personnel with security duties, or a certificate of course completion from an appropriate Coast Guard-accepted course will be deemed to satisfy the requirements for all other vessel personnel in paragraph (e) of this section.
 (e)  After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all other vessel personnel must hold a valid endorsement in security awareness, or a certificate of course completion from an appropriate Coast Guard-accepted course meeting the requirements of 33 CFR 104.225.
(f)  After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all contractors, whether part-time, full-time, temporary, or permanent, must have knowledge of, through training or equivalent job experience in accordance with the requirements of 33 CFR 104.225.  Vessel owners and operators must maintain records documenting this requirement and produce those records to the Coast Guard upon request.
Closed
                                       

129-11
T/S 75
STCW
SNPRM
§ 11.813   Requirements to qualify for an STCW endorsement as vessel personnel with security duties.
(a) The applicant for an endorsement as vessel personnel with security duties must present satisfactory documentary evidence of meeting the requirements in 33 CFR 104.220.
(b) All applicants for an endorsement must meet the physical examination requirements in 46 CFR, part 10 subpart C.
(c)  All applicants for an endorsement must meet the safety and suitability requirements and the National Driver Registry review requirements in §10.209(e) of this subchapter, unless they have met these requirements within the previous 5 years in connection with another endorsement.
(d)	Until 1 January 2014, seafarers who commenced an approved seagoing service prior to 1 January 2012 shall be able to apply for an endorsement as vessel personnel with designated security duties by:
(1)	approved seagoing service as shipboard personnel with designated security duties, for a period of at least six months in total during the preceding three years; or
(2)	having performed security functions considered to be equivalent to the seagoing service required in sub-paragraph paragraph (d)(1) of this section; or
(3)	passing an approved test; or
(4)	successfully completing approved training.
Closed
                                       

130-11
T/S 75
STCW
SNPRM
§ 11.815   Requirements to qualify for an STCW endorsement in security awareness.
(a) The applicant for an endorsement security awareness must present satisfactory documentary evidence of meeting the requirements in 33 CFR 104.225.
(b) All applicants for an endorsement must meet the physical examination requirements in 46 CFR, part 10 subpart C.
(c)  All applicants for an endorsement must meet the safety and suitability requirements and the National Driver Registry review requirements in §10.209(e) of this subchapter, unless they have met these requirements within the previous 5 years in connection with another endorsement.
(d)	Until 1 January 2014, seafarers who commenced an approved seagoing service prior to 1 January 2012 shall be able to apply for an endorsement in security awareness by:
(1)	approved seagoing service as shipboard personnel, for a period of at least six months in total during the preceding three years; or
(2)	having performed security functions considered to be equivalent to the seagoing service required in sub-paragraph of this section; or
(3)	passing an approved test; or
(4)	successfully completing approved training.
Closed
                                       

131-11
T/S 75
STCW
SNPRM
STCW Engineering competencies with formal training requirements

Table A-III_1 - OICEW

Application of Leadership & Teamworking skills  -  ERM - No subject matter experts on board, no time, & more effective.

Maintenance and repair of electrical and electronic equipment  -  Safety Concerns
Closed
                                       

132-11
T/S 75
STCW
SNPRM
STCW Engineering competencies with formal training requirements

Table A-III_2  -  Management Level CE/2E

Use leadership and managerial skills - No subject matter experts on board, no time, & more effective.

Maintain safety and security of the vessel, crew and passengers and the operational condition of life-saving, fire-fighting and other safety systems  -  Required by STCW.

Table A-III_4  -  

Table A-III_5 - 

Table A-III_6 

The USCG needs to ensure that assessments (i.e. exams) are truly testing knowledge, not just the ability to memorize answers to questions.  This may include removing access to exam questions for studying or moving away from the multiple choice exams.
closed


133-11
T/S 75
STCW
SNPRM
STCW Deck competencies with formal training requirements

General Comments:

   1. Generally, the officers do not have the time to perform training and assessment onboard due to minimal manning, higher workload and operational constraints.  
   2. Under STCW mandatory rest period rules, the time available for training is limited.
   3. The officers may not have the requisite knowledge to effectively teach and assess the needed subjects.
   4. Training is not part of a ships officer's job description.
   5. Most officers have not been exposed to "train the trainer" techniques.
   6. Most officers are reluctant to assume the legal liability of training.
   7. Some subjects can be better conducted ashore due to safety and economic reasons.
   8. If a company wants to address the above issues, then the company must provide the resources to conduct approved onboard training.

Code reference:  Table A-II/1-Specification of minimum standard of competence for officers in charge of a navigational watch on ships of 500 gross tonnage or more 

The following competencies and KUPs would better serve the intents of STCW if they were presented in a structured program:

   * Coastal Navigation theory (including magnetic and gyro compasses and passage planning);
   * Basic Stability and trim;
   * Watchkeeping (BRM, application of COLREGs)  -  simulation based );
   * Celestial Navigation (for oceans endorsement);
   * Meteorology;
   * Basic Shiphandling; and 
   * Basic Cargo Handling .

The length of the training can vary depending on the delivery medium (classroom, online, shipboard, blended, etc.).  It should be the responsibility of the training provider to justify, to the National Maritime Center, how they can accomplish the goals in less time than outlined by the model courses.  (Start with the model course as the benchmark and adjust as necessary.) 

The content of the training should be appropriate to the tonnage, route and/or type of vessel. For example, basic shiphandling can be performed aboard OSVs, tugs and ferries, rather than in a full-mission simulator.

Code reference:  Table A-II/2-Specification of minimum standard of competence for management level on ships of 3,000 gross tonnage or more 

The following competencies and KUPs would better serve the intents of STCW if they were presented in a structured program:

   * Advanced Watchkeeping (simulation based focused voyage planning, communication and leading the bridge team);
   * Advanced and Emergency Shiphandling (maneuvering a large vessel in restricted waterways);
   * Advanced Cargo, Stability and Trim including damage stability;
   * Weather routing ;
   * Monitor, Control and Compliance with laws and regulations;
   * IBS/INS; and
   * Marine Propulsion Systems.

Code reference:  Table A-II/2-Specification of minimum standard of competence for management level on ships of greater than or equal to 500 GT, but less than 3,000 GT.

The following competencies and KUPs would better serve the intents of STCW if they were presented in a structured program:

   * Advanced Watchkeeping  (voyage planning, communication and leading the bridge team);
   * Advanced and Emergency Shiphandling * (maneuvering a large vessel in restricted waterways);
   * Advanced Cargo, Stability and Trim including damage stability;
   * Weather routing ;*
   * Monitor, Control and Compliance with laws and regulations;
   * IBS/INS, if so equipped; and
   * Marine Propulsion Systems.

