Jan 2010 Licensing Update From Norleen Schumer

[gCaptain]

The following is the latest update from Norleen Schumer at www.maritimelicensing.com

I have been reading and trying to digest the November 17th Federal Register, not an easy task at best, as I am sure you have noticed. Back in April of last year, I sent out an e-mail concerning a statement that NMC wanted placed on all sea service letters from Towing companies stating that:
In accordance with 46 CFR 10.209, (c)(6)(ii), this mariner has completed ongoing participation in training and drills during the validity of the license being renewed.

Well now, in the new E-46 CFR, 10.209 (General Application Procedures) no longer reads like this. Now, you must look under 10.227 (Requirements for Renewal) where you will find two different ways of saying the above in your letters of sea service.

(A) In accordance with 46 CFR 10.227 (d)(8)(D)(vi)(A), this mariner has completed ongoing participation in training and drills during the validity of the license or MMC being renewed.
OR

(B) In accordance with 46 CFR 10.227 (d)(8)(d)(vi)(B), this mariner has completed ongoing participation in training and drills during the validity of the license or MMC being renewed.

I have not received any word from NMC on how best to accomplish writing this up. But, I would probably say to you that the best way to cover your bases and your employees is to incorporate both of these statements in your letters of sea service if they are applicable of course. Please note that neither mention anything about providing anything other than these two items. Under the "old" 46 CFR 10.209 it was not stated either, but NMC wanted to see a completed TOAR at the time of renewal if the mariner did not meet 46 CFR 10.209 (c)(6)(ii).

I don't know if this information is helpful to you, but I just thought I would pass on, just one small item of interest. Please read E-46 CFR 10.209 and 10.227 for yourself just to make sure I have all my ducks in a row.

Thanks for everything and if I didn't say so before, Happy New Year to each of you.

--
Norleen L. Schumer
MaritimeLicensing.com
800-562-9758
360-447-8328
360-616-2730 (fax)

[Xtracho]

Question: I have a sea time letter from 1996.... yeah it's old but it has over 700 days of time on it. I don't think it was required to quote the CFR at that time and the company no longer exists. Will NMC accept it?

[capitan1962]

I just renewed in November. Really fast, I sent it off and 23 days later had my new MMC good until 2014. Man am I glad I did that, also the physical form is much more intense now. I was able to used an older one luckily but no more.

[rwells78]

If you have not read the November 17th Federal Register, you really should.

Regardless, you need to apply immediately for any and all license upgrades you THINK you may be qualified for, because you will have to show much more sea service and 10's of thousands more dollars in training courses to get that same upgrade in a couple of months from now when the proposed changes go into effect.

Engineer officers in particular will get a rude introduction to what many deck officers have had to do to comply with STCW.

If you snooze, you lose.

[water]

Originally Posted by rwells78

If you have not read the November 17th Federal Register, you really should.

Regardless, you need to apply immediately for any and all license upgrades you THINK you may be qualified for, because you will have to show much more sea service and 10's of thousands more dollars in training courses to get that same upgrade in a couple of months from now when the proposed changes go into effect.

Engineer officers in particular will get a rude introduction to what many deck officers have had to do to comply with STCW.

If you snooze, you lose.

Is there a set date that these will go into effect? A number of us here are scrambling to get our ducks in line before the change.

Any info would be appreciated.

Many thanks!

[10talents]

Originally Posted by Xtracho

Question: I have a sea time letter from 1996.... yeah it's old but it has over 700 days of time on it. I don't think it was required to quote the CFR at that time and the company no longer exists. Will NMC accept it?

They accepted my old letters from 30 years back.

[captfish]

Originally Posted by water

Is there a set date that these will go into effect? A number of us here are scrambling to get our ducks in line before the change.

Any info would be appreciated.

Many thanks!

No date is set yet, as the gov't is still accepting comments on the proposed change. After the comment period is over (FEB 2010), the USCG will gather all the comments, drop them into the shredder and then make a final rule. This process could take a few months...or longer, depending on how many changes they make to the proposed rule, if any. I would guess the final rule could be out this summer, at the earliest.

As far as I know, applications are still good for upto a year. So, if you think you will have the required seatime in the next twelve months for an upgrade or original go ahead and apply. The NMC will respond telling you how many days/classes you need, and then you can complete them before 12 months are up. In the meantime, if the rules change, your application will be grandfathered. Someone please correct me if I am wrong...

[water]

Originally Posted by captfish

No date is set yet, as the gov't is still accepting comments on the proposed change. After the comment period is over (FEB 2010), the USCG will gather all the comments, drop them into the shredder and then make a final rule. This process could take a few months...or longer, depending on how many changes they make to the proposed rule, if any. I would guess the final rule could be out this summer, at the earliest.

As far as I know, applications are still good for upto a year. So, if you think you will have the required seatime in the next twelve months for an upgrade or original go ahead and apply. The NMC will respond telling you how many days/classes you need, and then you can complete them before 12 months are up. In the meantime, if the rules change, your application will be grandfathered. Someone please correct me if I am wrong...

Thanks, captfish. I talked to NMC seveal weeks ago, and was advised it is taking about 30 days to process applications, and then applicants have 90 days to correct any deficiencies.

I have by classed completed, but am scrambling to find a 28 day hitch to complete sea time requirements.

Any other insights would be appreciated.

[Conspearasea]

I heard the same as water has posted, that the window for completing deficiencies has been dropped to 90 days....not 12 months anymore.

I would guess, and have heard from reputable sources, that after the final ruling is made there is usually a fair time-period until the ruling takes effect......HOW long that is, I have no idea. Regardless when it hits, it's going to hurt quite a few guys.

Any one else w/ some known figures....I'm finishing one more class before sending in an upgrade to test for 500 Master based on the 90 day windows......

[wxbuoy]

In a notice given to us while attending school/classes in S. Florida, it says " The USCG is requesting comments on the proposed final implementation of STCW for US mariners. The goal is to have the final implementations in place by July 2010 thus ending the Interim Regulations." The 90 page NPRM can be accessed online at http;//govpulse.us/entries/2009/11/E9-26821/implementations-of-the-1995-amendments-to-the-international-convention-on-standards-of-training-certi That is the link I have from the school. start early, get going, it is only going to get more difficult to continue to sail. Hope this helps at least one person!