86-10 T/S 58 MERPAC recommends that a task statement be promulgated to activate the workgroup that drafted the Medical NVIC and begin a review and update of the documents.  This should be a standing task statement for continuous review.  The original task statement chose a NVIC as the tool for communication based on the assumption that it would be reviewed and updated.  Until the MMMAC is created, MERPAC should continue this work.  The NMC will provide data about the numbers of each condition applied for and the determination of those applications.  Additionally, a review should be conducted of medical tests being submitted at great cost to the mariners that resulted in an approved credential with no limitations, to determine if the request for those tests was appropriate, and justified the expense of the tests.  With this information, the working group could recommend the addition and/or removal of conditions.  MERPAC should also create a new tool, possibly an addendum to the NVIC, to provide further education to mariners and physicians on items that the NMC considers unallowable/unfavorable.  As a 3rd deliverable, the CG-719K and CG-719K/E forms need to be reviewed and amended, including specifically a review of the language that collects a "medical history" that conflicts with the parameters and "look back" period for medical conditions defined in enclosure (3) of the NVIC.  The work of this group should also ensure that letters to mariners requesting additional information reference enclosure (3) of the Medical NVIC.  Additional testing being requested that is currently NOT in the NVIC should be reviewed and included or stopped.  Include in discussion requests for pharmacy records and medications that are not acceptable.  Mariners need to know what medications may be substituted as acceptable.   Closed

87-10 T/S 58 MERPAC recommends that the NMC review the current fee structure and consider whether mariners can be charged one fee instead of the `smorgasbord' of fees to choose from. Open

88-10 T/S 58 MERPAC recommends that the Coast Guard advise mariners that they have stopped additional testing requirements based SOLELY on body mass index (BMI), other than the standards published in the Medical NVIC.  The Coast Guard needs to develop appropriate educational material for physicians and bring this issue to the work group established to review the medical NVIC. Closed

89-10 T/S 58 MERPAC recommends that the Coast Guard resurrect the educational material that this committee developed for mariners for their education regarding medications and supplements, either prescription or OTC.  This needs to be given priority. Open

90-10 T/S 58 MERPAC formally commends Captain David Stalfort on the excellent performance of his duties at the National Maritime Center.  Many Commanding Officers have stood before this body and explained why the requests and recommendations of the committee would not or could not be acted on.  Captain Stalfort came and accepted these recommendations and made great strides in enacting them.  Captain Stalfort has provided great service to the mariners of this country, and this committee formally thanks him for his work.  Closed

91-10 T/S 72 Minimum amount of service, in (8-hour) days, to qualify for RFPNW for mariners who do not complete an approved program of special training.

MERPAC recommends that seagoing service be calculated in both 8-hour days and 12-hour days. Closed

92-10 T/S 72 Minimum amount of service, in (8-hour) days, to qualify for RFPNW for mariners who do not complete an approved program of special training.

MERPAC recommends that the mariner shall complete not less than 180 8-hour days of seagoing service, or 120 12-hour days of seagoing service to fulfill the seagoing service for ratings forming part of a navigational watch. With special training, the mariner shall complete not less than 60 8-hour days of seagoing services, or 40 12-hour days of seagoing service to fulfill the seagoing service for ratings forming part of a navigational watch. Closed

93-10 T/S 72 Minimum amount of service, in (8-hour) days, to qualify for RFPNW for mariners who do not complete an approved program of special training.

MERPAC recommends that in establishing seagoing service, discharge slips, small vessel sea service forms, and letters of sea service issued by the master of the vessel and/or by the company be accepted as proof of seagoing service. Closed

94-10 T/S 72 Tonnage of the vessels upon which qualifying service is obtained.

MERPAC recommends that qualified service on a vessel of any tonnage be accepted as seagoing service.   Closed

95-10 T/S 72 Routes upon which the qualifying service is obtained.

MERPAC recommends that in light of the definition of seagoing service found in STCW Regulation 1/1.25:       "Seagoing service means service on board a ship relevant to the issue of a certificate or other qualification;" the Coast Guard should accept seagoing service which has been obtained on any navigable water. Closed

96-10 T/S 72 Capacity in which the mariner serves and the scope of his/her duties during the qualifying service. This should specifically address the requirement in STCW Regulation II/4 that training and experience be "associated with navigational watchkeeping functions."

MERPAC recommends that the Coast Guard retain the language that is found in the STCW NPRM 46 CFR 12.420 (c)(1)(I):

      "... seagoing service that includes training and experience associated with navigational watchkeeping functions and involving the performance of duties carried out under the supervision of an OICNW or a qualified deck rating;"

The capacity in which the mariner serves and the scope of his/her duties would be performed during navigational watchkeeping functions and involving the performance of duties carried out under the supervision of deck watch officer or a qualified deck rating. Closed

97-10 T/S 72 MERPAC recommends that in light of STCW Section A-I/6.6, assessment of competence can be performed by any licensed deck officer on the vessel. Closed

98-10 T/S 72 MERPAC recommends that when assessing the rating according to Table A-II/4, the assessor should use the assessment forms contained in NMC Policy No. 14-02 or other approved assessment forms. Closed

99-10 T/S 72 MERPAC recommends that in recognition of the mariner's experience, training and knowledge, on the issuance of his/her first license, and with the completion of STCW Basic Safety Training, the deck officer be issued an RFPNW endorsement on his/her STCW certificate. Closed

100-10 T/S 72 In reference to the 1999 letter by the Chief of Marine Personnel which stated:

      "...vessels of not more than 500 gross registered tons on near coastal, domestic voyages will not be required to have seamen qualified as ratings forming part of a navigational watch because that STCW rating does not apply to vessels of less than 500 gross tons."