*The content of the training should be appropriate to the tonnage, route and/or type of vessel. For example, Advanced and Emergency shiphandling can be performed aboard OSVs, tugs and ferries, rather than in a full mission simulator.
closed
                                       

134-11
No T/S
MERPAC recommends that the government pursue creating methods of funding for maritime education due to the impact of the regulatory training and education requirements. (46 USC sec 51103) 
closed
                                       

01-12
N/A
Recognizing that proficiency in English is already required for officers and qualified ratings, MERPAC recommends that the Coast Guard establish minimum requirements for English language for all ratings.  All seafarers should be able to speak and understand the English language to perform their general and emergency duties on board a ship
open
                                       

02-12
N/A
MERPAC recommends that, since TWIC credentialed individuals have demonstrated that they are low risk and that they have been extensively background checked, they should be expedited through the airport screening process.
closed
                                       

03-12
T/S 76 & 77
The assessment guidelines tables for Master/Chief Mate 500-3,000 GT were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at:
http://homeport.uscg.mil/merpac ; then click on Meetings/Minutes; then click on meeting 36 to view the enclosures.
Closed
                                       

04-12
T/S 58
MERPAC recommends that the Coast Guard revise Task Statement 58 by amending the title to, "Stakeholder Communication in the Mariner Credential Program."  MERPAC further recommends that the task statement be retained as an open one.  
The entire supporting language of the task statement will need to be updated to support the new task title.  Change the due date to remain open as long as MERPAC chooses.  
The Coast Guard has made great progress since this Task Statement was adopted and MERPAC appreciates all the work and progress that has been done to date.
Closed
                                       

05-12
T/S 58
MERPAC recommends that Brochures are needed on additional subjects, starting with How to Use the Regional Exam Center, the Medical Process, Safety and Suitability checks; what they are and what they aren't.  Language needs to be plain English...NO ACRONYMS!!  Ask mariners to view product before producing.
Closed
                                       

06-12
T/S 58
MERPAC notes that the Web page is a big plus; list serve is a plus, but recommends that NMC needs to use social media:  Facebook and You Tube, videos, etc.  
open
                                       

07-12
T/S 58
MERPAC recommends that the Coast Guard explain the process to obtain and the possibilities once one holds a credential by having RECs participate in local job fairs/visiting maritime high schools and mariner trade school programs, etc.
Closed
                                       

08-12
T/S 58
   1. MERPAC recommends that the Coast Guard find a way to create a credential issue number: 
      Example:  00-00-00-00
      License-document-STCW-Tankerman issue number for example
closed
                                       

09-12
T/S 58
MERPAC feels that a Certificate for framing is unacceptable and mariners are not using it.  MERPAC recommends that the Coast Guard finish creating a professional, attractive document suitable for framing using the original license template, border and artwork.
Closed
                                       

10-12
N/A
In support of MERPAC's previous recommendation to the SNPRM that STCW Assessments be conducted by qualified assessors, MERPAC recommends that the Coast Guard task MERPAC with assisting in the development of appropriate standards for qualified assessors and in defining a quality control system that assures the integrity and accountability of assessments for both institutional and in service assessment.
Closed
                                       

11-12
T/S 30
Recognizing the complexity involved with sea time and training for transitioning military service personnel to the merchant marine, MERPAC recommends that NMC and the REC have a designated person, who has expertise in the military/merchant marine nexus, to assist veterans toward the their fullest potential in maritime careers. This may be facilitated by piloting transition initiatives in several cities having military service populations.
Closed
                                       

12-12
T/S30
In response to President Obama's June 1, 2012 call for greater effort by federal agencies to assist veterans in transitioning to the civilian workforce, MERPAC recommends that the Secretary of Homeland Security encourage her counterparts at the Department of Defense and other appropriate agencies to:
      a. Establish a dedicated person to act as a liaison with the National Maritime Center for course approval and course renewal; and
      b. That this person have a long term position.
Open
                                       

13-12
T/S 30
MERPAC encourages the military services to establish tracking of the levels of credentials being sought by current and former military personnel to establish effectiveness of pilot programs.
Closed
                                       

14-12
T/S 77

The assessment guidelines tables for Officer in Charge of a Navigational Watch and Master for near-coastal vessels of less than 500 GT were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures.
Closed
                                       

15-12
T/S 77
The assessment guidelines tables for Able Seafarer - Deck were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures.
Closed
                                       

16-12
T/S 77

The assessment guidelines tables for Chief Engineer (Unlimited) were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures.
Closed
                                       

17-12
T/S 77
The assessment guidelines tables for Chief Engineer (Limited) were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures.
Closed
                                       

18-12
T/S 77
The assessment guidelines tables for Able Seafarer - Engine were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures.
Closed
                                       

19-12
T/S 79
Dynamic Positioning Officers (DPO) should be credentialed but not necessarily "licensed." If the DPO is not a licensed officer, a licensed officer of the navigation watch shall be provided, if required.
Closed
                                       

20-12
T/S 79
Minimum training for DPOs should be recognized as meeting:
         a.  International Marine Contractors Association (IMCA) M117; and
         b.  Maritime Safety Committee (MSC) MSC.1/Circ.738/Rev.1 standards.
Closed


21-12
T/S 79
In addition to II. (2), further training may be required to ensure the proper performance of duties and should be the responsibility of companies based on the DP system, vessel type, and service/activities.
Closed


22-12
T/S 79
Operational measures (including manning, watch protocols, etc.) will be based on risk assessments performed under a Safety Management System.
Closed
                                       

23-12
T/S 79
These recommendations could be applied to operations outside of the Outer Continental Shelf.
Closed
                                       

24-12
T/S 58
MERPAC recommends that the NMC should make it clear to mariners and Coast Guard employees alike that the time period for mariners to submit additional information (AI) to the NMC was established to ensure that files submitted to the NMC remain active.  When a mariner is "in extremis" on a license application, the additional stress of a ticking clock is unnecessarily stressful. If a mariner or their designated third party contacts the NMC regarding the open application, that contact should automatically be regarded as a request for additional time.
Closed
                                       

25-12
T/S 58
MERPAC recommends that the application form for a merchant mariner credential be updated.   The position of the committee has been and continues to be that once a mariner has any issue that has been adjudicated, and if it was listed on their last application, that issue should not be required to be listed on each subsequent application.  The Committee questions the need for the mariner to disclose the issuance of a Letter of Warning at any time, but he or she certainly should not have to disclose the same letter at each application.  
Closed
                                       

26-12
T/S 58
Section 809 of the Coast Guard Authorization Act of 2010 relieved mariners that do not access restricted spaces on U.S. vessels from having to hold a TWIC.  Yet, mariners are currently paying twice for a card they no longer need.  The Coast Guard needs to work with TSA to retain the current fee structure in the Code of Federal Regulations which separates the TWIC fee into the three components.  This would ensure that mariners can pay the fee for the collection of data and the background check, ONLY.  These mariners should not be required to pay for the card production, since they will not pick up the card.  MERPAC believes that the collection of this fee can be ceased immediately.  Additionally, the Coast Guard should continue to actively pursue, in those locations where it is possible, the co-location of a TWIC enrollment center at each Regional Exam Center.  TSA and its contractor conducted a pilot project in two REC locations, which was by all accounts extremely successful, but it states that it has no intention to expand this concept.
Open
                                       

01-13
T/S 30
MERPAC recommends that the NMC find and identify ACE-approved (American Council on Education) courses and training that are conducted by the military maritime training institutions that could then be recognized by the NMC in part or in whole for required training for merchant marine ratings, endorsements, or licenses. Members of the work group recalled NVIC 09-01 that addresses this issue.

