NPRM STCW Proposed Rule QSS Requirement

[bardawg48]

Someone help me out, It appears that training schools will be required to adopt a Quality Standards System. In the past the NMC has approved courses , instructors etc and this service was free. Does this mean ABS , DNV or ACE have to be utilized as a third party to audit courses and programs. Can a facility use a ISO 9000 guidelines and develop their own QSS.

I think this needs clarification. Can the schools operate as they have been under uscg oversight or are we ging to have to spend a ton of money, I believe the uscg estimates 87 million to incorporate QSS over a 10 year period. Here is the clip of the NPRM I did not clip all of it

Federal Register /Vol. 74, No. 220 /Tuesday, November 17, 2009 / Proposed Rules 59375

(5) Training Provider Requirements—
Require training providers to adopt aquality standards system (QSS); would require an internal audit of Coast Guard approvedcourses midway during the validity period of a course’s acceptance;and would require providers to send an annual report to the Coast Guard
regarding each course they teach....

We estimate that this proposed rule would also affect 160 STCW training providers by requiring them to provide the Coast Guard’s National Maritime Center (NMC) with an annual report on all courses. Training providers choosing to offer STCW Convention training
would also have to implement a quality standards system (QSS) and write and maintain a QSS manual; conduct internal and external audits of each Coast Guard-approved course, and keep a paper or electronic record on each student completing a course. The costs of the proposed rule are presented in Table 1. We estimate the total present value cost over the 10-year period of analysis (from 2009 to 2018) to be $87.1 million at a 7 percent discount rate and $105.4 million at a 3 percent discount rate.

[danzante]

I just shot you a PM about this.

[gltqm]

Someone help me out, It appears that training schools will be required to adopt a Quality Standards System. In the past the NMC has approved courses , instructors etc and this service was free. Does this mean ABS , DNV or ACE have to be utilized as a third party to audit courses and programs. Can a facility use a ISO 9000 guidelines and develop their own QSS.

I think this needs clarification. Can the schools operate as they have been under uscg oversight or are we ging to have to spend a ton of money, I believe the uscg estimates 87 million to incorporate QSS over a 10 year period. Here is the clip of the NPRM I did not clip all of it

Federal Register /Vol. 74, No. 220 /Tuesday, November 17, 2009 / Proposed Rules 59375

(5) Training Provider Requirements—
Require training providers to adopt aquality standards system (QSS); would require an internal audit of Coast Guard approvedcourses midway during the validity period of a course’s acceptance;and would require providers to send an annual report to the Coast Guard
regarding each course they teach....

We estimate that this proposed rule would also affect 160 STCW training providers by requiring them to provide the Coast Guard’s National Maritime Center (NMC) with an annual report on all courses. Training providers choosing to offer STCW Convention training
would also have to implement a quality standards system (QSS) and write and maintain a QSS manual; conduct internal and external audits of each Coast Guard-approved course, and keep a paper or electronic record on each student completing a course. The costs of the proposed rule are presented in Table 1. We estimate the total present value cost over the 10-year period of analysis (from 2009 to 2018) to be $87.1 million at a 7 percent discount rate and $105.4 million at a 3 percent discount rate.

I presented in the form of two questions sent via e-mail to Mr. Mark Gould on December 7, 2009 in accordance with the NPRM regarding the intent of the NPRM to comply with Regulation I/8 paragraphs 1.1 and 1.2.
Question (1) If the Coast Guard approves or has approved an STCW course will the Coast Guard be the governmental agency performing the QSS monitoring activities in accordance with Regulation I/8 1.1 as the training provider's QSS organization?
Question (2) Is the intent of the proposed revisions to 46CFR 10.303 to require training schools to use a QSS organization (entities such as the ABS, DNV or ACE) other than a governmental agency (i.e. the Coast Guard) to perform the QSS monitoring activities in accordance with Regulation I/8 1.1 as the training provider's QSS organization?
The reply from Mr. Gould- Our attorneys have advised us that these questions should be sent to the docket for inclusion, and we will address them after the comment period closes.