MERPAC recommends that the Coast Guard make the requirements for RFPNW applicable to vessels over 500 GRT/1600 GT ITC in near coastal service. Closed

01-11 T/S 75 STCW SNPRM 10.107 - MERPAC believes that any person serving as an assessor needs to be qualified with training in the skills required to assess competency and be approved by the Coast Guard, whether as a Qualified Assessor or as a  Designated Examiner.  Therefore, a definition of Qualified Assessor should be added as follows: "Qualified assessor or QA means a person who is qualified to evaluate, for STCW endorsements, whether an applicant has demonstrated the level of competence in the task for which the assessment is being made. This person must be approved by the Coast Guard or by a CG approved or accepted program of training." Closed

02-11 T/S 75 STCW SNPRM 10.107 - Coast Guard should work with MERPAC to develop the standards for a QA, including developing an approval process and an auditing and oversight program.  A task statement should be developed for MERPAC.   Closed

03-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that a definition for "Certificate of Registry" needs to be added. Closed

04-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the definition of a "Domestic" officer endorsement is confusing. Strike "domestic" and replace with "National". (Globally) Closed

05-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends a change to the definition of "disabled vessel", that the Coast Guard should remove the last sentence of the definition and revert to the original definition.  As stated, we believe this definition would mean that any time a vessel maneuvering to and from the dock with an assist tug, or a vessel that takes an assist/escort tug, that that vessel would be deemed to be a disabled vessel.   Closed

06-11 T/S 75 STCW SNPRM 10.107 - MERPAC notes the absence of a definition for "direct supervision" and recommends that one is needed. Closed

07-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the definition of "drug test" be amended to broaden the testing procedure.  See note below:

Title 49: Transportation

Subtitle A: Office of the Secretary of Transportation

PART 40: PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS

Subpart I: Problems in Drug Tests

40.195 - What happens when an individual is unable to provide a sufficient amount of urine for a pre-employment follow-up or return-to-duty test because of a permanent or long-term medical condition

(a) This section concerns a situation in which an employee has a medical condition that precludes him or her from providing a sufficient specimen for a pre-employment follow-up or return-to-duty test and the condition involves a permanent or long-term disability. As the MRO in this situation, you must do the following:

(1) You must determine if there is clinical evidence that the individual is an illicit drug user. You must make this determination by personally conducting, or causing to be conducted, a medical evaluation and through consultation with the employee's physician and/or the physician who conducted the evaluation under 40.193(d).

(2) If you do not personally conduct the medical evaluation, you must ensure that one is conducted by a licensed physician acceptable to you.

(3) For purposes of this section, the MRO or the physician conducting the evaluation may conduct an alternative test (e.g., blood) as part of the medically appropriate procedures in determining clinical evidence of drug use. Closed

08-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that all manning documents and COIs should separately specify the STCW endorsements from the national endorsements that must be carried onboard for international voyages. Closed

09-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the term "STCW endorsement" include additional language clarifying that the underlying domestic endorsement must be held by the applicant for an STCW certificate. Closed

10-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that a definition for "medical certificate" be added.  Provide discussion of the use of the medical certificate in the appropriate section. Closed

11-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the "coastwise voyage" definition encompass voyages to nations in which we have a treaty or other arrangements between nations that allow coastwise transit. Closed

12-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the definition of "domestic voyage" language should delete the phrase that says "without entering waters under the jurisdiction of another country."  Closed

13-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends adding a definition for ILO. Closed

14-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the definition of "limited" include horsepower.

Closed

15-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the Coast Guard review the definitions of "self propelled tank vessel" and "tankship" to ensure inclusion of all vessels.  Closed

16-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends correction of the definition for "utility towing".  We believe at this time that paragraph 2 conflicts with the proposed definition for disabled vessel. Closed

17-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the Coast Guard amend the definition of "restricted" to read ...endorsement, for example, specific ... Closed

18-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the definition of "safe and suitable person" needs to include "...safety and security of life or property..."

Closed

19-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the definition of "support level" should coincide with STCW Code (A-I/1)  -- management level and operational level, also. Closed

20-11 T/S 75 STCW SNPRM 10.107 - MERPAC recommends that the definition "vessel personnel with security duties" be revised. Currently, it does not accurately capture security duties and it should be changed to harmonize with text from B-VI/6 in STCW. Closed

21-11 T/S 75 STCW SNPRM 10.205 - Change the second sentence to read "Except upon a written request of the applicant, the Coast Guard will post-date the issuance of the MMC up to 12 months from the date that the Coast Guard accepts a complete application as defined on this part."  MERPAC recommends that the new credential validity date coincide with the expiration date of the active credential held by the mariner. Closed

22-11 T/S 75 STCW SNPRM 10.209 - MERPAC recommends that a copy of a radar course certificate should not have to be certified, as proposed in (d)(4).

Closed

23-11 T/S 75 STCW SNPRM 10.209 - Coast Guard needs to add "if required" at the end of (f). All references to TWIC should be modified in this way because a TWIC is no longer required per U.S. statute to accompany all merchant mariner credentials.  (Global) Open

24-11 T/S 75 STCW SNPRM 10.219 - MERPAC does not support the payment of fees only electronically.  Mariners should not be forced to pay via credit card. Not everyone has a credit card. Allow for cash, certified/cashier's checks or money order payment. Closed

25-11 T/S 75 STCW SNPRM 10.221 - Coast Guard needs to add a new paragraph to address the means of proving citizenship since a TWIC is no longer required for all MMC's. Open

26-11 T/S 75 STCW SNPRM 10.223 - Delete (c)(2), since TWIC isn't required for everyone.

Open

27-11 T/S 75 STCW SNPRM 10.225 - (a)(2)  conflicts with 10.227(b) and 10.227(i). Modify (a)(2) to say "except where provided for in 10.227(b) and 10.227(i)."

Closed

28-11 T/S 75 STCW SNPRM 10.227(d)(6) - If there is going to be a national medical certificate, then de-link the medical certificate from the MMC and issue a separate medical certificate. The Coast Guard needs to check for consistency with other regulations (10.302 et al) and, if necessary, consider a Legislative Change Proposal to ensure that credentials are issued after evaluating a mariner's professional qualifications alone. Closed

29-11 T/S 75 STCW SNPRM 10.231(b) - Replace text to ensure evaluators issue a new 5-year credential (as a default) if all required documentation accompanies the application, even if the mariner does not select "renew' on the application form, or the evaluator should contact the mariner to inquire if they are requesting a raise in grade, which would not reset the expiration date.  Replace text as follows: " If an applicant for a new endorsement or a raise in grade meets the renewal requirements under 10.227 for the endorsements listed on the MMC, that applicant will receive a credential valid for 5 years.  Where an applicant does not meet the renewal requirements for an endorsement(s) such endorsement(s) may be issued with the expiration date that is the same as the current MMC." Closed

30-11 T/S 75 STCW SNPRM 10.232(a)(5) - Delete the word "direct" in the last line.  Replace reference to 11.328 with 11.329 and check all references to ensure there are no errors. (Supposed to be referring only to STCW).