Open
                                       

02-13
T/S 30
MERPAC recommends that the Coast Guard establish a billet whose incumbent acts as a sponsor, who:
         a. Is designated to respond to the needs of the stakeholders:
                 i. Separating military personnel
                 ii. Industry training facilities 
         b. Though this recommendation is directed at the Coast Guard, 
         c. MERPAC recommends that a similar billet should be 
 established in each military branch.
Closed
                                       

03-13
T/S 30
MERPAC recommends that a designated NMC staff person be assigned to the Task Statement 30 work group.
Closed
                                       

04-13
T/S 30
MERPAC recommends:
            That the Coast Guard apply for course approval, and maintain approved courses with the National Maritime Center. 
            That the National Maritime Center accepts as equivalent ACE-approved courses or training submitted by a service member in place of a NMC-approved course or training.
          c. MERPAC also believes that all military branches should have their courses approved by the NMC, and maintain all approved courses when they come up for renewal.
Open
                                       

05-13
T/S 30
MERPAC recommends that the National Maritime Center develop career advisement materials, and make them available at REC's. These materials would be directed to service members, and guide them in translating military service and training to merchant mariner ratings, endorsements, and licenses.
Open
                                       

06-13
T/S 71
Prior to updating these 46 CFR 11.910 (Deck) and 11.950 (Engine) tables to the STCW Manila Amendments, they must first be corrected for the International as well as Domestic licenses.  We will get only one shot at making changes to the 46 Code of Regulations and everything possible should be done so that it can all be accomplished at one time without leaving obvious errors in the table in existence.  It is recommended that MERPAC be tasked with these responsibilities.
Closed
                                       

07-13
T/S 71
In the review of TS 71, it was stated that many Coast Guard certified courses would be required to be completed in order to comply with the STCW Manila Amendments.  MERPAC feels that it is redundant and a waste of resources to require mariners to again be tested on these previously Coast Guard certified courses during the license exams.
Closed
                                       

08-13
T/S 71
MERPAC recommends that the current license exam format for the Operational level be pared down dramatically to reflect just those subject topics that fall outside of STCW and comply with the U.S. Domestic regulations.
MERPAC recommends that it be tasked with this responsibility.
Open
                                       

09-13
T/S 71

MERPAC recommends that all exams and assessments for limited, DDE and OSV licenses (Motors) be looked at when it comes to anything for steam, main boilers, auxiliary boilers, etc. as some vessels may not have this equipment.
Closed
                                       

10-13
T/S 71
MERPAC recommends that a group should be formed to look at the assessments for the limited licenses made up to include the industry that uses limited licenses.
MERPAC further recommends that it be tasked with this responsibility.
Closed
                                       

11-13
T/S 77
Recommended assessment guidelines for Electro-Technical Officer may be located at:
http://homeport.uscg.mil/merpac; then click on "Meeting 38" (under Meetings/Minutes);  
Closed
                                       

12-13
T/S 77
Recommended assessment guidelines for Electro-Technical Ratings may be located at:
http://homeport.uscg.mil/merpac; then click on "Meeting 38" (under Meetings/Minutes);  
Closed
                                       

13-13
T/S 77
Recommended assessment guidelines for Able Seafarer-Engine may be located at:
http://homeport.uscg.mil/merpac; then click on "Meeting 38" (under Meetings/Minutes);  
Closed
                                       

14-13
T/S 80


The work group has identified a potential training gap for US seafarers specific to the crossover between DL and LG Tankerman endorsements.  Recently, the USCG NMC has interpreted the current CFR regulations to allow an individual currently holding DL Tankerman  endorsement and seeking an LG endorsement to only comply with the provisions of 46CFR13.203 (PIC)/46CFR 13.303 (PIC-barge)/46CFR13.503 (engineer), eligibility requirements that address seatime and transfer experience, and not comply with 46CFR13.201(f)(PIC)/46CFR 13.301(f) (PIC-barge)/46CFR13.501(f)(engineer) "Original endorsement" requirements that an individual meet the requirement of a course in DL or LG appropriate for the endorsement applied for.
STCW 
Regulation V/1-2 requires specific LG training commensurate with the individual's duties.
As it stands now a US seafarer can obtain an LG endorsement, under the current NMC understanding of 46CFR, with no LG specific training.  This directly affects the grandfathering clauses and training requirements being considered by this working group.  
MERPAC recommends that the CG enforce STCW Regulation V/1-2 and require LG training commensurate with the individual's duties. That before any tankerman (LG) endorsement be issued a USCG-approved tankerman (LG) course completion certificate be presented.
Open
                                       

15-13
T/S 80
Companies that are starting LNG fuel operations for the first time require consideration of alternate certification proposals to certify initial vessel crews who may not have the opportunity to observe three (3) formal bunkering operations.
MERPAC recommends that the Coast Guard consider alternate certification proposals to certify initial crews who are dealing with startup or new LNG operations who cannot comply with proposed Regulation V/X3.
Closed
                                       

16-13
T/S 80
When a vessel manning is not consistent with the categories outlined in MSC 285 (86), section 8.2.1, MERPAC recommends that training and certification should be required of the deck and engine crew members assigned those duties and responsibilities. We recommend proposed Regulation V/X (2) and (3), add the term after officer to "or those crew members assigned similar responsibilities".
Closed
                                       

17-13
T/S 80
MERPAC recommends editing Regulation V/X (4) (line 2) by changing "4" to "3".
Closed
                                       

18-13
T/S 80
MERPAC recommends that the following wording be added to Regulation V/X (3)-  Simulator training including simulated bunker transfers may be used to satisfy up to 2 of the 3 required bunker transfers. This is consistent with current practice in simulator credit in Tankerman (LG) and (DL) courses.
Closed
                                       

19-13
T/S 30
MERPAC recommends that it solicit members for a Maritime Industry sponsored private/public partnership to conduct the "mapping/comparison" of the military Personnel Qualifications System tasks to align with the STCW competencies and training requirements, so as to allow easier transition into maritime industry employment.

Open
                                       

20-13
T/S 30
MERPAC recommends that the USCG insert the following type of verbiage (taken from USCG-543 Policy Letter 11-07) into Policy Letter 14-02 for the purpose of authorizing the military Commanding Officer to assess the RFPEW and RFPNW competencies and KUP's:

"iii. when serving on a seagoing military vessel of at least 200 GRT/500 GT and is either the Commanding Officer, Executive Officer or is authorized to conduct similar Assessments for the U.S. Navy or for the U.S. Coast Guard Personnel Qualifications Standards (PQS) for underway Officer of the deck (OOD)".
     
The rationale is to allow engineering personnel to be STCW assessed aboard military vessels.
Open
                                       

21-13
T/S 30
MERPAC recommends that the National Maritime Center staff a full-time Government Services employee dedicated to providing maritime career counseling and assistance to military veterans for obtaining endorsements and licenses in order to optimize their military qualifications for conversion to USCG and STCW credentials. 

Closed
                                       

22-13
T/S 30
MERPAC recommends that the military branches improve the flow of civilian professional maritime credentialing information to its members on a continual basis, emphasizing the maritime credentialing process and its value early in the service member's career, thus allowing the service member to participate in the credentialing process while still on active or reserve duty.

Closed
                                       

23-13
T/S 30
MERPAC encourages the military to utilize civilian maritime terminology  
whenever possible and offer professional credentialing pathways throughout the member's careers, i.e. Deck Watch Officer equals the STCW Officer in Charge of a Navigational Watch, Engineering Watch Officer equals the STCW Officer/Rating Forming part of an Engineering Watch, etc.

