STCW Code (1600 Master to 3rd Mate)

[Capt Brian]

Can someone explain to me why my STCW certificate(1600 Master) has the following statement "who has been found duly qualified in accordance with the provisions of regulations(s) II/2 (and some others not relevant to this post)".

After reading the STCW Code Chapter II, Section A-II/2, it states the following "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."

Now, maybe I am just not that bright, but what I understand from reading the STCW Code is that A-II/2 is HIGHER then a A-II/1, and it clearly states that A-II/1 is INCORPORATED into A-II/2. So, why then, do I as well as others not qualify for a 3rd Mate Unlimited license and are being required by the NMC to take, as Luther Greer put it to me once, "those $20,000 worth of classes" to DOWN GRADE to a 3rd Mate Unlimited.

Curious what the thoughts of everyone on here is. Please, do not hesitate to tell me to "step away from the pipe" on this issue and let me know I am off my rocker........

Thanks - Brian

[seadawg]

that seems to be the $64k question for many of the 1600tn masters on here..it would appear that the USCG's logic as to what is inherent doesn't apply in this particular situation??

[anchorman]

You pretty much nailed that.

It comes back to the fact that there in no policy on operational level masters, and what the NMC reverts to is RFPNW as the sole guide for operational master ratings, which makes absolutely no sense because it basically rates a master as an AB when seeking OICNW.

I wish NMC would wake up and realize what Captain Fink and all of the REC Chiefs were aware of in 2002 when the policy was written. That 'Mate' comes before 'Master' - that fact was so inherent a need for policy was not even undertaken. Fast-forward to today, now that most are retired and moved on to other things -they were too generous in the ability of their successor's to grasp what they thought was obvious seven years ago.

WAKE UP COAST GUARD!!!!

Officer in Charge of a Navigational Watch (OICNW)
The fact of the matter is this, Policy letter 01-02 specifically talks about 500 ton "Mate", 1600 ton "Mate", and 3rd "Mate" unlimited because these are the three licenses that an "Original" applicant can apply for in which OICNW will apply, NOT because a 500 & 1600 ton Master are not considered in charge of a navigation watch as the term suggests.

This issue just pisses me off because of the fact that it's so obvious to mariners by reading the STCW code, understanding the term "Officer", "in-charge",and "Navigation Watch".......and last but not least - Has anyone ever applied the assessments to a 1600 ton Master when upgrading to 3rd Mate? I'm almost embarrassed for the Coast Guard when I'm assessing a guy on his 7th issue master license and asking him to show me how to give 10 degrees starboard rudder.

It's really past stupid at this point for me.

[djackson]

Captain Brian and all,

I am "in the same boat"; 1600T Master Oceans applying for 3rd Unlimited. I was initially denied and they said I needed assessments according to Policy Letter 01-02. I have asked for reassessment after reading 01-02 and CFR's carefully.

Policy Letter 01-02, Page 1-6 states:

"d. An applicant who holds either a 500GRT or a 1,600 GRT license and STCW certification that were based on service that began on or after 1 August 1998 and wishes to apply for a third mate's license must acquire the sea service required by 46 CFR 10.402 and 10.407. No further testing and assessments are required."


Also I looked up 2008 CFR 46, CH. 1, Part 10.407 (c), which states:
(c) While holding a license as master of ocean or near coastal steam
or motor vessels of not more than 1,600 gross tons, one year of service
as master on vessels of over 200 gross tons operating on ocean or near
coastal waters will qualify the applicant for a license as third mate of
ocean or near coastal steam or motor vessels of any gross tons.

My application is in its 15th week. I now regret not doing the silly assessments and getting this over with. It seems that the regulations, as written, are being ignored in this case. I call NMC a couple times a week to check on my upgrade status and have not been able to get anyone to give me a time frame for approval/denial. My advise to anyone in this situation is fill out the assessments and forget about attempting logic or a fair assessment using regs with the NMC. They have lost it.
Good luck............

[anchorman]

Can someone explain to me why my STCW certificate(1600 Master) has the following statement "who has been found duly qualified in accordance with the provisions of regulations(s) II/2 (and some others not relevant to this post)".

After reading the STCW Code Chapter II, Section A-II/2, it states the following "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."

Now, maybe I am just not that bright, but what I understand from reading the STCW Code is that A-II/2 is HIGHER then a A-II/1, and it clearly states that A-II/1 is INCORPORATED into A-II/2. So, why then, do I as well as others not qualify for a 3rd Mate Unlimited license and are being required by the NMC to take, as Luther Greer put it to me once, "those $20,000 worth of classes" to DOWN GRADE to a 3rd Mate Unlimited.

Curious what the thoughts of everyone on here is. Please, do not hesitate to tell me to "step away from the pipe" on this issue and let me know I am off my rocker........