Closed

31-11 T/S 75 STCW SNPRM 10.232 (b) - Insert a new paragraph that would allow the issuance of an STCW-restricted certificate based on seagoing service on the waters of British Colombia and the inland passage. (as day for day service on inland waters).  To ensure continued service for seafarers working in this area. Closed

32-11 T/S 75 STCW SNPRM 10.235(h) and (i) - Change "will" to "may" since TWIC is no longer required for all mariners.  Should insert text directing mariner to appeal to TSA not USCG. Closed

33-11 T/S 75 STCW SNPRM 10.237 - Change in the red line of the SNPRM did not appear in the FR SNPRM.   Change is not significant.   Closed

34-11 T/S 75 STCW SNPRM 10.301(a) - MERPAC believes that the NMC process needs to refocus the medical review of mariners so that the process is risk based.  Additionally, MERPAC is concerned that the change to the medical review process requiring the implied issuance of a medical certificate will exceed the capabilities of the NMC because of the increase in the number of reviews necessitated by the proposed 1 and 2-year cycle of certificates, and an unacceptable backlog will be created.  Therefore, mariner's jobs would be jeopardized.

Therefore; Replace "operational limitations" with "limitations and/or other conditions......."   (to assure consistency with NVIC). Open

35-11 T/S 75 STCW SNPRM 10.301(b) - MERPAC believes that the NMC cannot adequately conduct or issue the certificates in a timely manner as laid out in this section.  We believe that the only long term solution is development of a designated medical practitioner issued certificate as an option for the mariner.  The designated medical practitioner should only be "an option" since there may not be enough mariners in an area to support this system. open

36-11 T/S 75 STCW SNPRM 11.709(b) - In addition to necessary amendments to 46 CFR § 10.301, in order to put into effect MERPAC's recommendation that first class pilots and mariners merely "serving as" a pilot be required to have 5 year medical certificates (instead of 1 year medical certificates), 46 CFR § 11.709(b) and (d) should be amended as follows:

    (b) Every person holding a license or MMC endorsement as first-class pilot must have a thorough physical examination each year, to be completed by the first day of the month following the anniversary of the individual's most recently completed Coast Guard required physical examination.  Every fifth year, as per the medical certificate/endorsement requirements in 46 CFR § 10.301(b),  the results of the physical examination must be recorded on a CG-719K form and submitted to the Coast Guard no later than thirty (30) calendar days after completion of the physical examination.         "PLAN B":  MERPAC feels strongly about the above recommendation.  However, as a "Plan B" in the event the Coast Guard does not accept MERPAC's recommendations that first class pilots and mariners merely "serving as" a pilot be required to have 5 year medical certificates, MERPAC recommends that first class pilots and "serving as" pilots be required to have 2 year medical certificates.  Under "Plan B", 46 CFR § 11.709(b) and (d) should be amended as shown below:

    (b) Every person holding a license or MMC endorsement as first-class pilot must have a thorough physical examination each year, to be completed by the first day of the month following the anniversary of the individual's most recently completed Coast Guard required physical examination.  Every other year, as per the medical certificate/endorsement requirements in 46 CFR § 10.301(b),  the results of the physical examination must be recorded on a CG-719K form and submitted to the Coast Guard no later than thirty (30) calendar days after completion of the physical examination.       (d) If a person holding a first class pilot license or endorsement does not submit his or her CG-719K form in accordance with 46 CFR § 11.709(b), the individual may not operate under the authority of that license or endorsement until the CG-719K form has been properly submitted to the Coast Guard.

(b)(3)  If Coast Guard moves forward with a certificate for national mariners, pilots should be included in this group if applicable.  Closed

37-11 T/S 75 STCW SNPRM 10.304(b) What is a communicable disease? CG needs to define exactly what the concerns are.  Mariners that ONLY have a FH credential are receiving extensive, potentially unnecessary, medical testing. Clarification needs to be provided in guidance as there currently is no standard for  "communicable".     Closed

38-11 T/S 75 STCW SNPRM 10.304(d)(2) - Recommend dropping (d)(2) which has been imported from NVIC and STCW. Recommend leave it in guidance. Closed

39-11 T/S 75 STCW SNPRM 10.305 - (b) Amend redline to conform with SNPRM.

Closed

40-11 T/S 75 STCW SNPRM 10.402 - Change "course approval" to mirror the IMO format to avoid confusion in the implementation.

Closed

41-11 T/S 75 STCW SNPRM 10.402(e) - Add "significant" before the word "change" in course approval.

Closed

42-11 T/S 75 STCW SNPRM 10.403 (a)(6)(i) - Replace "answers" with "scores"

Closed

43-11 T/S 75 STCW SNPRM 10.403(a)(6)(iii) - Change to read "Compliance with attendance policy."

Closed

44-11 T/S 75 STCW SNPRM 10.403(a)(7) - Add "significant" before "change".

Closed

45-11 T/S 75 STCW SNPRM 10.404(a)(3) - After "allowed," add "substitution of required service as a result of ..."   (to avoid individuals from having to take the same class twice to maintain an endorsement when upgrading). Closed

46-11 T/S 75 STCW SNPRM 10.405 - Include a five-year renewal requirement for QA and DE, consistent with the five-year requirement for instructors.

Closed

47-11 T/S 75 STCW SNPRM 10.405(a) (3) - After "a level of qualification", insert "being sought," and change "training objectives" to "tables of competence".

Closed

48-11 T/S 75 STCW SNPRM 10.405 - Change paragraph (c) into new paragraph (b)(4). In new (b)(4), change "and/or" to "or"; and delete the final sentence.  The sentence is an IMO reference that is inappropriate for a domestic credential. Closed

49-11 T/S 75 STCW SNPRM 10.409(h)(2)(i) - MERPAC believes this language is unclear. Change the word "client" to insure that it reflects the intent that a QSS cannot approve courses for a subsidiary of its own organization. Closed

50-11 T/S 75 STCW SNPRM 10.410 - Include a requirement that if company training is included under the ISM, the Coast Guard should accept ISM to the extent that it meets the QSS requirements. Closed

51-11 T/S 75 STCW SNPRM 10.410(d) - change "national" to "nationally recognized".