Closed
                                       

24-13
T/S 30
MERPAC recommends that the USCG, Navy and Army continue to seek USCG National Maritime Center approval of their courses for STCW credentialing.
Closed
                                       

25-13
T/S 78
MERPAC adopts and recommends that the Coast Guard accept the recommendations of the Intercessional Work Group which gathered at the USCG Jemal Building in Southeast Washington, D.C. on Wednesday and Thursday, July 26-27, 2013.
Open
                                       

26-13
T/S 78
MERPAC recommends that supplemental guidance to COMDTPUB P16700.4 / NVIC 02-13 (30 JUL 2013) be promulgated by the USCG providing for a Point of Contact to whom seafarers can report complaints [paragraph 6. Inspection Process, sub-paragraph (14) Onboard complaint procedures (MLC Regulation 5.1.5), p.23].
Open
                                       

27-13
T/S 80
MERPAC recommends that Task Statement 80 remain open until STCW is amended, the IGF Code manning and training requirements and National Regulations finish development due to ongoing developments, at IMO and nationally, and that our positions be retained as these developments progress and that the MERPAC working group meet during the Spring Meeting of 2014.
Open
                                       

28-13
T/S 80
MERPAC recommends that a gap analysis be performed to determine the differences in training requirements between Tankerman PIC (LG) and that needed for personnel aboard vessels using natural gas as fuel to ensure that the training requirements for Tankerman PIC (LG) includes the requirements of the  personnel aboard vessels using natural gas as fuel.
Closed
                                       

29-13
T/S 80
MERPAC recommends that Task Statement 80 be amended to include provisions for initial training should regulations not be available.
Closed
                                       

30-13
T/S 80
MERPAC recommends that the Coast Guard regularly update MERPAC and the Task 80 working group of the ongoing work of relevant advisory groups and IMO.

Open
                                       

31-13
T/S 81
MERPAC recommends a 3 tier training program as follows:
   * Safety awareness for all personnel onboard.
   * Approved "basic training" course for all deck officers operating in the designated polar regions with the exception of vessels that will only be in the polar regions for very short durations (example along a great circle track).
   * Approved "advanced training" for masters & chief officers operating vessels in the ice fields of the designated polar regions.

1  -  Revise 1st bullet point of item #5 of page 2 to state "Safety awareness for all personnel onboard" to `safety awareness for all deck and engine personnel". 
2 - Expand example in 2nd bullet point of item #5 of page 2 (example along great circle track to include "and not near ice i.e. 50 miles of forecasted ice").
3  -  Working group expressed concern that calling the two certifications, basic and advanced could lead to overwhelming levels of competency and training required at the advanced level. The working group recommends renaming basic as level 1 and advanced level 2.
4  -  Add following statement onto item 1 of "Mandatory minimum requirements for the training and qualifications of masters and deck officers on board ships operating in ice-covered polar waters" of page 4 (The carriage of an "ice pilot (s)" holding an advanced/level 2 certification is adequate when a vessel master does not hold the advanced/level 2 certification). The group also proposed the definition of ice pilot be provided.
5 - In section A-V/3, item #2, added the word Polar to the advanced level training to clarify not all ice covered waters required this training.
6  -  Table A-V/3-1, the working group recommends changing basic to level 1 in the title, also recommends deletion of all requirements for all simulator training (simulator use may be an option, but should not be required at this level). And the group recommends all highlighted KUP's that refer to operations in ice be moved to the advanced/level 2 table because this table is for operation in ice free waters.
7  -  Table A-V/3-2, the working group recommends changing advanced to level 2 in the title, also recommends deletion of all requirements for all simulator training due to lack of realistic ice software. (simulator use should be optional at this time as realistic duplication of ice navigation is at best questionable at this time)
8  -  Table A-V/3-2, the working group reworded nearly every KUP to make them specific and useable by a training institution, we however did not move any of the KUP's from the basic/level 1 table to the level 2 table pending approval on that recommendation.
9  -  The working group recommends that the Awareness level training should not exceed 2 hours (either onboard the vessel, via computer based training (CBT), or in an approved course).
10  -  The working group recommends that the Basic/Level1 training should not exceed 16 hours (via an approved course).
11 - The working group recommends that the Advanced/Level 2 training should not exceed 24 hours (via an approved course).
12 - The working group recommends that No additional training be required for engineers beyond the Awareness level.
13 - The working group recommends that the existing, experienced personnel with at least 4 months of Polar ice operations experience in an STCW Management level position be grandfathered into the Advanced/Level 2 certification, Basic/Level 1 certification and Awareness level training. No further grandfathering of vessel personnel is recommended.
14 - The working group recommends that the task remain open pending further IMO action on the STCW or Polar Code.
Explanation/reasoning behind request to change basic and advanced terminology to level 1 and level 2 which are reflected in items 3, 6 & 7 above: 
The intent was/is to ensure there was a clear understanding of the different requirements between the two. 
Basic/level 1 is the training needed for operational level deck officers on vessels who transit waters defined in the Polar Code but DO NOT INTEND/CAN NOT SAFELY ENTER THE ICE.
Basic/level 1 is the training needed for deck officers in charge of a navigational watch aboard vessels transiting waters defined in the Polar Code who WILL NOT OPERATE IN ICE COVERED WATERS. In addition, the training is required for operational level deck officers in Polar Waters who MAY OPERATE IN ICE COVERED WATERS.
Advanced/level 2 is the training needed for Management level deck officers on vessels who transit waters defined in the Polar Code and MAY OPERATE IN ICE COVERED WATERS.

Closed
                                       

32-13
T/S 82
Task Statement 82 asked MERPAC to review Coast Guard Merchant Mariner Credential Application Forms.
The Task Statement and forms, including MERPAC's recommendations, may be accessed at http://homeport.uscg.mil/merpac, in the minutes of the Meeting 39 folder, enclosures 8-13.
Closed
                                       

33-13
T/S 83
Task Statement 83 asked MERPAC to review the STCW assessment guidelines for Chief Engineer (unlimited) and Officer in Charge of an Engineering Watch and determine alternate definitions of the Knowledge, Understanding, and Proficiencies; Methods for Demonstrating Competence; and Criteria for Demonstrating Competence for vessels less than 3,000 GT (ITC) with horsepower greater than 3,000 kW.

The assessment guidelines, including MERPAC's recommended changes, may be accessed at http://homeport.uscg.mil/merpac, in meeting the meeting 39 folder, in the attachment named "Recommendations."

Open
                                       

34-13
T/S 83
In addition to recommendation 33-13, MERPAC recommended that  these same tables be utilized for STCW endorsements as Chief Engineer (OSV) for vessels of not more than 6,000 GT (ITC) since it was determined that these vessels have similar equipment and levels of technology.
Open
                                       

01-14
T/S 85

Task Statement 85 asked MERPAC to review and submit recommendations to the draft update of Chapters 20 through 26 of Volume III of the Marine Safety Manual (MSM).

MERPAC's recommendations, as well as the draft update of Chapters 20 through 26 of Volume III of the MSM, nay be accessed at http://homeport.uscg.mil/merpac, in meeting 39, in the attachment named "Recommendations."
Closed
                                       

02-14
T/S 30
MERPAC recommends that, in accordance with Veterans Report 5-31-2012 of the Executive Office of the President, expand the text in the Coast Guard Authorization Act related to a veteran's opportunity to obtain a merchant mariner credential to all armed forces service by matching service qualifications with national and international standards (the current text only applies to the Coast Guard).
Open
                                       

03-14
T/S 30
MERPAC recommends that the Coast Guard remove the 200 GRT requirement of a "designated examiner" for RFPNW assessment in NVIC 06-14 (RFPNW).
Open
                                       

04-14
T/S 30
MERPAC recommends that the Coast Guard streamline the process of obtaining a TWIC for active duty service members by utilizing existing military identification.
Closed
                                       

05-14
T/S 80
MERPAC recommends that Coast Guard policy letters 01-14 and 02-14, concerning vessels using LNG as fuel should encompass all gas fuels and not just LNG. The recommendation is that the policy letters mirror the HTW work product and include all fuels subject to the IGF code.
Open
                                       

