New NMC policy letter needed.

[anchorman]

It seems to me, with out a doubt, that NMC needs to publish a new policy letter that covers those licensed mariners who hold licenses that do not have OICNW on their STCW, but hold licenses that are considered "operational Level" by STCW.
The USCG has effectively changed the definition of "Officer in Charge of a Navigational Watch" to "Mate in Charge of a Navigational Watch" because of the lack of policy on operational level Masters.
Current policy is leaving way too much up for interpretation and there lies the inconsistency. Having a change of guard on the second floor should not affect the outcome of an applicant one way or another, and that has obviously been the case.
The problem starts with not having any STCW policy at all regarding operational level (500ton & 1600ton) Masters licenses, which are also OICNW.
A new broad policy should simply state that "ANY" applicant Master that currently has an "operational level" license, that either applies for an upgrade, or wants have OICNW endorsed of their STCW, and has a current STCW, can do so by: 1) By completion of assessments 2) Taking OICNW test.
OICNW shall be endorsed to STCW certificates for all 500ton&1600ton Masters licenses, but if the Master license was issued under the old system, 1) & 2) would have to be completed before upgrading.
Policy letter 01-02 should be specified that the enclosed requirements are for original applicants and upgrading applicants that have never held an operational level license.

It's just plain stupid that you can actually get a Master license with less requirements than a Mates license under current policy. You can have a Mate OSV and go to 1600 ton Master because the current policy does not specify the Master license as an OICNW license, but if you apply for a 1600 ton Mate, forget about it, All of 01-02 applies. Nice little loop hole indeed. And, I can think of five or six more examples.

[Casper]

Anchorman, Thanks for that post man. I have recently upgraded from 100M to 500M and was really confused about the whole OICNW assessments. Here's a copy of my credential details... As you can see, I have not completed any OICNW assessments. Does the STCW regulation II/2: Master,Chief Mates(500 Gross Tons or More) mean I don't have to take the assessments ?
International
Regulations II/2: Master, Chief Mates (500 Gross Tons or More)
VI/5: Vessel Security Officer
Int'l Capacities Limitations Vessel Security Officer Master Limited to service on motor propelled offshore supply vessels of not more than 3,000 Gross Tons (ITC Tonnage). Not Valid for service on ARPA equipped vessels. Valid for domestic near coastal voyages only.
Master Limited to vessels of not more than 500 Gross Registered Tons (Domestic Tonnage). Not Valid for service on ARPA equipped vessels. Valid for near coastal voyages only.
Domestic
Domestic CapacitiesLimitations Deck Officer - Master Of Steam or Motor Vessels Of Not More Than 500 Gross Registered Tons (Domestic Tonnage) Upon Near Coastal Waters. For vessels under 200 GRT (Domestic Tonnage), 500 GT (ITC Tonnage) on domestic voyages only, the holder of this credential meets the STCW 1995 regulations without further endorsement. Radar Observer (Unlimited)
Deck Officer - Master Of Offshore Supply Vessels Of Not More Than 3000 Gross Tons (Itc Tonnage) Upon Domestic Near Coastal Waters. Radar Observer (Unlimited).

It seems to me, with out a doubt, that NMC needs to publish a new policy letter that covers those licensed mariners who hold licenses that do not have OICNW on their STCW, but hold licenses that are considered "operational Level" by STCW.
The USCG has effectively changed the definition of "Officer in Charge of a Navigational Watch" to "Mate in Charge of a Navigational Watch" because of the lack of policy on operational level Masters.
Current policy is leaving way too much up for interpretation and there lies the inconsistency. Having a change of guard on the second floor should not affect the outcome of an applicant one way or another, and that has obviously been the case.
The problem starts with not having any STCW policy at all regarding operational level (500ton & 1600ton) Masters licenses, which are also OICNW.
A new broad policy should simply state that "ANY" applicant Master that currently has an "operational level" license, that either applies for an upgrade, or wants have OICNW endorsed of their STCW, and has a current STCW, can do so by: 1) By completion of assessments 2) Taking OICNW test.
OICNW shall be endorsed to STCW certificates for all 500ton&1600ton Masters licenses, but if the Master license was issued under the old system, 1) & 2) would have to be completed before upgrading.
Policy letter 01-02 should be specified that the enclosed requirements are for original applicants and upgrading applicants that have never held an operational level license.