Closed

52-11 T/S 75 STCW SNPRM 10.410(c)(2)(v) - delete "training"

Closed

53-11 T/S 75 STCW SNPRM 10.410(c)(3) - delete proposed language and insert "Organizations are subject to audits at least twice in a five-year period.  Organizations should cooperate with Coast Guard scheduled audits." Closed

54-11 T/S 75 STCW SNPRM 10.412  - Replace "A-1/6" with "B-1/6"

Closed

55-11 T/S 75 STCW SNPRM 46 CFR 11 General Comment  --  Mariners should not be able to obtain an STCW endorsement without meeting the service requirements for the associated national endorsement.  This is not about qualification requirements, it IS about progression requirements. Closed

56-11 T/S 75 STCW SNPRM 11.102(a) - link is not helpful... Somehow, make STCW available to the general public.  It is not sufficient to incorporate by reference, since the document is only available by purchasing it.   Closed

57-11 T/S 75 STCW SNPRM 11.201(a) - change "passage of a professional examination" to "demonstration of competence  (more encompassing of different methods). Closed

58-11 T/S 75 STCW SNPRM 11.201 (e)(2) - No STCW endorsements listed considering the title and the application of the entire section.

Closed

59-11 T/S 75 STCW SNPRM 11.201 (f) - amend to be consistent with 10.301(a).

Closed

60-11 T/S 75 STCW SNPRM 11.201 (h)(1) - recommend change "within the previous" to read "more than".  Coast Guard needs to define "evidence" as detailed in the proposed language.  (global) Closed                                                  1.   61-11 T/S 75 STCW SNPRM 11.201(j)(1)(iii) -recommend extend time from 3 months to 6 months. Closed

62-11 T/S 75 STCW SNPRM 11.301(i) - should extend grandfathering provisions.  (persons with an operational level endorsement upgrading to management level should not be required to do the assessments for operational level, since they were already completed) Closed

63-11 T/S 75 STCW SNPRM 11.305(a)(3)(ii) - Change language "if required" to read "if serving on a vessel..." consistent with STCW. Closed

64-11 T/S 75 STCW SNPRM 11.309 (b)(1) - but also global...  Leadership competency  -  how is it achieved? Specify in regulations or policy what kind of evidence will be used.  Closed

65-11 T/S 75 STCW SNPRM 11.323 (b)(2) - Change "completing Coast Guard approved or accepted training" to "demonstrating competence".

Closed

66-11 T/S 75 STCW SNPRM 11.323(e) - Delete  -   this is inconsistent with 15.915.

Closed

67-11 T/S 75 STCW SNPRM 11.325(a)(3)  and other  similar paragraphs are unnecessary. (This applies to all sections with the same language) and should deleted as it not reflecting the required competencies. Closed

68-11 T/S 75 STCW SNPRM 11.325(b)(2) - Why has this specifically been mentioned, when the STCW table mentions managing other items? (this function is not new to STCW). (This applies to all sections with the same language) 11.325(c) - Recommend that a working group be formed with Coast Guard HQ and NMC and industry to clarify and define the certification process for single or limited size engine staff.  In addition, this working group should also develop the same for vessels of limited size deck staffing. Change the wording in the last sentence as follows: "Under these circumstances, the certificate may will include a corresponding limitation." (This applies to all sections with the same language). Open

69-11 T/S 75 STCW SNPRM 11.335(c) - Delete current text and replace with "An applicant who holds an STCW endorsement as OICEW, second engineer officer, or chief engineer officer will be allowed to receive the ETO endorsements upon completion of the requirements in Section A - III/6 of the STCW Code" Closed

70-11 T/S 75 STCW SNPRM 11.335(d) - Delete due to above recommendation. Closed

71-11 T/S  75 STCW SNPRM Table 11.505(a) - Use attached table as needed (as modified in 4 year row between 2 A/E Unlimited and Chief Engineer Limited) and notes (Need to add appropriate Limited Chief Engineer, MODU and OSV Engineer Endorsements).  Effect is to eliminate engineer near coastal endorsement.  If working outside of boundary line, STCW applies.  If not, US endorsement applies.  (new crossovers)  Need better explanation of crossover from Unlimited DDE to OICEW within regulations (DDE to have x years as DDE = OICEW (after completing assessments).    Need to develop assessments for Limited Chief Engineer at STW 43 Closed

72-11 T/S 75 STCW SNPRM 11.516(a)(3) - Replace "graduation from" with "completion of an Engineering Officer Qualification Course".  An EOOW letter from the Army, Coast Guard or Navy should be prima facie evidence of competence.   Closed

73-11 T/S 75 STCW SNPRM 11.403 Table - Insert exam between 2nd mate and C/M on far-left progression. Also in Table, in far right progression, don't have to go through BCO/BS to get to OIM.  It is only one path. Re-assess entire chart for accuracy, including the two above. Closed

74-11 T/S 75 STCW SNPRM 11.404(c) (et seq). - Great Lakes time is linked with inland time... need to break out, 12 months for GL and 24 months for inland.  All the way through, even in UIFVs and T/V. New policy recognizing GL time as equivalent to ocean not carried through in Section 11. Closed

75-11 T/S 75 STCW SNPRM 11.463 - Harbor assist license  -  creation of a new license would unnecessarily complicate the licensing scheme and potentially stovepipe mariners.  The current TOAR system allows mariners to complete applicable assessments and receive a restricted towing license. Closed

76-11 T/S 75 STCW SNPRM 11.470 - (b)(2)(iii)  -  check name (check to see if BOEMRE/MMS still exists)...recommend that correct name be obtained before publication. Closed

77-11 T/S 75 STCW SNPRM 11.480(d) - confusing... when renewing radar endorsement or credential endorsement?    Re-draft to ensure current practice of not putting radar endorsement on MMC is stated. Closed

78-11 T/S 75 STCW SNPRM 11.709(d) and 713(a) come up with a different term than "invalid."

Closed

79-11 T/S 75 STCW SNPRM 11.821 - Adding this standard extracted from a different (HSC) code is confusing and inappropriate. At a minimum add clarification about high speed craft code (reference the code) and to what vessels it applies to.  Closed

80-11 T/S 75 STCW SNPRM 11.900 tables are pre-STCW-95.   MERPAC recommends that the tables be separated by operational and management levels.  Small group to discuss and to locate any Δ between national and STCW endorsements that occur in this table.

      1). Completely remove the table 11.910-2 & 11.950-2 from the SNPRM.        2). In lieu of the table, the USCG should issue documentation with considerable detail as to what is contained in each exam for each license level.        3). MERPAC should assist in the development of this documentation, which might take the form of a module description as has been used in the past.        4). MERPAC Task 71 regarding license exam questions cannot logically proceed until recommendations 1-3 are well underway Open

81-11 T/S 75 STCW SNPRM Part 12 - Global  -  make endorsements comply with the titles in the law

Closed

82-11 T/S 75 STCW SNPRM 12.409(a) - change  after "every person" to read "every person serving under the authority of a rating endorsement as lifeboatman-limited on any United States vessel fitted with liferafts but not fitted with lifeboats must hold an endorsement as lifeboatman or as lifeboatman-limited." (bad language in both 12.407 and 12.409). Closed

83-11 T/S 75 STCW SNPRM 12.601(c) - make identical to 11.301(b)(3).