06-14
T/S 80
MERPAC recommends that, with regard to Coast Guard policy letters 01-14 and 02-14, care should be taken to assure that requirements for personnel on board vessels using gas fuels are differentiated from those for a full tankerman  -  LG endorsement as appropriate.  All references to the Parts of 46 CFR that are for tankermen should be eliminated.
Closed
                                       

07-14
T/S 80
With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that the applicability of existing regulations, while useful as a reference point, is not necessarily germane to gas-fueled vessels as they have different operating characteristics, service, and training requirements. 
Closed
                                       

08-14
T/S 80
With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that, with respect to operations, the policy letter should incorporate or adopt the language of the operational requirements of the draft IGF Code to the greatest extent possible.
Open
                                       

09-14
T/S 80
With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that, with respect to training, the Coast Guard incorporate or adopt the language of the training requirements of HTW 1-WP.4-Rev1. the intent of this policy (interim or long standing), would dictate which annex of HTW 1-WP.4-Rev1 to include. MERPAC recommends that the fewer changes, the better, meaning Annex 4 should be incorporated as much as possible, with reference to the competencies listed in the tables as the requirements at basic and advanced levels.
Closed
                                       

10-14
T/S 80
With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that the Coast Guard ensure that the transitional provisions are followed as an interim until the new HTW requirements are mandatory to allow for initial personnel training for the new technology. 
closed
                                       

11-14
T/S 80
With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC notes that many of its recommendations are to incorporate what will be part of STCW. There is a high likelihood that there will be smaller vessels (which may or may not have engineers) that will be using gas fuels. For these smaller operations, MERPAC recommends that companies should be given the flexibility to work with local OCMI's to develop procedures, policies and training that may be more appropriate to the scope of their operation than the fuller STCW requirements and which would achieve equivalent levels of safety (similar to allowances currently in 33 CFR 155.715).
Closed
                                       

12-14
T/S 80
With regard to enclosure (2) of Coast Guard draft policy letter 01-14, MERPAC recommends that this enclosure be deleted in its entirety.  The MSC resolution will be superseded by HTW1-WP.4-Rev1. MERPAC recommends that HTW 1-WP.4-Rev1 be inserted as an enclosure to the policy letter if possible.
Closed
                                       

13-14
T/S 80
MERPAC recommends that the Coast Guard work towards approving courses that meet the requirements of part A (Annex 4) of HTW 1-WP.4-Rev1 and look to begin issuing endorsements for the same as quickly as possible. With the expected growth of gas as a fuel in industry, this is going to be a pressing need sooner rather than later, and training providers and companies will need these approvals.
Closed
                                       

14-14
T/S 81
MERPAC presented a red-line version of Annex 2 of the HTW 1/WP.4 document to the Coast Guard for consideration. 

This document can be located at http://homeport.uscg.mil/merpac
in the attachments to Meeting 40. 

Closed
                                       

15-14
T/S 81
MERPAC recommends that consideration be given to require Polar Familiarization based on the risk assessment for all crew members.
Closed
                                       

16-14
T/S 83
MERPAC presented to the Coast Guard a table to discuss various aspects of possible grandfathering.  

Open
                                       

17-14
N/A
MERPAC presented recommendations on the Coast Guard Authorization Act of 2015 and 2016:
(H.R. 4005, Section 309c, CREDITING OF UNITED STATES ARMED FORCES SERVICE, TRAINING AND QUALIFICATIONS)
This section requires the Secretary to maximize the extent to which armed forces service, training, and qualifications are creditable toward meeting merchant mariner licensing requirements and the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 (STCW Convention).  
MERPAC supports this section and has been working on this issue for more than 12 years and will continue to work on the implementation of these programs.
closed
                                       

18-14
N/A
    (H.R. 4005, Section 319, MERCHANT MARINE PERSONNEL ADVISORY COMMITTEE)
This section directs the Secretary to establish a Merchant Marine Personnel Advisory Committee to: (1) advise the Secretary on personnel matters relating to the U.S. merchant marine, including training, qualifications, certification, documentation, and fitness standards; and (2) comment on personnel regulations proposed by the Coast Guard. The section permits the Committee to conduct studies and make its recommendations available to Congress.  The section also requires the Committee to report to the Commandant regarding: (1) merchant mariner licensing, certification, and documentation programs; and (2) state maritime academy problems with implementation of amendments to the STCW Convention that entered into force on January 1, 2012.  The section also directs the Commandant to forward such report to Congress with recommendations for actions to implement the report's recommendations.  
MERPAC does not support this section.  In the proposed rewrite of MERPAC's charter, several amendments were added that could change the makeup of the Committee and potentially render it less effective.
As presently written, the development of a report on the comparison of the U.S. mariner credentialing program with that of other IMO member states creates the following issues:
   a. Comparison should be made to 3 flag states that are comparable to the United States, such as Norway, United Kingdom, Australia, etc. which are involved in the administration of the training and credentialing of their merchant marine.  Flag administrations with the greatest tonnage generally do not have a training program for merchant mariners, but rely on the recognition of credentials from other administrations.
   b. That being said, any expectation that we can compare the U.S. system with other countries is unrealistic even if we could compel other IMO member states to provide the information necessary for the comparison.
   c. MERPAC members are volunteers with jobs and expertise in their individual fields. It is unrealistic to expect that a MERPAC member could participate in the completion of such a study. Considering that this task would require significant time, this would translate to more meetings and extensive travel as the members would need to travel to the selected countries in order to obtain the required information and, therefore, Congress would need to significantly increase the budget allocation for MERPAC.
The time period to submit the report is totally unrealistic for many reasons including those stated above.
open
                                       

19-14
T/S 80
The applicability of the IGF Code and training for vessels using fuels subject to the IGF code is for vessels greater than 500 gross tons (ITC). There are likely, however, to be vessels of less than 500 GT (ITC) that will be using such fuels in the future, and MERPAC recommends that personnel serving aboard such vessels should be subject to similar training requirements.
open
                                       

20-14
T/S 80
MERPAC recommends that, on vessels that carry a licensed engineer, masters and engineers should have Coast Guard approved advanced training or Coast Guard accepted training (as defined in this paper).  Personnel with safety response duties should have Coast Guard approved basic training or Coast Guard accepted training.
open
                                       

21-14
T/S 80
MERPAC recommends that, on vessels that do not carry a licensed engineer, masters and personnel with direct responsibility for bunkering and/or operation of gas fuel systems should have Coast Guard approved advanced training or Coast Guard accepted training as defined in this paper).  Personnel with safety response duties should have Coast Guard approved basic training or Coast Guard accepted training.
open
                                       

22-14
T/S 80
The Coast Guard retains the authority to exempt the number and/or the training level for personnel, if there are other safety precautions in effect.  An operator may submit, as part of their safe manning proposal, an appropriate number of personnel carrying basic, advanced, or accepted training. This may include, but not be limited to, providing exemptions based upon the quantity of fuel carried, shore based availability of emergency response with route limitations, method of bunkering or other provisions that adequately allow for safe operations.  MERPAC recommends that the Coast Guard consider the ability of personnel to safely and comprehensively respond to emergency situations and the ability of the personnel on board to safely operate the equipment, keeping in mind specific hazards associated with IGF fuels.
open
                                       

23-14
T/S 80
With regard to the HTW 1/21, Annex 7, Interim Guidance, MERPAC recommends that the U.S. implement paragraph 2.2.1.3 by requiring documentary evidence from the trainer/course provider.
open
                                       

24-14
T/S 80
With regard to the HTW 1/21, Annex 7, Interim Guidance, MERPAC recommends that the Coast Guard accept training that is given by qualified personnel, such as, engine manufacturers or other vendors, as being acceptable under paragraph 1.1.5 for the appropriate training elements.
open
                                       

