USCG Training Vs STCW Training

[BMCSRetired]

I am fixing to roll in the mud with pigs. However, before I perform this act, I want to get a feel for the level of training received while wearing the blue suit. Specifically, how do you rate the training you received on the bridge of a major cutter (>140ft) compared to the "required" STCW training for 2nd/3rd unlimited. I am putting this identical request in the NAVY section also because I respect their abilities, traditions and excellent training methods.

Here is the information and ground rules I would like to limit this to;

1. Keep it civil.
2. You wore a blue suit.
2. You earned a 1600 ton or greater license or are actively working on earning one.
3. You stood QMOW/JOOD or Underway OOD watches on a major cutter.
4. You were qualified for the above watch (passed a board and received a letter)
5. How would rate the USCG Training to "Approved" STCW training?
6. You DID NOT graduate from the USCGA
7. If you did graduate from the USCGA, how would you rate the Academy training to other
"approved" training.

I want to get a discussion started on this because I have my own opinion and feel pretty strongly about this issue. Before the usual stuff starts up, let me qualify my own situation.

A. I have a lot of free time.
B. I am appealing some policies.
C. I can afford the schools.
D. I am stimulating the economy by creating work (and hopefully jobs) for somebody at the NMC so
they must to work on refuting appeals insteading of issuing form letters.
E. I think it is a cop out the USCG does not recognize their own training.
F. Since the USCG does not recognize their own training, they are violating the STCW Code and
because of that, the CFR's and endangering lives at sea.

If you want to communicate with me confidentially because any time you question stuff with your license, any entry is made in your file, you must be a member of GCaptain. Unless of course, you know my secret identity.

[cappy208]

What do you mean: "An entry is made in your file"? Is this a negative? Do they keep track and hold us accountable for questioning them? Does this entry affect our ability to apply for licenses? More info please. I have suspected a tit for tat thing for years. do you have proof?

[Capt. Phoenix]

How are they violating STCW? I thought STCW only applies to commercial vessels, not military vessels or private vessels. In fact, I think STCW has a specific exemption for military vessels...

[Steamer]

How are they violating STCW?

I asked the same question in the other thread he started with the same rant and didn't get an answer either. I also asked how this was a threat to marine safety but didn't get an answer to that one either.

Sometimes a rant is just a rant, I guess and claims are made just for the drama.

[tengineer]

The US government exempts their employees from most regulations required of normal businesses and working folks. They don't even come under OSHA. What's more, MSC, NOAA and other civilian maritime organizations specifically exempt themselves from maritime rules though they do say they will try to abide by all applicable USCG, ABS etc. regulations. But if they don't? Nada. Heck, the NOAA Corps captains don't even have a license.
The US military abiding by a UN/IMO maritime convention and STCW? Never happen and they have never said they'd abide. What do you expect? The USCG licensing US Navy 'captains'? I'd love to see that proposed.

[BMCSRetired]

The US government exempts their employees from most regulations required of normal businesses and working folks. They don't even come under OSHA. What's more, MSC, NOAA and other civilian maritime organizations specifically exempt themselves from maritime rules though they do say they will try to abide by all applicable USCG, ABS etc. regulations. But if they don't? Nada. Heck, the NOAA Corps captains don't even have a license.
The US military abiding by a UN/IMO maritime convention and STCW? Never happen and they have never said they'd abide. What do you expect? The USCG licensing US Navy 'captains'? I'd love to see that proposed.

I can not get online until the beginning to mid November so while I can, let me say this about that...

My initial statement is partially a rant. I am not advocating the USCG license people while they are active duty. What I am advocating is ensuring that the training received on the bridge of Navy and Coast Guard vessels is "as far as reasonable and practicable" is recognized training.

As far as abiding, they do come under most OSHA, International Pollution, Geneva (in most cases), and other regulations and conventions. What is the big deal with recognizing your people as experts and able to do a job???

Additionally the CFR's specifically state the STCW code overrides federal law. If you think they can always ignore the law, then just like the silly "Don't ask, don't tell" (and my addition, DO NOT CARE!!!) policy, I would expect the ignorance of the training requirements of the STCW will be challenged after a mishap or loss of life. That case in San Diego with USCG boat running over that vessel would be a perfect example if it was it was a larger USCG vessel. Additionally, "cherry-picking" parts of laws you agree with and ones you do not is a recipe for disaster. As we all know, maritime law never changes until someone dies or a company loses a lot of money.