Closed

84-11 T/S 75 STCW SNPRM 12.601(b)(1)(i) - add text to require a QA.

Closed

85-11 T/S 75 STCW SNPRM Table 12.603(e)  - Able Seafarer Special.  Include a new footnote to allow for the reduction of sea service (6 months) by taking an approved course.

Closed

86-11 T/S 75 STCW SNPRM 12.603(b) - first line  -  change "may" to "shall"

Closed

87-11 T/S 75 STCW SNPRM 12.605 -  Table 12.605(c) - Ordinary seamen.  Include a new footnote to allow for the reduction of sea service (6 months) by taking an approved course. Closed

88-11 T/S 75 STCW SNPRM 12.607(b) - first line  -  change "may" to "shall"

Closed

89-11 T/S 75 STCW SNPRM 12.611(b) - Delete current text and replace with "An applicant who holds an STCW endorsement as able seafarer-engine and domestic rating endorsements as electrician, electrician/refrigerating engineer, or junior engineer will be allowed to receive the ETR endorsements upon completion of the requirements in Section A - III/7 of the STCW Code". Closed

90-11 T/S 75 STCW SNPRM 12.611(c) - Delete due to above recommendation

Closed

91-11 T/S 75 STCW SNPRM 12.625 and 627 - re-draft to ensure that it provides all transitional provisions from STCW.  (check 15.1113 implementation date and make sure they're the same). Closed

92-11 T/S 75 STCW SNPRM 13.107(d) - revise text  -  remove " and for maintaining and operating the bunker systems including the fuel oil" (tankerman engineer is specifically for cargo operations.  Delete everything after the semicolon.)  and add "liquid cargo  in bulk".  Ensure that text does not apply to the transfer of other than bulk liquid cargoes and a tankerman endorsement is not needed. Closed

93-11 T/S 75 STCW SNPRM 13.117  -  1. revise to allow applicant to complete an approved course for renewal when expired for more than 12 months   see 13.120(a)(3).   Many mariners are not aware that taking a course counts towards renewal of tankerman endorsements.  This would allow the mariner the ability to maintain  their tankerman endorsement following expiration of greater than 12 months. 2. Change reference from rating to endorsement.   Closed

94-11 T/S 75 STCW SNPRM 13.120(a)(1)  - after tank vessel, insert "including service aboard a barge, as appropriate".  This is to enable mariners serving on towing vessels, with tankerman credentials, the ability to renew those credentials. Closed

95-11 T/S 75 STCW SNPRM 13.203  -  add text to give ATBs full credit for sea time and experience (loads/discharges) towards full tankerman-PIC endorsement.  Many new ATBs have identical cargo-handling equipment as tankships.   Closed

96-11 T/S 75 STCW SNPRM 13,203(c) - need to include a crossover program from different types of tankers.  Seafarers would already have tanker experience.  A shorter course consistent with the STCW could be appropriate. Closed

97-11 T/S 75 STCW SNPRM    13.603  -   Split oil and chemical tanker requirements into separate sections... can combine courses, but split sea time requirements.  Incorporate STCW code properly..  include fast track in regulation V/I-1.  Seafarers serving on board tankers certified to carry both oil and chemical should receive sea credit for both oil and chemical.

allow T/E to obtain this endorsement so C/E and 1st don't have to get tankerman-PIC endorsement...  Under this text engineers C/E and 1st will be unable to do the loading and discharges.    Include language to allow mariners with STCW management level engine endorsements and tankerman-engineer national endorsement to receive an STCW Advanced tanker cargo operations endorsement if they have completed the STCW assessments.  Changes may be accomplished by amending the domestic (13.201) requirements and the STCW requirements.

Create a new STCW section for Tankerman (Barge) to build on 13.301 for the service requirements but not the training requirements.  The training requirements would be the same as 13.201.  Include grandfathering provisions. Closed

98-11 T/S 75 STCW SNPRM 13.605 -- Apply comments from 13.603, as appropriate.

Closed

99-11 T/S 75 STCW SNPRM Part 15 - General comments - Add section about manning documents and COIs should also separately specify the STCW endorsements that must be carried onboard for international voyages. Closed

100-11 T/S 75 STCW SNPRM Part 15 - Pilots  -  The statutory requirement does not require submission of the medical exam nor does it imply issuance of a new certificate.  Considering the high volume of medical certificates that will need to be processed to move to a 2 year medical certificate, the Coast Guard should continue a five-year certificate applicable to first class pilots and those serving as first class pilots. Amend 15.401(c)(3)  to include first class pilots and delete 15.401(c)(2) where the pilot would be subject to an annual medical exam and should make it available upon request.  Change 10.301 and 11.709 accordingly Closed

101-11 T/S 75 STCW SNPRM Part 15 - The Coast Guard should issue a notice to all shipowners explaining the implementation of the US medical certificate to facilitate port state control inspections. Closed

102-11 T/S 75 STCW SNPRM Part 15 - Add New 15.105(g)(3) Add:  Pilot vessels are not considered seagoing ships because they operate within, or closely adjacent to, sheltered waters or areas where port regulations apply. Closed

103-11 T/S 75 STCW SNPRM 15.401(c)  -  medical certificate, there is no effective date.  Add an additional sentence:  "Until such date as a separate certificate is issued, a valid MMC serves as the medical certificate."   Closed

104-11 T/S 75 STCW SNPRM 15.401(c)  -  Amend to ensure that is not meant to include uncredentialed mariners.  Amend "A person may not employ or engage an individual who is employed in a position required to hold an MMC..." Closed

105-11 T/S 75 STCW SNPRM 15.403(a) requirement to have a TWIC with an MMC is in conflict with the current statutes.  Amend by adding "if applicable"

Closed

106-11 T/S 75 STCW SNPRM 15.403(b) requirement to have a TWIC with an MMC is in conflict with the current statutes.  Amend by adding "if applicable" Closed

107-11 T/S 75 STCW SNPRM Part 15 - General comment  -  Text should honor original agreement with DOT that the STCW application in domestic trade would start at 500 GRT.  Amend text in Part 15 to apply this agreement.          * Global change in Part 15 - add "or 500 GRT on a domestic voyage" wherever 200/500 tonnages are used.  This is per DOT agreement to use 500 GRT and on the application of the STCW.