25-14
T/S 80
STCW Regulation V/3.1.7 requires that masters, engineer officers and all personnel with immediate responsibility for the care and use of fuels and fuel systems on ships subject to the IGF Code shall have completed at least one month of approved seagoing service that includes a minimum of three bunkering operations on board ships subject to the IGF Code. Two of the three bunkering operations may be replaced by approved simulator training on bunkering operations.  MERPAC recommends that the Coast Guard develop grandfathering provisions for crews on vessels subject to the IGF Code.  
open
                                       

26-14
T/S 30
Meeting 41
MERPAC recommends that the NMC website be made more 
military-user friendly, i.e.  military to merchant mariner transition tab content such as;
               a.      USCG Military File Evaluation Manual; and
               b. Cross-walked endorsement competencies.
Open
                                       

27-14
T/S 30
Mtg 41
MERPAC recommends that TGPS, TAPS, and other professional 
development centers include merchant mariner credentialing 
information.
Open
                                       

28-14
T/S 30
Meeting 41
MERPAC recommends that the Coast Guard and NMC work together with MERPAC to identify and develop the crosswalks/gaps for military ratings/qualifications to civilian mariner credentials, i.e. MK to QMED, Officer of the Watch  or Bosun's Mate/deck rating  to Master Towing Vessels, etc.
open
                                       

29-14
T/S 30
Mtg 41
MERPAC recommends that Navy and Coast Guard Offices of Cutter and Boat Forces submit their underway qualifications to the NMC for assessment.
open
                                       

30-14
T/S 30
Mtg  41
MERPAC recommends that the Navy and Coast Guard offer funding for prospective deck and engineering officers to obtain a merchant mariner credential with appropriate endorsement.
closed
                                       

31-14
T/S 30
Mtg 41
MERPAC recommends that the Coast Guard consider approving courses for tonnages above 200 GRT in lieu of examinations.
closed
                                       

32-14
T/S 86
Mtg 41
For non self-propelled MOUs, MERPAC recommends removing the requirement for Able Seaman-MODU. This credential is currently not authorized under regulations.
open
                                       

33-14
T/S 86
Mtg 41
While Basic Training as defined by A.1079(28) is appropriate for  those levels indicated in Table 1, MERPAC strongly recommends  that certification in the form of training certificates be considered adequate for proof of training and that non-mariners not be  required to receive credentials from the Coast Guard. To require credentialing would necessitate TWICs, which could be highly problematic for foreign crews.  Additionally, this would create a substantial additional burden upon the already stretched resources at the National Maritime Center.
open
                                       

34-14
T/S 86
Mtg 41
In order to facilitate compliance with BSEE SEMS rules, MERPAC recommends that it should be the responsibility of the employer to ensure that their personnel are appropriately trained and qualified. As such, any requirement to verify training has been met should fall upon the employer and not the OSV/MOU crew members. Validation of this training should be done at the  leaseholder's dispatch location.
open
                                       

35-14
T/S 81
Meeting 41
MERPAC recommends amendments to the tables of competence provided for review.  The annexes in this document include the recommended amendments.  The documents are  based on drafts from Norway (HTW 1/11/1), Argentina (HTW 1/11) and Canada (STW 44/13).   The group created two tables, which are attached as enclosure (6):
         *    "Specification of minimum standard of competence in basic  training for ships operating in polar waters;" and 
         *    "Specification of minimum standard of competence in advanced training for ships navigating in polar waters."
         *    
The Tables of competence may be located at http://homeport.uscg.mil/merpac
in the attachments to Meeting 41 minutes.
Closed
                                       

36-14
T/S 81
Meeting 41
MERPAC recommends sea service requirements for mariners working onboard vessels operating within the polar regions; specifically: 
   *    Recommend a minimum 60 days of sea time serving in an 
       operational or management level deck position within either  
       Polar Region prior to certification of Advanced Polar Water 
       training; and 
   *    No sea time service should be required to qualify for a Basic 
       Level Polar certification.
closed
                                       

37-14
T/S 81
Meeting 41
With regard to grandfathering for existing mariners, MERPAC 
 recommends for:
     *       An advanced endorsement for Polar waters, a minimum of 180 
 days of deck officer service within the previous ten years in Polar waters, of which at least 90 of these days are in a management deck officer position.  No additional training should be required.
     *    A basic endorsement for Polar waters, a minimum of 90 days of 
       service within the previous ten years in Polar waters in an 
       operational or managerial deck officer position.   No additional 
       training should be required.
closed
                                       

38-14
T/S 81
Meeting 41
MERPAC recommends that the information in this report becomes the basis to the U.S. position to HTW 2.
closed
                                       

39-14
No T/S
Meeting 41
MERPAC recommends that the Coast Guard prepare a list of all exam questions which require the use of CFRs for MERPAC.

open
                                       

40-14
No T/S
Meeting 41
MERPAC recommends that the NMC produce and publish module descriptions for every examination module for all grades of licenses.  This information should be posted on the NMC website no later than January 2, 2015.  
open
                                       

01-15
Meeting 41
TS 87
MERPAC submitted one report and seven tables with recommended revisions to be made to Coast Guard NVICs.   These documents may be accessed at http://homeport.uscg.mil/merpac; then click on "meetings/minutes" and click on "Meeting 41A".
Open
                                       

02-15
Mtg 42
TS 87
MERPAC submitted one report spanning 24 NVICs with 10 recommended revisions.  This can be found as Enclosure 7 to the meeting 41 minutes.
Open, being reviewed by CVC-4
                                       

03-15
Mtg 42
TS 30
MERPAC recommends that the military develop business rules in their training programs that support the crosswalks for military to mariner transitions.  These crosswalks need to include on the job training, basic and advancement schools.  This could also have the effect of providing an added value to the recruitment process by providing incentive to potential candidates who may be considering a possible civilian maritime career.
Open
                                       

04-15
Mtg 42
TS 30
MERPAC recommends that each military service define a process so that individual military members can get the information needed so that they can properly determine what experience and training transfers to a mariner credential endorsement. This information will identify any (gap) so that they can efficiently be processed through the NMC for the highest credential for which they are eligible. 
Open
                                       

05-15
Mtg 42
TS 30
MERPAC recognizes that implementation of the Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281. and Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291 for Coast Guard personnel is divided among different USCG offices (CG-1, CG/7 and FORCECOM).  MERPAC recommends that the USCG identifies the single point of contact (from CG-1, CG-7 or FORCECOM) responsible for implementation of the legislation.  Furthermore, MERPAC recommends that the USCG briefs the full committee on their efforts and progress to fulfill the legislation requirements.
Open
                                       

06-15
Mtg 42
TS 30
MERPAC recommends that the Chief of Naval Operations provide resources and support for the development and permanent maintenance of a crosswalk to develop a military to mariner process as defined in Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281 and Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291
Open
                                       

07-15
Mtg 42
TS 30
MERPAC recommends that each military branch develop an in-house team dedicated to developing credentialing processes, crosswalks and maintain communications with the USCG NMC.  This communications with NMC should include updates so that the NMC can serve as an information source for potential military to mariner candidates.  See Sec 305(a) of Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281
Open
                                       

08-15
Mtg 42
TS 30
MERPAC recommends an expeditious rulemaking, if necessary, to implement the Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281, Section 305(a) amendment to Section 7101 (j) of title 46, United States Code and Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291 by the end of FY 15-16.Furthermore, the USCG should amend the MSM to reflect the contents of same legislation.
Open
                                       