Thanks - Brian

You are right, and the main thing here is more along the lines of Coast Guard policy. Remember that STCW is a minimum standard. How this minimum standard is applied is totally up to them. The biggest problem is the ambiguity in Coast Guard policy, not STCW. The uneven handedness of application of policy not only damages what NMC is trying to do, but it deeply effects the mariner because we rearrange our lives, schedules, and budgets to take classes, complete assessments, and try to find the time for a home life. Then, on top of all of that, most of these requirements have to be done before submitting an application just to find out something changed, not in the policy, but the interpretation of it. Outside of everything else, that simply is not fair to the mariner, and I would go as far as including the evaluators at NMC.
A precedence has clearly been set, and I am an example of that (all of my unlimited upgrades were post 2002), as are hundreds of other mariners in the application of policy letter 01-02. The Coast Guard needs to take a hard look at that career path and erase the ambiguity by specifically identifying operational level masters licenses. As you pointed out, it is well within the construct of STCW, but as far as we know, it could have been an STCW auditor that shut this career path down by asking for training certificates on a newly issued 3rd Mate, that was a 1600 ton Master, and this material could not be produced.
Either way, NMC has a clear obligation to fix this self-imposed mess of things so people like yourself know what to do.

[stevefoster]

Let's keep working on this, I'm writing as many emails as I can to as many people as I can including my Congressman Jo Bonnor. I am supposed to hear from Capt. Stalfort today.................

[stevefoster]

Let's keep working on this, I'm writing as many emails as I can to as many people as I can including my Congressman Jo Bonnor. I am supposed to hear from Capt. Stalfort today.................

Captain,
Attached is the approval to test letter for 3rd Mate AGT upon oceans, the original letter will be mailed with the new Merchant Mariner Credential(MMC) adding Master of Towing Vessels upon oceans and Western Rivers. The credential production teams should print first thing in the morning and I left instructions for 2-day express mail. I have waived the issuance fee for the new MMC and the issuance fee already paid prior will be applied to the 3rd Mate issuance upon passing the exams. If any problems arise please feel free to contact me, the below phone number is my direct number.

Jennifer Hogge
Merchant Mariner Evaluation Specialist
National Maritime Center
100 Forbes Drive
Martinsburg, WV 25404
304-433-3654
(Fax) 304-433-3412

[Capt Brian]

From: Lincoln.D.Stroh@uscg.mil
Sent: Monday, September 28, 2009 5:41 PM
Cc: Harden, Luke; Stalfort, David CAPT; Fagan, Linda CAPT; Argenti, Laticia CAPT
Subject: RE: Policy Letter 1-02 and 46 CFR 11.401 + IMO STCW Code

Capt.

By now, you have seen the below email from CAPT Stalfort's staff about your email and its processing as a "reconsideration." CAPT Stalfort's staff will evaluate your request in light of current policy, in compliance with the current regulations, and in the spirit of the requirements of STCW. In order to preserve the integrity of the "reconsideration" and "appeal" processes, I cannot discuss the particular application of the policy, regulations and code in this email reply. However, if NMC's written response to your reconsideration is not to your satisfaction, you may "appeal" to our office at CG Headquarters.

In that we have had numerous, recent discussions between our offices and NMC to clarify the subject policy letter, regulations and STCW code, and our offices oversee policy and regulations for NMC, we can provide the latest interpretation of these documents to your appeal, which may be more favorable than lower reconsiderations. The clarification of our latest interpretations will be spelled out, more timely for you, in the reconsideration and appeal process. Please continue to follow this process as we work to publish our clarifications.

In that NMC will respond to your reconsideration by Friday, we too will quickly turn around your appeal if you so choose to appeal.

Thank you,

Lincoln Stroh
Captain, USCG
Deputy Director, Prevention Policy
(202) 372-1016

[Capt Leigh]

Congratulations Steve,Carpal Tunnel Syndrome has finally paid off for You!
You couldn't have hoped for more,having your MOT added as well.I'm now considering a move to Dauphin Island (poor side) where the representatives actually respond to your needs.
I hope this portends good news for all those awaiting sanity.
Kudos to you sir...Leigh

[Capt Leigh]

Captain Brian,I think that reads as good news,and I think your letter really made the most sense of The STCW's actual policy.It is amazing how little meat I could find in my research.As we know that is just a guide for each govt.,but it sure makes the intent plain,and seems that Master 1600 trumps OICNW.Good work,and good luck....Leigh

[stevefoster]

Congratulations Steve,Carpal Tunnel Syndrome has finally paid off for You!
You couldn't have hoped for more,having your MOT added as well.I'm now considering a move to Dauphin Island (poor side) where the representatives actually respond to your needs.
I hope this portends good news for all those awaiting sanity.
Kudos to you sir...Leigh

Thanks so much Leigh and come on down to our sleepy, laid back little fishing town of 1350 residents. And you are right, Congressman Jo Bonner is the man..............

[Capt Brian]

This is the letter that I received on Friday. Sounds like good news for me, but need to clarify the 1600 Master testing. Hopefully, it did not "fall" out of my folder enroute to WV:

Captain,
My branch was assigned to review the request for reconsideration submitted via e-mail below. After our review of your service and training, we have verified that you tested for and held a Mate 1600 Near Coastal in 2006.