         * Global change in Part 15  -  add " after seagoing vessel"  wherever  horsepower is mentioned, tonnage should be also mentioned 200 GRT/500 GT.  Example "seagoing vessel of 200 GRT/500 GT or more driven by main propulsion machinery of 1000HP/750 kW propulsion power or more..." Closed

108-11 T/S 75 STCW SNPRM 15.404(d)(3)     Recommend delete current language indicating that all ratings, including wipers, must possess endorsement as Able Seafarer  - Engine instead of QMEDs.  MERPAC needs to categorize what QMED categories should be RFPEW (watchstanding) (FWT, Oiler) and which QMED categories should be Able Seafarer  -  Engine (non-watchstanding) (all others) to reflect the rating who stands a watch and who does not.

Requirements should reflect that all those watchstander ABs and QMEDS are required to hold RFPNW or RFPEW.

"QMEDs serving on vessels in a non-watchstanding position, excluding wipers, oilers and FWT, must hold able seafarer-engine." Closed

T/S 75 STCW SNPRM 15.405 - Too broad, goes too far beyond what should be required.  Replace "on which he or she is engaged" with "appropriate to their duties and responsibilities".  Second sentence - After the word "these" insert "may". Closed

110-11 T/S 75 STCW SNPRM 15.515 (b)  -  overly restrictive and impossible during normal vessel operations.  Delete "made fast to shore". Closed

111-11 T/S 75 STCW SNPRM 15.816- change "competence" to "documentary evidence meeting the regulations as per 46 CFR 11.23xx".  Closed

112-11 T/S 75 STCW SNPRM 15.818  -  There are no guidelines for GMDSS maintainer courses in the U.S.  These need to be developed and provided to industry.

Open

113-11 T/S 75 STCW SNPRM 15.860(i) to (j)  -  Amend paragraph (i) in accordance with the recommendation under Part 13 to include a new STCW endorsement for barge.Closed Closed

114-11 T/S 75 STCW SNPRM 15.860  -  Table 1 Place double or triple asterisks and associated note that an engineer who holds a tankerman PIC (XX) can be substituted for a tankerman-engineer. Closed

115-11 T/S 75 STCW SNPRM 15.901  -  conflict between redline and SNPRM.  Redline is correct version.

Closed

116-11 T/S 75 STCW SNPRM 15.901(c)-  amend to be consistent with definition of self-propelled vessels.

Closed

117-11 T/S 75 STCW SNPRM 15.905- conflict between redline and SNPRM.  Redline is correct version.

Closed

118-11 T/S 75 STCW SNPRM 15.915 (a)- Return the conditions under which a DE can sail to the current regulations,  need to retain the 500 GRT limit.

Closed

119-11 T/S 75 STCW SNPRM 15.1101  -  See recommendation regarding exemption of pilot vessels to STCW.

After "of this subchapter," change comma to period and delete the remainder of the sentence.  This is done to increase the clarity of paragraphs 1 and 2. Closed

120-11 T/S 75 STCW SNPRM 15.1103(a)  -  add at the end of the paragraph "and other relevant national license requirements".

Closed

121-11 T/S 75 STCW SNPRM 15.1103(b) and (c)  -  change the tonnage to 500 "GRT" and add tonnage to all HP references. Closed

122-11 T/S 75 STCW SNPRM 15.1103(e) (1) -  change to " serving on seagoing vessels, except those vessels listed in 15.1101 of this part".  Add also to implementation of medical certificate in earlier recommendations about implementation date. Closed

123-11 T/S 75 STCW SNPRM 15.1105  -  Subparagraphs written too broadly.  Add insertion referencing exempted vessels from paragraph (a) into paragraphs (b) and (c).

Closed

124-11 T/S 75 STCW SNPRM 15.1105( c )(1)  -  change from "BST or safety familiarization" to "BST and safety familiarization specific to that vessel."

Closed

125-11 T/S 75 STCW SNPRM 15.1109   -  add " serving on seagoing vessels, except those vessels listed in 15.1101 of this part".

Closed

126-11 T/S 75 STCW SNPRM 15.1111(i)  -  in SNPRM, but not in redline, match up redline to match SNPRM. 15.1111(j)  - delete from SNPRM (not in redline).

Closed

127-11 T/S 75 STCW SNPRM 15.1111  -  add definition of "work" which includes drills not being counted as such.  Use an existing definition that is consistent with other regulations dealing with work and rest.  Concern expressed about meeting and logging OPA 90 work rules versus STCW rest rules. Outside of this rulemaking, Congress should revisit OPA 90 work rules and revise to be consistent with STCW. Closed

128-11 T/S 75 STCW SNPRM 15.1113(c)  -  Amend text to address the following issues:    * Ensure (a), (b) and (c) apply only to vessels over 500 GRT;    * Include all transitional provisions from STCW;    * Account for existing mariner compliance by 2012;    * Account for new mariners compliance by 2014;    * Contractors and other personnel should not be required to obtain an endorsement  (additional burden); and    * Individuals who have completed a USCG accepted VSO course or have been designated as VSO are considered as having met the requirements of training for personnel with or without security duties.    Ensure that requirements take into account STCW.Circ 7(16) providing a compliance waiver until 2017.         MERPAC recommends that the text should be amended as follows: § 15.1113  Security personnel. (a)  Onboard a seagoing vessel of 200 GRT/500 GT or more, all persons performing duties as Vessel Security Officer (VSO) must hold a valid endorsement as VSO. (b)  Persons who hold an endorsement as VSO will be deemed to satisfy the requirements for vessel personnel with security duties in paragraph (c) of this section. (c)  After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all personnel with security duties must hold a valid endorsement as vessel personnel with designated security duties, or a certificate of course completion from an appropriate Coast Guard-accepted course meeting the requirements of 33 CFR 104.220. (d)  Persons who hold an endorsement as vessel personnel with security duties, or a certificate of course completion from an appropriate Coast Guard-accepted course will be deemed to satisfy the requirements for all other vessel personnel in paragraph (e) of this section.  (e)  After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all other vessel personnel must hold a valid endorsement in security awareness, or a certificate of course completion from an appropriate Coast Guard-accepted course meeting the requirements of 33 CFR 104.225. (f)  After 1 January 2012, onboard a seagoing vessel of 200 GRT/500 GT or more, all contractors, whether part-time, full-time, temporary, or permanent, must have knowledge of, through training or equivalent job experience in accordance with the requirements of 33 CFR 104.225.  Vessel owners and operators must maintain records documenting this requirement and produce those records to the Coast Guard upon request. Closed