09-15
Mtg 42
TS 30
MERPAC commends SOCP on their work to date on this subject and continues to value all industry input to this process.  
Closed
                                       

10-15
Mtg 42
TS 30
MERPAC recommends that the Coast Guard publicize progress made in the military to mariner processes as it occurs.  This could include, but not be limited to, publication within commercial maritime industry publications, "Proceedings", online blogs, websites and internal publications.
Open
                                       

11-15
Mtg 42
TS 30
MERPAC recommends that the Coast Guard regularly communicate with MARAD the developments of crosswalks and training programs to further develop the mariner pool and that this pool of mariners be considered in MARAD's development of a National Maritime Strategy. 
Open
                                       

12-15
Mtg 42
TS 30
MERPAC recommends that in accordance with Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281, Sec 305, regarding maximizing creditability of military training, the NMC accept alternative assessment methods, including Coast Guard and Navy Performance Qualification System (PQS) and Army Duty Performance Tests (DPT), which substantially meet the requirements of the NVIC.
Open
                                       

13-15
Mtg 42
TS 30
MERPAC recommends that the Coast Guard brief this committee on all recommendations that have been generated under Task Statement #30 and the subsequent outcomes.
Open
                                       

14-15
Mtg 42
TS 30
The working group also recommends that the full committee amend Task Statement 30 as follows in order to reflect the Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291 and Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281:
Open
                                       

15-15
Mtg 42
TS 88
MERPAC submitted ten tables with recommended revisions.  These can be found as Enclosures 1a and 1b to the minutes.
Open
                                       

16-15
Mtg 43
No TS
MERPAC recommends that the Coast Guard go to TSA and request a modification to the TWIC requirement that allows flexibility for those who have applied for a renewal to be able to sail foreign for up to 90 days or first U.S. Port after the 37 day extension. This would allow those who may be joining a vessel for which they may be underway for an extended length of time without access to receive a TWIC to continue working in the event of a delay in issuance. 
Open
                                       

17-15
Mtg 43
No TS
MERPAC also recommends that communications and meeting minutes from the TWIC Stakeholders Communication Committee (TSCC) are provided to MERPAC so we may know of possible issues or concerns in advance. 
Open
                                       

18-15
Mtg 43
No TS
MERPAC recommends that the NMC review their procedures to allow for visual verification by the evaluator to be adequate proof of authorization by the mariner that the third party can discuss their evaluation. 
Open
                                       

19-15
Mtg 43
No TS
.MERPAC recommends that the NMC review their procedures to allow for evaluators to contact sea service letter authors, who provide contact information, directly in efforts to clarify the sea service information provided. MERPAC believes this direct line of communication will expedite the receipt of AI requests, reduce the need for future AI requests and facilitate more efficient credentialing.
Open
                                       

20-15
Mtg 43
TS 30
MERPAC recommends that necessary policy for PL 113-281  be developed for implementation of the statute while the rulemaking process goes forward.

Open
                                       

21-15
Mtg 43
TS 30
MERPAC recommends that PL 113-281 Sec 305(a) be implemented immediately.

Open
                                       

22-15
Mtg 43
TS 30
MERPAC recommends that USCG CG-7, CG-1 and ForceCom be invited to MERPAC meetings for continuity of the USCG Military to Mariner effort.

Open
                                       

23-15
Mtg 43
TS 30
MERPAC recommends that Navy SWOS, NETC, U.S. Navy CNO(N42) and other programs be invited to MERPAC meetings for continuity of the Navy Military to Mariner effort.
Open
                                       

24-15
Mtg 43
TS 30
MERPAC recommends that, if invited, the USCG participate in the military to mariner panel that is anticipated to be formed at the January 2016 Surface Navy Association Symposium.
Open
                                       

25-15
Mtg 43
TS 30
MERPAC recommends the Coast Guard collaborate with MARAD and DOL to correct the O*NET titles and produce an accurate number of active merchant mariners.  This affects the demand signal for the federal government and affects the disbursement of financial support for military to mariner training.
Open
                                       

26-15
Mtg 43
TS 30
MERPAC recommends that the National Maritime Center track first time applications for Merchant Mariner Credentials from military applicants, retired or otherwise.  This is to establish a database to determine the effectiveness of MERPAC task Statement #30 and in anticipation of a request from the Federal Military to Mariner round table of CMTS.
Open
                                       

27-15
Mtg 43
TS 30
MERPAC recommends that each service institute permanent assigned billet(s) to ensure the continuous maintenance of crosswalks and course approvals.  Also,  each service should maintain a permanently assigned billet(s) as a Mariner Credentialing Specialist and Mariner Career Counselor.  This should be a mixture of civilian and military personnel so that the continuity of experience and processes can be maintained.  (Fort Eustis Model).
Open
                                       

28-15
Mtg 43
TS 30
MERPAC recommends that the military services authorize tuition assistance payments for credentialing courses that are not accredited  by the American Council on Education (ACE)
Open
                                       

29-15
Mtg 43
TS 30
MERPAC commends SWOS for participating and offers its assistance with the development of crosswalks. They also thank the Radio Technical Commission for Maritime Services RTCM for their support of the August Working Group.
Closed
                                       

30-15
Mtg 43
TS 30
MERPAC recommends that all of the services meet regularly and represent their constituency in order to develop a common framework of crosswalk assessment tools for National Maritime Center submissions.
Open
                                       

31-15
Mtg 43
TS 30
MERPAC recommends holding an added intercessional at Yorktown, VA or Fort Eustis, VA to facilitate discussions on the development of deck crosswalks for the impacted services.
Open
                                       

32-15
Mtg 43
TS 30
MERPAC recommends that the working group revisions to MSM Volume III, Chapter 2 and Table in Figure 2-1 be considered for the latest revision of MSM Volume III and be returned , with comments  at the recommended MERPAC intercessional  in (l) above.
Open
                                       

33-15
Mtg 43
TS 30
MERPAC recommends that the MSM Volume III, Chapter 2 be considered for STCW equivalence and determine acceptable military assessment protocols. 
Open
                                       

34-15
Mtg 43
TS 58
Industry would also like to thank you for the new DE verification tool on the NMC website. We would request that it be corrected to ask for the license number as this is what is listed on the TOAR and is the only number that companies can currently use to verify the validity of the DE and therefore the mariners completed TOAR. There is not a separate DE ID number issued at this time and if there was it is not the same language as the TOAR uses.
Open
                                       

35-15
Mtg 43
TS 58
It was shared that one long standing process for vetting questions is through the protest process during an exam. We know that if this protest question can be the difference between passing or failing, it is addressed immediately, however we are interested in what the process is if it does not impact passing or failing for that specific mariner since it may still be a problematic question. If not already done, can there be a process where the RECs send ALL protests to NMC exam team for review and revision of question if warranted?
Open
                                       

36-15
Mtg 43
TS 58
Lead instructors actively teaching an approved course should be credited at least equally to a student for purposes of renewal/revalidation.
Open
                                       

37-15
Mtg 43
TS 58
With respect to AI letters due to clarification of sea service (i.e. job title, missing info, format of letter, time in department, etc.) and where there is contact information for the author of the letter, the NMC should develop a standard process wherein they contact the author of the letter directly. This would accomplish two things:

		a.	It would clear the inventory backlog of AI items faster as the current process requires contact of the mariner directly, and the mariner then contacts the author for assistance and it would also

		b.	Prevent future issues from the same author for other mariners they are writing letters for as they could revise their template to better suit and more closely align with the needs of the NMC.
Open
                                       

