Supporting Statement

for

Standards of Training, Certification and Watchkeeping for Seafarers
(STCW), 

1995, 1997, and 2010 Amendments to the International Convention

OMB No.:  1625-0079

COLLECTION INSTRUMENTS:  Instruction

A.  Justification

1)  Circumstances that make the collection of information necessary. 

The collection of information is needed to ensure that mariners have
completed training and assessment necessary to receive STCW
certification or endorsement.  Collection of information is also needed
to demonstrate to the International Maritime Organization that the
United States has in place certain specific regulations that implement
the international requirements.  The requirements generally reflect
routine practices for U.S. ship operating companies and training
institutions.  The requirements are issued under the authority of Title
46 United Sates Code (U.S.C.) Chapter 71. 

STCW requires seafarers serving on vessels affected by STCW to either
take training, or demonstrate competency, in skills necessary to perform
assigned duties.  The regulation contains collection of information
requirements for the following: documentation of curriculum for training
courses used to receive STCW certification or endorsement; documentation
of practical skills demonstration; documentation of training and
assessment; documentation of medical fitness; maintenance of
seafarers’ records by vessel owners or operators; and, documentary
evidence showing that the personnel serving on passenger ships on
international voyages meet appropriate training.  

There are no forms associated with this COI.  Individuals/companies can
develop whatever works for them as long as the info content follows the
rules.  The CG has published guidance on STCW requirements.  Info can be
found at --   HYPERLINK "http://www.uscg.mil/STCW/stcw-help.htm" 
http://www.uscg.mil/STCW/stcw-help.htm  .  There is no requirement to
share or upload info electronically.

The table below identifies which part of the CFR corresponds to the
subject.

Table 1

STCW requirements: CFR, Subject and Affected Population

46 CFR	Subject and Affected Population

10.404	a) Recording of training and assessment record books.

Candidates for an STCW certificate or endorsement as an officer in
charge of an engineering watch applying to substitute approved training
in place of required service.

Candidates for an STCW certificate or endorsement as an officer in
charge of an engineering watch, for service in a seagoing vessel. 

10.408	b) Documentation of training courses and student’s performance.


c) Documentation and submission of skills demonstration to the National
Maritime Center (NMC).

Training and assessment providers. 

11.1105,

12.905 and

15.1103 	d) Documentary evidence showing that the personnel serving on
passenger ships on international voyages meet appropriate training

All personnel serving on passenger ships 

12.205, 10.301	e) Documentation of medical fitness.

All applicants for new merchant mariner credential w/ STCW endorsement 

Medical examinations every 2 years for all mariners w/ STCW endorsement

15.1107, 12.625, 12.627, 11.1005	f) Maintenance of merchant mariners’
records by owner or operator.

Seagoing vessels subject to the STCW.

Documented evidence of training for personnel with security duties

Documented evidence of security awareness for all other personnel

Documented evidence of foreign sea service

15.1111	g) Posting of watch schedules.

Seagoing vessels subject to the STCW.



a)  Recording of training and assessment record books.  Candidates for
an STCW certificate or endorsement as an officer in charge of a
navigational watch or engineering watch may use a combination of
training and sea service to meet STCW requirements.  When seagoing
service is combined with training in order to qualify for STCW
certification, training must be documented in a Coast
Guard-accepted-training-record book.  Documentation of sea-service will
ensure that seafarers that opt to use sea-service as the basis for their
qualifications have the experience that will allow them to meet the
standards of competency outlined in STCW.

b)  Documentation of training courses and student’s performance. 
Where courses are required, objectives and criteria used for training
not subject to Coast Guard approval must be documented and available for
evaluation.  Documentation of course objectives and training criteria
will ensure that training and assessment activities prepare seafarers to
meet the standards of competency outlined in STCW.

c)  Documentation and submission of skills demonstration to the NMC. 
Under STCW, when courses are not required, candidates for original
licenses and license renewals must demonstrate competency in skills
necessary to perform assigned duties.  Evidence of demonstrated
competency must be documented and submitted to the NMC in order for
candidates to receive STCW certification or documentation.

d)  Documentary evidence showing that the personnel serving on passenger
ships on international voyages meet appropriate training.  STCW
Regulation V/3 requires that each mariner who completes the required
training receive a certificate.  Every five years, completion of a
refresher course would be documented in the mariner’s record and it
would show that the mariner has received such training, or has otherwise
maintained competence in the required areas of knowledge, understanding
and proficiency. 

e)  Documentation of medical fitness.  Applicants for merchant
mariners’ documents must submit written reports from medical
practitioners stating that they are medically fit to perform assigned
duties once every two years.  Documentation of medical fitness will
ensure that seafarers are fit to perform assigned duties.

f)  Maintenance of merchant mariners’ records by owner or operator. 
Ship companies must ensure that information regarding the medical
fitness, experience, and competency of seafarers serving on any vessel
is maintained and accessible to management.  Seafarers’ records
maintained by the owners/operators would be subject to Coast Guard
review in its oversight function to ensure that seafarers employed on
vessels affected by STCW have the skills and fitness level necessary to
perform assigned duties.  

g)  Posting of watch schedules.  Rest hour minima will require posting
of rest hour schedules for each vessel.  These recordkeeping
requirements are largely consistent with good commercial practices and
dictate good seamanship for safe navigation.