129-11 T/S 75 STCW SNPRM § 11.813   Requirements to qualify for an STCW endorsement as vessel personnel with security duties. (a) The applicant for an endorsement as vessel personnel with security duties must present satisfactory documentary evidence of meeting the requirements in 33 CFR 104.220. (b) All applicants for an endorsement must meet the physical examination requirements in 46 CFR, part 10 subpart C. (c)  All applicants for an endorsement must meet the safety and suitability requirements and the National Driver Registry review requirements in §10.209(e) of this subchapter, unless they have met these requirements within the previous 5 years in connection with another endorsement. (d)	Until 1 January 2014, seafarers who commenced an approved seagoing service prior to 1 January 2012 shall be able to apply for an endorsement as vessel personnel with designated security duties by: (1)	approved seagoing service as shipboard personnel with designated security duties, for a period of at least six months in total during the preceding three years; or (2)	having performed security functions considered to be equivalent to the seagoing service required in sub-paragraph paragraph (d)(1) of this section; or (3)	passing an approved test; or (4)	successfully completing approved training. Closed

130-11 T/S 75 STCW SNPRM § 11.815   Requirements to qualify for an STCW endorsement in security awareness. (a) The applicant for an endorsement security awareness must present satisfactory documentary evidence of meeting the requirements in 33 CFR 104.225. (b) All applicants for an endorsement must meet the physical examination requirements in 46 CFR, part 10 subpart C. (c)  All applicants for an endorsement must meet the safety and suitability requirements and the National Driver Registry review requirements in §10.209(e) of this subchapter, unless they have met these requirements within the previous 5 years in connection with another endorsement. (d)	Until 1 January 2014, seafarers who commenced an approved seagoing service prior to 1 January 2012 shall be able to apply for an endorsement in security awareness by: (1)	approved seagoing service as shipboard personnel, for a period of at least six months in total during the preceding three years; or (2)	having performed security functions considered to be equivalent to the seagoing service required in sub-paragraph of this section; or (3)	passing an approved test; or (4)	successfully completing approved training. Closed

131-11 T/S 75 STCW SNPRM STCW Engineering competencies with formal training requirements

Table A-III_1 - OICEW

Application of Leadership & Teamworking skills  -  ERM - No subject matter experts on board, no time, & more effective.

Maintenance and repair of electrical and electronic equipment  -  Safety Concerns Closed

132-11 T/S 75 STCW SNPRM STCW Engineering competencies with formal training requirements

Table A-III_2  -  Management Level CE/2E

Use leadership and managerial skills - No subject matter experts on board, no time, & more effective.

Maintain safety and security of the vessel, crew and passengers and the operational condition of life-saving, fire-fighting and other safety systems  -  Required by STCW.

Table A-III_4  -

Table A-III_5 -

Table A-III_6

The USCG needs to ensure that assessments (i.e. exams) are truly testing knowledge, not just the ability to memorize answers to questions.  This may include removing access to exam questions for studying or moving away from the multiple choice exams. closed

133-11 T/S 75 STCW SNPRM STCW Deck competencies with formal training requirements

General Comments:

   1. Generally, the officers do not have the time to perform training and assessment onboard due to minimal manning, higher workload and operational constraints.      2. Under STCW mandatory rest period rules, the time available for training is limited.    3. The officers may not have the requisite knowledge to effectively teach and assess the needed subjects.    4. Training is not part of a ships officer's job description.    5. Most officers have not been exposed to "train the trainer" techniques.    6. Most officers are reluctant to assume the legal liability of training.    7. Some subjects can be better conducted ashore due to safety and economic reasons.    8. If a company wants to address the above issues, then the company must provide the resources to conduct approved onboard training.

Code reference:  Table A-II/1-Specification of minimum standard of competence for officers in charge of a navigational watch on ships of 500 gross tonnage or more

The following competencies and KUPs would better serve the intents of STCW if they were presented in a structured program:

   * Coastal Navigation theory (including magnetic and gyro compasses and passage planning);    * Basic Stability and trim;    * Watchkeeping (BRM, application of COLREGs)  -  simulation based );    * Celestial Navigation (for oceans endorsement);    * Meteorology;    * Basic Shiphandling; and     * Basic Cargo Handling .

The length of the training can vary depending on the delivery medium (classroom, online, shipboard, blended, etc.).  It should be the responsibility of the training provider to justify, to the National Maritime Center, how they can accomplish the goals in less time than outlined by the model courses.  (Start with the model course as the benchmark and adjust as necessary.)

The content of the training should be appropriate to the tonnage, route and/or type of vessel. For example, basic shiphandling can be performed aboard OSVs, tugs and ferries, rather than in a full-mission simulator.

Code reference:  Table A-II/2-Specification of minimum standard of competence for management level on ships of 3,000 gross tonnage or more

The following competencies and KUPs would better serve the intents of STCW if they were presented in a structured program:

   * Advanced Watchkeeping (simulation based focused voyage planning, communication and leading the bridge team);    * Advanced and Emergency Shiphandling (maneuvering a large vessel in restricted waterways);    * Advanced Cargo, Stability and Trim including damage stability;    * Weather routing ;    * Monitor, Control and Compliance with laws and regulations;    * IBS/INS; and    * Marine Propulsion Systems.

Code reference:  Table A-II/2-Specification of minimum standard of competence for management level on ships of greater than or equal to 500 GT, but less than 3,000 GT.

The following competencies and KUPs would better serve the intents of STCW if they were presented in a structured program:

   * Advanced Watchkeeping  (voyage planning, communication and leading the bridge team);    * Advanced and Emergency Shiphandling * (maneuvering a large vessel in restricted waterways);    * Advanced Cargo, Stability and Trim including damage stability;    * Weather routing ;*    * Monitor, Control and Compliance with laws and regulations;    * IBS/INS, if so equipped; and    * Marine Propulsion Systems.