38-15
Mtg 43
TS 58
The NMC evaluation process needs to include a feedback mechanism for AI that affirms or rejects when the clarifying or additional information provided by the applicant was adequate.

		a.	It was brought to my attention that if a mariner submits the requested AI information, thinking they satisfied the request, but it was inadequate, the evaluator does not send another AI letter as they assume the applicant is sending more information. Rather the mariner needs to contact the NMC when they don't hear anything to inquire as to whether or not what they sent was sufficient.  

		b.	Make nmc evaluator training available either digitally or in person for maritime educators when procedural or form changes occur that would impact their candidates. This would help us help you and alleviate the AI burden to mariners and the nmc.
Open
                                       

39-15
Mtg 43
TS 58
I would like to thank the NMC team for their continued efforts to redraw and publish the engineering illustrations and ask that this be done as quickly as possible to assist mariners in properly studying for their respective examinations. Having an ETA for completion would be very helpful. Some of the diagrams refer to very old manuals that in some cases are out of print and unavailable to the mariner for the purposes of study (such as MO-20, and MO-45 for example which are out of a manual from 1954). Is there a way to use more updated manuals that mariners have greater access to for study purposes? This actually highlights why the publishing of the questions and answers is critical for the mariners' ability to properly prepare for his/her examination.
Open
                                       

40-15
Mtg 43
TS 58
It has come to our attention that the Coast Guard Authorization Act of 2015, will make the USCG exempt from FOIA requests relating to any merchant mariner examination question, etc. Can you tell us how this happened and why it MERPAC would not be tasked with this before such a controversial piece of legislation would be drafted and put forward? This could be very damaging to the mariner credentialing process and yet it seems to have been done without any public or industry feedback. Why? 

	a.	Questions need to be vetted and with over 25% of the 700 reference pubs out of date it would be impossible for a mariner to prepare for exams without the publication and exchange of information relating to the exams.

	b.	When compared to other commercial license exams the merchant mariners carry a much heavier burden. 

	c.	Please help us understand the intended outcome.

	d.	Recommendation that merpac discuss this legislation and render an opinion as to our position on the matter for the record.
Open
                                       

41-15
Mtg 43
TS 58
Military to mariner website access would be better on the homepage and must be updated to reflect present legislation.
Closed
                                       

42-15
Mtg 43
TS 87
MERPAC would like a report from the USCG on the status of our previous comments and recommendations.
Open
                                       

43-15
Mtg 43
TS 87
MERPAC recommends for immediate action that the USCG give credit to the principal approved instructors of Coast Guard approved courses with full course credit equal to the students taking the course.
      
Open
                                       

44-15
Mtg 43
TS 87
MERPAC recommends that the USCG provide clarification and guidance as to how instructor and closely related service will apply towards renewal requirements for national and STCW endorsements pre- and post- December 31, 2016.
Open
                                       

45-15
Mtg 43
TS 87
MERPAC also recommends that the USCG provide  a sample letter or language that training and educational institutions can use to document an instructor's service.
Open
                                       

46-15
Mtg 43
TS 87
MERPAC recommends that the USCG update NVIC 3-14 to accurately reflect the correct language that should appear on certificates.  MERPAC also recommends a harmonization of course numbers, content, course approval and certificate language and that information provided in NVIC 3-14.
Open
                                       

47-15
Mtg 43
TS 87
MERPAC recommends that certificates for specific STCW courses (specified by name in NVIC) need not include the specific tasks listed, other than the course name and CFR reference, where appropriate.
Open
                                       

48-15
Mtg 43
TS 87
MERPAC recommends a global check for similar inconsistencies in wording.
Open
                                       

49-15
Mtg 43
TS 87
MERPAC recommends, as above, a global check for similar inconsistencies in wording.
Open
                                       

50-15
Mtg 43
TS 87
MERPAC accept the recommended changes to the following Modules
         o Guidelines on Fatigue
         o Shipboard Fatigue and the Owner/Operator/Manager
         o Fatigue and the Seafarer

Open
                                       

51-15
Mtg 43
TS 87
MERPAC recommends forwarding to Australia
Open
                                       

52-15
Mtg 43
TS 87
That an intersessional be scheduled to review draft changes from Australia of modules	
         o Guidelines on Fatigue
         o Shipboard Fatigue and the Owner/Operator/Manager
         o Fatigue and Ship Design
Closed
                                       

53-15
Mtg 43
TS 91
The choice to have harmonized credentials should be non-mandatory as an "opt-in" choice for the mariner. 
Open
                                       

54-15
Mtg 43
TS 91
For those who do opt-in, they may experience a one-time shortening of their medical certificate or MMC. These consequences should be explained to the mariner if they elect to do so and it will result in a shortening of one credential.
Open
                                       

55-15
Mtg 43
TS 91
Medical certificates should have an issue date at any time up to the valid term of the physical exam, i.e. if a physical is taken 1/1/2014 the issue date can be any date 12/31/2014 or sooner. This should be considered for both national and STCW medical certificates. This recommendation should not apply to those with medical issues.
Open
                                       

56-15
MTG 43
TS 91
The CG should take for action a review of whether requiring training for RADAR renewal every five years makes sense or if underway service on a vessel equipped with RADAR should be considered adequate experience for renewal. This should be reviewed for both national and international credentials. The original requirement appears to be linked to STCW 1978 requirements for refresher training which no longer exists.
Open
                                       

57-15
MTG 43
TS 91
If mandatory training is deemed appropriate, there are a lot of considerations for harmonization of the RADAR to the credential to consider. These include:
         a. If harmonized, what happens when a mariner raises grade and wants a full five year certificate (which includes a new physical)  -  would they need to retake radar?
         b. Is there truly a need to print radar observer on the credential? Most would prefer to keep it there, but if it helps harmonization it may be worth consideration to just stop printing.
Open
                                       

58-15
MTG 43
TS 91
There are about 95k mariners who have a medical certificate without STCW. Mass harmonization may result in serious NPT increases at the NMC. If harmonization is allowed, an implementation strategy should be developed to try and mitigate this risk.
Open
                                       

59-16
MTG 43b
TS 87
MERPAC recommends that these modules be forwarded to Australia in order to provide initial input into their paper on this subject. 
Open
                                       

60-15
MTG 43b
TS 87
MERPAC recommends that the U.S. submit the MERPAC approved Module 2 to HTW as a separate paper and include the following points for HTW to consider regarding the revision of MSC 1014.
   * A FRMS is not the only option for Companies to address fatigue in a risk based manner, as illustrated in our version of module 2.
   * A FRMS would be difficult to implement for many operators
   * Must avoid any additional administrative burdens for the seafarer and the company(e.g. formal FRMS)
   * Must avoid any additional PSC burden on seafarers
   * Must protect the privacy of seafarers
   * Guidance should be written for intended audience (not technical experts, but written at the reading level of general seafarers, KISS keep it short and simple, etc.)
   * Avoid confrontational tones and language in writing (e.g. insidious)
   * Reference all referred to research as per IMO guidelines
   * Measures should be scalable to all modes of maritime transportation. 
   * If HTW accepts the US version of module 2 then module 3(seafarer) must be amended to delete the seafarer's obligations under the FRMS

                                       

61-15
MTG 43b
TS 87
The USCG should ensure whenever the  topic or discussion of fatigue comes up at IMO they should support and ensure proper reference and comment is made that" vessels should at all time be appropriately manned in order to encompass all aspects of maintaining safe operations on board (in accordance with the Principles of minimum safe manning, adopted by the Organization by resolution A.1047(27)).

                                       




                                       




                                       




                                       