This information collection supports the following strategic goals:

Department of Homeland Security

Prevention

Protection

Coast Guard

Marine Safety

Protection of the Natural Resources

Prevention Policy & Response Policy Directorates (CG-5P & CG-5R)

Reduce crewmember deaths and injuries on U.S. commercial vessels

Reduce the risk of major loss of life on passenger vessels

Reduce the discharge of oil into the marine environment

Reduce the discharge of chemicals into the environment

2)  Purpose of the information collection.  

The purpose of the information collection is to ensure compliance with
international requirements and to maintain acceptable quality in
activities associated with training and assessment of merchant mariners.
 Documentation of objectives and criteria used for training and
assessment would ensure that training programs meet the objectives
required by the IMO.  Documentation of skill demonstration and
sea-service would ensure that seafarers have the skills and experience
necessary to perform assigned duties.  Ship company record maintenance
and rest hour posting requirements would make companies responsible for
verifying the credentials of seafarers employed in their service.

3)  Considerations of the use of improved technology.  

The information collection may be in written or electronic form.  There
are no forms, structured format or system required for maintaining the
information.  We estimate that about 50% of the reporting and
recordkeeping requirements can be done electronically.  

4)  Efforts to identify duplication.  

There are no State or local regulations relating to this issue.  No
similar information collection is conducted by other Federal agencies. 
Similar information does not exist.

5)  Methods used to minimize the burden to small businesses if involved.


Domestic law generally excludes uninspected passenger vessels from
regulations applicable to ocean-going vessels, the Coast Guard exempts
personnel serving on uninspected passenger vessels from STCW
requirements.  Additionally, domestic regulations for small passenger
vessels and for seagoing vessels less than 200 gross register tons are
considered equivalent to STCW standards.  

6)  Consequences to the Federal program if collection were not conducted
or conducted less frequently. 

Failure to effect the required collection of information relating to
skills and experience could render unverifiable compliance with STCW
training and assessment requirements.  Without an information
collection, there would be no practical means for holding the owner or
operator of a seagoing vessel accountable for inadequate navigational
safety practices.  Also, there would be no way to determine whether
seafarers employed on vessels covered under STCW had successfully
completed training or demonstrated competency in skills necessary to
perform assigned duties.

7)  Special collection circumstances.  

This information collection is conducted in manner consistent with the
guidelines in 5 CFR 1320.5(d)(2).

8)  Consultation.

A 60-day Notice will be published in the Federal Register to obtain
public comment on this collection.  

9)  Provide any payment or gift to respondents.  

There is no offer of monetary or material value for this information
collection.

10)  Assurances of confidentiality provided to respondents.  

There are no assurances of confidentiality provided to the respondents
for this information collection.  This information collection request is
covered by the Marine Information for Safety and Law Enforcement (MISLE)
and Merchant Mariner Licensing and Documentation System Privacy Impact
Assessments (PIAs) and the MISLE and Merchant Seamen’s Records System
of Records Notices (SORNs).  Links to the aforementioned PIAs and SORNs
are provided below:

  HYPERLINK
"https://www.dhs.gov/sites/default/files/publications/privacy_pia_uscg_m
isle.pdf" 
https://www.dhs.gov/sites/default/files/publications/privacy_pia_uscg_mi
sle.pdf   

   HYPERLINK
"https://www.dhs.gov/publication/dhsuscgpia-015-merchant-mariner-licensi
ng-and-documentation-system" 
https://www.dhs.gov/publication/dhsuscgpia-015-merchant-mariner-licensin
g-and-documentation-system   

  HYPERLINK
"https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14906.htm" 
https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14906.htm   

  HYPERLINK
"https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14911.htm" 
https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14911.htm   

11)  Additional justification for any questions of a sensitive nature.  

There are no questions of sensitive language.

12)  Estimate of annual hour and cost burden to respondents.  

The estimated annual number of respondents is 35,116. 

The estimated annual number of responses is 46,738.  

The estimated annual hour burden is 29,366 hours.

The estimated annual cost burden is $2,080,980. 