It's just plain stupid that you can actually get a Master license with less requirements than a Mates license under current policy. You can have a Mate OSV and go to 1600 ton Master because the current policy does not specify the Master license as an OICNW license, but if you apply for a 1600 ton Mate, forget about it, All of 01-02 applies. Nice little loop hole indeed. And, I can think of five or six more examples.

[anchorman]

Casper,
That is part of the stupidity. Because you went to 500 ton Master, you do not need OICNW. You will not need it when you go to 1600 ton Master. OICNW does not cover Masters at all, only Mates. So, unless you want to get your 3rd Mate, you will never see it. That's where the problem starts because for years, many mariners have upgraded to 3rd Mate from 1600 ton Master with the assessments and by taking the OICNW test. Suddenly, NMC is requiring all of the OICNW course too. Does it make sense at this point to learn the points of a compass and port from starboard? It's a waste of time.

[Casper]

Yeah, makes no sense at all.... Thanks for the post. I'm sure it will be help to many others on GCapt

[water]

Anchorman and Casper - Many thanks for the posts. Capt Fran had mentioned this loophole earlier, and I've been trying to sort it all out.

So what classes did you end up taking for your 500 T, Casper?

I have a 100 T NC, and was first licensed in 1981. Never thought I'd want more than a 100 T, but now I'm at a point in my life/career that I'd like to get my 500 T Oceans.

[Casper]

Water,

Before I even applied at the CG I took the following classes:
Bridge Resource Managment
Med Care Provider + renewed First Aid
Adv Fire Fighting
Flashing Lights

Keep in mind that you will also need to get Able Seaman, which I already had. Also apply for STCW if you already don't have it, and take VSO class. That was pretty much it...


quote=water;17464]Anchorman and Casper - Many thanks for the posts. Capt Fran had mentioned this loophole earlier, and I've been trying to sort it all out.

So what classes did you end up taking for your 500 T, Casper?

I have a 100 T NC, and was first licensed in 1981. Never thought I'd want more than a 100 T, but now I'm at a point in my life/career that I'd like to get my 500 T Oceans.[/quote]

[Shellback]

What does the STCW list for someone with 500 Ton Master license? Only the courses that are listed in the above post.. If you don't need the OICNW could you still serve as a mate with it?

[anchorman]

Mr.Stalfort send me an email Friday to address our concerns about policy 01-02. Above all else, he wants to make sure all policies are clear, not just for us, but his evaluators as well. He is aware of this policy and the ambiguity.
As most policy comes from USCG headquarters, which I think is a good thing, (I never did think policy and application of the same policy should happen under the same roof), he has asked the Mariner Credentialing Policy Division at Coast Guard Headquarters to review this and he expects something within the next few weeks.
Hopefully something happens rather quickly. Several applicants have decided to wait on upgrades considering these recent issues.
I think this will fall near Cavo's desk.

[stevefoster]

Mr.Stalfort send me an email Friday to address our concerns about policy 01-02. Above all else, he wants to make sure all policies are clear, not just for us, but his evaluators as well. He is aware of this policy and the ambiguity.
As most policy comes from USCG headquarters, which I think is a good thing, (I never did think policy and application of the same policy should happen under the same roof), he has asked the Mariner Credentialing Policy Division at Coast Guard Headquarters to review this and he expects something within the next few weeks.
Hopefully something happens rather quickly. Several applicants have decided to wait on upgrades considering these recent issues.
I think this will fall near Cavo's desk.

Anchorman, Thanks for the informative post, my last reply from my evaluator regarding my application for 3rd Mate from 1600 Ton Ocean Master is.......she has sent it up the ladder for further review.........
This means to me that she cannot discern what PL 01-02 11(d) is means and how it applies to my case. I am wondering if a new policy letter is really necessary or if the evaluators should be better trained in their jobs. I would hate to see an new policy letter come out and possibly confuse the issue even more. I believe a 5th grader could read what already exists and do a better job of applying what is written to any and all practical purposes for what it is intended. I see no gray area in PL 01-02 11(d). I think that if a letter needs to be written it needs to be a letter of instruction to the evaluators in WV on how to read the existing PL.........your post is encouraging though.............