On February 27, 2007, you applied for Master 1600 Near Coastal and Third Mate AGT Near Coastal. It was during this 2007 evaluation that we determined you had not met the OICNW requirements for the Mate 1600 Near Coastal you had been issued in 2006. Due to this error, the Mate 1600 Near Coastal license was then limited to an Inland Mate 1600, until such time that you completed all OICNW assessments and training. Additionally, once the OINCW assessments were provided you were incorrectly issued a Master 1600 Near Coastal instead of Mate 1600 credential. These critical errors hindered our ability to correctly assess your previously held credentials, which is why you were sent the deficiency letter for your current evaluation.

We cannot find documentation that you completed testing for a Master 1600 Near Coastal, which constitutes a critical error and would require the removal of your 1600 Masters endorsement. However, we have taken into consideration your experience and excellent safety record. For these reasons, we will not pursue correction of this possible critical error.

Currently you meet the service requirements for a Third Mate. Now that the previously held Mate 1600 Near Coastal license has been verified, NMC Policy Letter 01-02, Paragraph 11(d) does apply to you and you will be issued the Third Mate without any further testing or assessments.

Thank you for your time and service.

Jennifer Hogge
Merchant Mariner Evaluation Specialist
National Maritime Center
100 Forbes Drive
Martinsburg, WV 25404
304-433-3654
(Fax) 304-433-3412

[stevefoster]

This is the letter that I received on Friday. Sounds like good news for me, but need to clarify the 1600 Master testing. Hopefully, it did not "fall" out of my folder enroute to WV:

Captain,
My branch was assigned to review the request for reconsideration submitted via e-mail below. After our review of your service and training, we have verified that you tested for and held a Mate 1600 Near Coastal in 2006.

On February 27, 2007, you applied for Master 1600 Near Coastal and Third Mate AGT Near Coastal. It was during this 2007 evaluation that we determined you had not met the OICNW requirements for the Mate 1600 Near Coastal you had been issued in 2006. Due to this error, the Mate 1600 Near Coastal license was then limited to an Inland Mate 1600, until such time that you completed all OICNW assessments and training. Additionally, once the OINCW assessments were provided you were incorrectly issued a Master 1600 Near Coastal instead of Mate 1600 credential. These critical errors hindered our ability to correctly assess your previously held credentials, which is why you were sent the deficiency letter for your current evaluation.

We cannot find documentation that you completed testing for a Master 1600 Near Coastal, which constitutes a critical error and would require the removal of your 1600 Masters endorsement. However, we have taken into consideration your experience and excellent safety record. For these reasons, we will not pursue correction of this possible critical error.

Currently you meet the service requirements for a Third Mate. Now that the previously held Mate 1600 Near Coastal license has been verified, NMC Policy Letter 01-02, Paragraph 11(d) does apply to you and you will be issued the Third Mate without any further testing or assessments.

Thank you for your time and service.

Jennifer Hogge
Merchant Mariner Evaluation Specialist
National Maritime Center
100 Forbes Drive
Martinsburg, WV 25404
304-433-3654
(Fax) 304-433-3412

Wow, I thought I got a great deal, you don't even have to test for 3rd Mate.............congradulations.....hanging in there has it's rewards.............

[Capt Leigh]

I think it is appalling that the "Great Deal" you got is exactly what you SHOULD have received without the months of inept poor service that you DID receive, and that you actually had to write many letters and finally get AN ACT OF CONGRESS to receive what you have rightly earned.

But maybe it's just me

[stevefoster]

I think it is appalling that the "Great Deal" you got is exactly what you SHOULD have received without the months of inept poor service that you DID receive, and that you actually had to write many letters and finally get AN ACT OF CONGRESS to receive what you have rightly earned.

But maybe it's just me

Capt. Leigh,

Thanks for the sentiment. We must remember who we are dealing with. (Federal Government)..... I was never fluent in "BUREAUCRATESE" but it's nice to be able to utilize people that do speak that language. I believe most of us need to carry our passport to enter the Washingon, D.C. city limits. It's a foreign country especially to us "Southern" types......

[Jeffrox]

Stop the insanity!!!!

[Capt Brian]

Stop the insanity!!!!

Jeff - Is that not a trade mark phrase from Susan Powder?

Well all, my new MMC has been issued on 5 October and is sitting at the house awaiting my signature. Can't wait to check out that new MMC smell!!!

[Capt Leigh]

Congratulations Capt. Brian,I really am glad to hear the good news.Keep us informed if it is correct and has the RFPNW listed also.

"If your only tool is a hammer,every problem looks like a nail"
..... anonymous

[bluejay]

We cannot find documentation that you completed testing for a Master 1600 Near Coastal, which constitutes a critical error and would require the removal of your 1600 Masters endorsement. However, we have taken into consideration your experience and excellent safety record. For these reasons, we will not pursue correction of this possible critical error.

Congratulations, Brian.

Having seen Capt. Brian in action, he deserves what he has achieved.
The good stuff, that is.

[Capt Brian]

Congratulations Capt. Brian,I really am glad to hear the good news.Keep us informed if it is correct and has the RFPNW listed also.

"If your only tool is a hammer,every problem looks like a nail"
..... anonymous

The i's are dotted and the t's crossed. All good to go. And I especially like the new MMC smell. mmmmmmm