The burden to respondents is provided in Appendix A.  Respondents are
merchant mariners with a least 1 active STCW endorsement, training
providers that offer STCW-related course, and U.S. Flag vessels required
to be manned by mariners with STCW endorsements.  All wage rates used
are in accordance with the current edition of COMDTINST 7310.1(series)
for “Out-Government” personnel.  

a)  We estimate that it takes 1 hour per recording of a training and
assessment record and that a record is done by a technical specialist. 
The position of a technical specialist is equivalent to a GS-13. 
Additionally, we estimate that annually about 0.3% of the total STCW
mariner population uses this type of record.  

b)  We estimate that it takes 1 hour to document a training course or a
student’s performance and that a record is done by an administrative
specialist.  The position of an administrative specialist is equivalent
to a GS-7.  Additionally, we estimate that this action is taken once for
each STCW training provider and for each STCW course.  

c)  We estimate that it takes 0.5 hours to record and submit a skills
demonstration to the NMC and that that action is done by a technical
specialist.  The position of a technical specialist is equivalent to a
GS-13.  Additionally, we estimate that annually about 0.3% of the total
STCW mariner population uses this type of record.  

d)  We estimate that it takes about 5 minutes (0.083 hours) to record
that personnel serving on passenger vessels are trained as required by
STCW Regulation V/2 and that the action is done by a technical
specialist.  The position of a technical specialist is equivalent to a
GS-13.  Additionally, we estimate that annually about 2% of the total
STCW mariner population uses this type of record.  

e)  We estimate that it takes about 15 minutes (0.25 hours) by a medical
practitioner and 5 minutes (0.083 hours) by a mariner to record the
mariner’s medical fitness.  The position of a medical practitioner is
equivalent to a GS-15, and the mariner is equivalent to a GS-13. 
Medical fitness reviews are required every 2 years.  

f)  We estimate that it takes 3 hours to maintain seamen records per
voyage on each U.S. Flag vessel with STCW mariners and that the work is
done by an administrative specialist.  The position of a technical
specialist is equivalent to a GS-7.  Additionally, we estimate that each
vessel annually has 3 voyages (i.e., crew changes).  

g)  We estimate that it takes 15 minutes (0.25 hours) to post a watch
schedule per voyage on each U.S. Flag vessel with STCW mariners and that
the work is done by an administrative specialist.  The position of a
technical specialist is equivalent to a GS-7.  Additionally, we estimate
that each vessel annually has 3 voyages (i.e., crew changes).  

13)  Estimate of annualized capital and start-up costs.  

There are no recordkeeping, capital, start-up or maintenance costs
associated with this information collection.

14)  Estimates of annualized cost to the Federal Government.  

The annualized Federal Government cost estimate is $781,770 (see
Appendix B).  We estimate that it takes a member of the Coast Guard
about 30 minutes to review each (a) training and assessment record, (b)
training course or student performance record, (c) skills demonstration,
or (d) record that personnel serving on passenger vessels are trained as
required by STCW Regulation V/2.  We estimate that it takes a member of
the Coast Guard about 30 minutes to review each (e) medical fitness
record.  We estimate that it takes a member of the Coast Guard about 30
minutes to review each (f) seamen record and (g) each watch schedule. 
Additionally, for seamen records and watch schedules, we estimate that
the Coast Guard will spot check 25% of all records each year during
inspections, boarding or post-casualty investigations.  The Coast Guard
member conducting each of these activities is analogous to a Lieutenant
Junior Grade (LTJG, O-2).  The wage rate used is in accordance with the
current edition of COMDTINST 7310.1(series) for “In-Government”
personnel.  

15)  Reasons for change in the burden.  

The change in burden is an ADJUSTMENT due to a change (i.e., decrease)
in the estimated annual number of responses.  There is no proposed
change to the reporting requirements of this collection.  The reporting
requirements, and the methodology for calculating burden, remain
unchanged.  

16)  Plans for tabulation, statistical analysis and publication.  

This information collection will not be published for statistical
purposes.

17)  Approval for not explaining the expiration date for OMB approval.  

The Coast Guard will display the expiration date for OMB approval of
this information collection. 

18)  Exception to the certification statement.  

The Coast Guard does not request an exception to the certification of
this information collection.

B.  Collection of Information Employing Statistical Methods  

This information does not employ statistical methods.

  As a merchant mariner with an STCW endorsement only needs to take a
medical examination every 2 years, the STCW mariner population used in
this ICR is 50% of the total mariner population with STCW endorsements. 


  This population is estimated by using the Coast Guard’s Marine
Information for Safety and Law Enforcement (MISLE) database—searching
for Active, Inspected, Documented, US Flag Vessels with route type
'Oceans' and GRT, GT_ITC, or GRT_Simplified greater than or equal to
200.

1625-0079  

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