Mr. Cavo: Cancellation of Policy Letter 15-01

[Marlowe]

Mr. Cavo,

Given the imminent cancellation of NMC 15-01 how would I establish that a course I took prior to implementation of STCW 1995 is approved? Where might I access the individual course approvals?

[jdcavo]

The policy letter is being cancelled because it's not needed, not because any of the courses listed in it are no longer acceptable. 15-01 was never a complete list of acceptable courses, the course approval staff at NMC always maintained a list of acceptable courses, and it is more extensive than what is in the policy letter. They still maintain that list, contact them if you have a specific course you need to know about. What course(s) are you conbcerned with? I can't imagine there are many courses taken 10 or more years ago that haven't been "used" yet.

[JP]

I would like to know why the USCG approved courses that I took in 1978-1982 (before STCW) for an entire 2 year long program including a year of diesel engines and a semester of celestial navigation were not considered at least as good as the week long classes I had to take (again) for STCW 1995??? I tried to get a waiver and/or protest but the USCG would not allow me to do that until I turned in my application which they would not accept until I took (again) all the STCW classes. Catch 22!! I finally decided it was not worth it to continue argueing and wasting my time with the USCG when I had already taken (again) all of the STCW classes so that they would let me turn in my application (finally!). Either turn in my application and sit for the test and get it over with or argue for who knows how long and delay my license for another how many more years. I think the entire STCW should be repealed! At least in America. We do not need it and we should get rid of it now.

[Marlowe]

What course(s) are you conbcerned with? I can't imagine there are many courses taken 10 or more years ago that haven't been "used" yet.

GMDSS from CMA in the Fall of 1997. The course has "counted" for some and not for others from that time frame. Not a huge deal but would like to avoid re-taking it.

[jdcavo]

GMDSS from CMA in the Fall of 1997. The course has "counted" for some and not for others from that time frame. Not a huge deal but would like to avoid re-taking it.

That policy letter won't hep you, the course was almost certainly not approved. In 1997, GMDSS courses were not approved and most courses were only 1 week long and many did not have practical assessments. Many were just prep courses for the FCC nultiple choice exam (given by the school). in 1998 we put out policy and required GMDSS courses to be 2 weeks long (the IMO model is 4 weeks) and required there to be practical training and assessment on real equipment. If you took one of the shorter courses, it won't be accepted, but there is a way to get qualified without taking a complete 2 week course (more below). If others who took the same course as you got the GMDSS endorsement, they either followed the process below, or they got lucky. RECs frequently were inconsistent and didn't properly apply policy and regs, that's one of the reasons the centralized NMC was created.

If you took the shorter course, you can get GMDSS endorsed on your STCW by what was known as the "challenge" provision. You can get a school with an approved GMDSS course to give you the written exam and practical assessments without taking a course. If you pass, the assessments plus your shorter course will get you the GMDSS endorsement. See NMC Policy Letter 06-03 The first row of the table in Enclosure (1) is applicable to your situation. Note that the policy letter refers to assessment/examination by a Designated Examiner. All schools with approved GMDSS courses can have their GMDSS instructors act as Designated Examiners for GMDSS, there are now no longer any currently approved independent GMDSS Designated Examiners, you will need to go to a school for this option.

The above notwithstanding, you may not have much luck getting a school to assess you. Some might want to steer you to a more expensive courtse, but more likely most have found that without taking a course, many can't pass the exam and/or assessments without refresher training (some of the assessments involve operations not nrmally done on a routine, incident-free watch).