[dap7777]

Well having just got an answer myself on September 23, 2009, I can tell you what that person up the ladder is going to say: First, a 1600 Master Ocean like me has to provide assessments for his 3d Unlimited application (which I did); second, I also am supposed to go back and take those damn 16 courses. I plan on appealing her decision and to cite both sections 11(c) and 11(d) of Policy Letter 01-02 and stress that I hold an operational level license, but it seems to me my position is weak. What galls me is the huge number of 1600 masters going to 3d Unlimited preceding me who sqeaked through the door without doing the 16 courses (and some of them did not even do the assessments). Talk about (NMC) moving the goalposts! Looks like the door is closed! Can I claim I'm grandfathered? Can I cry foul? We shall see.

mariner7

[stevefoster]

Well having just got an answer myself on September 23, 2009, I can tell you what that person up the ladder is going to say: First, a 1600 Master Ocean like me has to provide assessments for his 3d Unlimited application (which I did); second, I also am supposed to go back and take those damn 16 courses. I plan on appealing her decision and to cite both sections 11(c) and 11(d) of Policy Letter 01-02 and stress that I hold an operational level license, but it seems to me my position is weak. What galls me is the huge number of 1600 masters going to 3d Unlimited preceding me who sqeaked through the door without doing the 16 courses (and some of them did not even do the assessments). Talk about (NMC) moving the goalposts! Looks like the door is closed! Can I claim I'm grandfathered? Can I cry foul? We shall see.

mariner7

Dap, who is your assessor? Mine is Abigail Cochenour. She sent my paper work up the ladder and as yet I have no decision from whoever is up the ladder.

[rjbpilot]

Anchorman, have you heard anything back from stalfort? It's been a few weeks now. J.cavo has been pretty silent lately......

[anchorman]

Anchorman, have you heard anything back from stalfort? It's been a few weeks now. J.cavo has been pretty silent lately......

It's been a month, but we are talking about government policy. Sometimes, even for them, the hardest thing is to get those together in one room to discuss this issue. Hopefully, we get something soon. If it is an issue that Mr.Cavo will deal with directly, he most likely cannot (as a matter of ethics) discuss this in the forum.

Here is the emails from last month......

Capt Fendley,
Sorry for the delayed response but I wanted to make sure I updated you on what we are doing to clarify the policy. We have received numerous requests to clarify and/or revise the policy, which was established some years ago, and we understand your concerns. I want to make sure the policy is clear so that you and other in the industry understand it, and more importantly my evaluators at NMC are consistent in the application of the policy. I've asked the Mariner Credentialing Policy Division at Coast Guard Headquarters to review this and I expect to have some information to you and others within the next few weeks.

Regards,
Dave



CAPT David C. Stalfort
Commanding Officer
National Maritime Center
304-433-3401

For more information on Mariner Licensing and Documentation go to http://homeport.uscg.mil and select Merchant Mariners under the list of Missions.

-----Original Message-----
From: dinochouestseatoshore
Sent: Tuesday, August 25, 2009 10:53 AM Eastern Standard Time
To: Stalfort, David CAPT
Cc: senator@landrieu.senate.gov
Subject: NMC policy 01-02

Mr. Stalfort,

My name is Captain Thad G. Fendley. I am an Unlimited Master and serve as Captain on the AHTS Dino Chouest. I am writing you specifically regarding policy letter 01-02. Several disturbing issues have arisen lately regarding this policy, its interpretation, and its effect upon upgrading applicants. There has been an obvious change in precedence, and I’m trying to find out why in an effort to help those who are being directly affected. My concern is grounded in the fact that I have appealed a similar interpretation to Captain Fink and this exact issue was resolved. I’m not sure if a new GS or active duty employee has been added to your team, but it’s too coincidental for these many applicants, just over the last 30 days, to get the same contrary result out of NMC.

The particular issue in question regarding policy letter 01-02 is the OICNW requirements toward upgrading applicants. It seems lately that NMC is requiring “all” applicants for 500ton mate, 1600ton mate, and 3rd mate unlimited fulfill “all” requirements as if they were applying for an original issue without consideration as an upgrade. As you know, policy letter 01-02 was specifically written for guidance on OICNW requirements regarding the 500ton, 1600ton, and 3rd mates because these are the three licenses an original applicant can apply for which OICNW requirements do apply. There is also a section (11) that applies particularly to upgrading applicants that have a current STCW certificates. Sections (11a)(11b)(11c)(11d)(11e)and (11f) are very important for several reasons. First, you obviously need a current license and STCW. Second, your STCW is not currently endorsed as OICNW. Otherwise, if you had OICNW, Section (11) would not apply at all, and neither would the entire policy letter because you have previously met the requirements. Section (11) applies directly to those applicants, such as a 1600 ton Master that may have a current STCW, but only endorsed as RFPNW, upgrading to 3rd Mate.