All I want is recognition of the time and effort I put into ensuring that while I was planning a voyage to get somewhere safely or on watch at 0230 with 120 other people asleep, they could sleep well. I really feel when I go to the licensing folks that I am not considered a real mariner until I sit in a class like an automaton repeating and regurgitating what I am told and then getting a certificate. A 12 year old can do that.

I believe that if you have a valid underway OOD letter and over 10 years of sea time, you have the required knowledge (training) and that should be included in a policy letter. I still believe the assessments should be completed and I feel that is even more important than the training. Anyone can sit in a class and pass, not everyone can maneuver and navigate.

TO CAPPY 208: On the issue of entries in your file, YES I have proof. If you think there are things in your file, you can get a copy of your file by filing for it under the Freedom of Information Act with USCG Headquarters for a nominal fee.

[Steamer]

All I want is recognition of the time and effort I put into ...

You should apply for a Tongan license, or maybe Nigerian. It might be easier and faster if the CG doesn't know you are an American. Chances are that a Tongan, Nigerian, or some other 3rd world white list mariner will make it to the wheelhouse before you do.

If you really want an American license then volunteer to take the place of that intern Cavo mentioned and work on the course approvals. Personally, I would look at getting a Marshall Islands ticket and wait a couple of months to replace an American license on the APL or Maersk fleets.

[jdcavo]

...What I am advocating is ensuring that the training received on the bridge of Navy and Coast Guard vessels is "as far as reasonable and practicable" is recognized training.

...Additionally the CFR's specifically state the STCW code overrides federal law.

I think you are misinterpreting the "reasonable and practicable" language. It refers to the responsibility of a Party to insure that the operation of their military vessels complies with STCW. For example, how much seagoing service is needed to qualify for the military equivalent of OICNW? Is it the 3 years (actual sea service, not calendar time) required by STCW Regulation II/1? If not, this is an example of the "reasonable and practicable" application of STCW to a military vessel.

Please cite the portion of the CFR that says the STCW "overrides" Federal law. I'm only familiar with the incorporation by reference of STCW into the domestic licensing regulations in 46 CFR 11.903. A more common interpretation of this is that if STCW has a higher standard than domestic requirements, the higher STCW standard must also be met. I don't think it means that if STCW has a lower standard, you don't need to meet the higher domestic requirement. For example, STCW V/1 does not require tank vessel service in order to get the STCW endorsement for tank vessels, but that does not mean that you do not need to have tank vessel service and cargo transfers to get a Tankerman-PIC endorsement. STCW does not "override" the higher domestic standard.

Training that has not been evaluated and approved as meeting the STCW can't be accepted for qualifying for an STCW document. The military training you describe has never been submitted for evaluation and approval, and thus cannot be accepted.

[jdcavo]

What do you mean: "An entry is made in your file"? Is this a negative? Do they keep track and hold us accountable for questioning them? Does this entry affect our ability to apply for licenses? More info please. I have suspected a tit for tat thing for years. do you have proof?

NMC has a practice of documenting communications with mariners in the mariner's electronic record. A summary of e-mails is also entered. As far as any nefarious intent for this practice, I'd suggest it's just sound business practice and is widely done by a variety of organizations. Long before working at NMC I had a practice of keeping a log of all phone communications. As far as the Coast Guard doing it, there have been instances when these records were used in a mariner's favor when these same records indicated they were given bad information and there was credible evidence the mariner acted in good faith on the information they were provided.

[BMCSRetired]

Training that has not been evaluated and approved as meeting the STCW can't be accepted for qualifying for an STCW document. The military training you describe has never been submitted for evaluation and approval, and thus cannot be accepted.

So are you saying that if someone in the Coast Guard submits the OOD PQS package, it could be evaluated and approved?

On another note, who submitted the USCG Academy curriculum and where is the record of who evaluated and approved it?

[jdcavo]

Not "someone", the unit/office responsible for developing and administering the PQS.