My current company (Edison Chouest Offshore) has produced many mariners over the years since the draft of policy letter 01-02 based on Section (11), but this career path has affectively been closed by a recent interpretation of not allowing its application in any situation. That is simply not consistent with the policy, STCW, and recent history. I ask for this to be investigated further. All mariners expect consistency out of the National Maritime Center to make life decisions at the kitchen table. Thank You for your time.

Best Regards,

Captain Thad G. Fendley

[Capt. Fran]

Anchorman,
Nice summation of the issue, and thanks for representing your fellow mariners!

[rjbpilot]

Very nice indeed. Thank you sir.

[jdcavo]

...J.cavo has been pretty silent lately......

You're all talking about appeals. My office works on appeals from NMC, so I can't get involved in it here.

[rjbpilot]

Thank you Jim, we all understand and respect that.

[Capt Leigh]

Thanks Anchorman,that was well written and on the money.We apprecite your effort even though you don't "have a dog in this fight"

[Capt Brian]

This is the next letter that I am sending out, please let me know of anything that I can add or remove to make this the best letter to resolve our issues.

Thanks - Brian

Good morning. I have read the IMO STCW Code and according to Chapter II, Section A-II/2 (Mandatory minimum requirements for certification of master and chief mates on ships of 500 gross tonnage or more) paragraph 2:

“The minimum knowledge, understanding and proficiency required for certification is listed in column 2 of table A-II/2. This incorporates, expands and extends in depth the subjects listed in column 2 of table A-II/1 for officers in charge of a navigational watch.”

The following statement is on my STCW certificate, “who has been found duly qualified in accordance with the provisions of regulation(s) II/4, VI/2, II/2, IV/2 & A-WAV of the above Convention, ….”.

If all 1600 Masters have II/2 on their STCW certificate it seems to reason that, according to the STCW Code, they meet the requirements for II/1 (Officer In Charge of a Navigational Watch) because II/2 INCORPORATES II/1 INTO the requirements of II/2. I as well as many other mariners feel the same way about this issue. We are not interpreting what we are reading, just following what is in print. It is clearly defined in Policy Letter 01-02, CFR’s, and the IMO STCW Code (Which, according to the CFR’s, The IMO STCW Code is INCORPORATED).

If this is not the intent of the USCG licensing of having II/2 listed on the STCW certificates for 1600 Master, then quit possibly ALL 1600 Master STCW certificates need to be rewritten. Is there a time frame that we, the mariners wishing to upgrade to 3rd Mate Unlimited can expect resolve on this issue? It is rather difficult to refute what is written in the “standards”.

[stevefoster]

This is the next letter that I am sending out, please let me know of anything that I can add or remove to make this the best letter to resolve our issues.

Thanks - Brian

Good morning. I have read the IMO STCW Code and according to Chapter II, Section A-II/2 (Mandatory minimum requirements for certification of master and chief mates on ships of 500 gross tonnage or more) paragraph 2:

“The minimum knowledge, understanding and proficiency required for certification is listed in column 2 of table A-II/2. This incorporates, expands and extends in depth the subjects listed in column 2 of table A-II/1 for officers in charge of a navigational watch.”

The following statement is on my STCW certificate, “who has been found duly qualified in accordance with the provisions of regulation(s) II/4, VI/2, II/2, IV/2 & A-WAV of the above Convention, ….”.

If all 1600 Masters have II/2 on their STCW certificate it seems to reason that, according to the STCW Code, they meet the requirements for II/1 (Officer In Charge of a Navigational Watch) because II/2 INCORPORATES II/1 INTO the requirements of II/2. I as well as many other mariners feel the same way about this issue. We are not interpreting what we are reading, just following what is in print. It is clearly defined in Policy Letter 01-02, CFR’s, and the IMO STCW Code (Which, according to the CFR’s, The IMO STCW Code is INCORPORATED).

If this is not the intent of the USCG licensing of having II/2 listed on the STCW certificates for 1600 Master, then quit possibly ALL 1600 Master STCW certificates need to be rewritten. Is there a time frame that we, the mariners wishing to upgrade to 3rd Mate Unlimited can expect resolve on this issue? It is rather difficult to refute what is written in the “standards”.

I have read the same thing and this is my basis for my argument that the evaluators are not doing their homework. It seems that, like the insurance companys, they have a predetermined NO in their minds and find any ill perceived reason to apply that NO to our applications to test without reading the policies and Codes in whole. The only part of your letter that I saw as a small mistake was in the last paragraph the word quite was misspelled. But they probably won't notice because they would have to read the whole letter to get to that part...............