*The content of the training should be appropriate to the tonnage, route and/or type of vessel. For example, Advanced and Emergency shiphandling can be performed aboard OSVs, tugs and ferries, rather than in a full mission simulator. closed

134-11 No T/S MERPAC recommends that the government pursue creating methods of funding for maritime education due to the impact of the regulatory training and education requirements. (46 USC sec 51103)  closed

01-12 N/A Recognizing that proficiency in English is already required for officers and qualified ratings, MERPAC recommends that the Coast Guard establish minimum requirements for English language for all ratings.  All seafarers should be able to speak and understand the English language to perform their general and emergency duties on board a ship open

02-12 N/A MERPAC recommends that, since TWIC credentialed individuals have demonstrated that they are low risk and that they have been extensively background checked, they should be expedited through the airport screening process. closed

03-12 T/S 76 & 77 The assessment guidelines tables for Master/Chief Mate 500-3,000 GT were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac ; then click on Meetings/Minutes; then click on meeting 36 to view the enclosures. Closed

04-12 T/S 58 MERPAC recommends that the Coast Guard revise Task Statement 58 by amending the title to, "Stakeholder Communication in the Mariner Credential Program."  MERPAC further recommends that the task statement be retained as an open one.   The entire supporting language of the task statement will need to be updated to support the new task title.  Change the due date to remain open as long as MERPAC chooses.   The Coast Guard has made great progress since this Task Statement was adopted and MERPAC appreciates all the work and progress that has been done to date. Closed

05-12 T/S 58 MERPAC recommends that Brochures are needed on additional subjects, starting with How to Use the Regional Exam Center, the Medical Process, Safety and Suitability checks; what they are and what they aren't.  Language needs to be plain English...NO ACRONYMS!!  Ask mariners to view product before producing. Closed

06-12 T/S 58 MERPAC notes that the Web page is a big plus; list serve is a plus, but recommends that NMC needs to use social media:  Facebook and You Tube, videos, etc.   open

07-12 T/S 58 MERPAC recommends that the Coast Guard explain the process to obtain and the possibilities once one holds a credential by having RECs participate in local job fairs/visiting maritime high schools and mariner trade school programs, etc. Closed

08-12 T/S 58    1. MERPAC recommends that the Coast Guard find a way to create a credential issue number:        Example:  00-00-00-00       License-document-STCW-Tankerman issue number for example closed

09-12 T/S 58 MERPAC feels that a Certificate for framing is unacceptable and mariners are not using it.  MERPAC recommends that the Coast Guard finish creating a professional, attractive document suitable for framing using the original license template, border and artwork. Closed

10-12 N/A In support of MERPAC's previous recommendation to the SNPRM that STCW Assessments be conducted by qualified assessors, MERPAC recommends that the Coast Guard task MERPAC with assisting in the development of appropriate standards for qualified assessors and in defining a quality control system that assures the integrity and accountability of assessments for both institutional and in service assessment. Closed

11-12 T/S 30 Recognizing the complexity involved with sea time and training for transitioning military service personnel to the merchant marine, MERPAC recommends that NMC and the REC have a designated person, who has expertise in the military/merchant marine nexus, to assist veterans toward the their fullest potential in maritime careers. This may be facilitated by piloting transition initiatives in several cities having military service populations. Closed

12-12 T/S30 In response to President Obama's June 1, 2012 call for greater effort by federal agencies to assist veterans in transitioning to the civilian workforce, MERPAC recommends that the Secretary of Homeland Security encourage her counterparts at the Department of Defense and other appropriate agencies to:       a. Establish a dedicated person to act as a liaison with the National Maritime Center for course approval and course renewal; and       b. That this person have a long term position. Open

13-12 T/S 30 MERPAC encourages the military services to establish tracking of the levels of credentials being sought by current and former military personnel to establish effectiveness of pilot programs. Closed

14-12 T/S 77

The assessment guidelines tables for Officer in Charge of a Navigational Watch and Master for near-coastal vessels of less than 500 GT were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures. Closed

15-12 T/S 77 The assessment guidelines tables for Able Seafarer - Deck were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures. Closed

16-12 T/S 77

The assessment guidelines tables for Chief Engineer (Unlimited) were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures. Closed

17-12 T/S 77 The assessment guidelines tables for Chief Engineer (Limited) were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures. Closed

18-12 T/S 77 The assessment guidelines tables for Able Seafarer - Engine were accepted by the full Committee and presented to the Coast Guard.  They may be viewed at: http://homeport.uscg.mil/merpac; then click on Meetings/Minutes; then click on meeting 37 to view the enclosures. Closed

19-12 T/S 79 Dynamic Positioning Officers (DPO) should be credentialed but not necessarily "licensed." If the DPO is not a licensed officer, a licensed officer of the navigation watch shall be provided, if required. Closed

20-12 T/S 79 Minimum training for DPOs should be recognized as meeting:          a.  International Marine Contractors Association (IMCA) M117; and          b.  Maritime Safety Committee (MSC) MSC.1/Circ.738/Rev.1 standards. Closed

21-12 T/S 79 In addition to II. (2), further training may be required to ensure the proper performance of duties and should be the responsibility of companies based on the DP system, vessel type, and service/activities. Closed

22-12 T/S 79 Operational measures (including manning, watch protocols, etc.) will be based on risk assessments performed under a Safety Management System. Closed

23-12 T/S 79 These recommendations could be applied to operations outside of the Outer Continental Shelf. Closed

24-12 T/S 58 MERPAC recommends that the NMC should make it clear to mariners and Coast Guard employees alike that the time period for mariners to submit additional information (AI) to the NMC was established to ensure that files submitted to the NMC remain active.  When a mariner is "in extremis" on a license application, the additional stress of a ticking clock is unnecessarily stressful. If a mariner or their designated third party contacts the NMC regarding the open application, that contact should automatically be regarded as a request for additional time. Closed

25-12 T/S 58 MERPAC recommends that the application form for a merchant mariner credential be updated.   The position of the committee has been and continues to be that once a mariner has any issue that has been adjudicated, and if it was listed on their last application, that issue should not be required to be listed on each subsequent application.  The Committee questions the need for the mariner to disclose the issuance of a Letter of Warning at any time, but he or she certainly should not have to disclose the same letter at each application.   Closed

26-12 T/S 58 Section 809 of the Coast Guard Authorization Act of 2010 relieved mariners that do not access restricted spaces on U.S. vessels from having to hold a TWIC.  Yet, mariners are currently paying twice for a card they no longer need.  The Coast Guard needs to work with TSA to retain the current fee structure in the Code of Federal Regulations which separates the TWIC fee into the three components.  This would ensure that mariners can pay the fee for the collection of data and the background check, ONLY.  These mariners should not be required to pay for the card production, since they will not pick up the card.  MERPAC believes that the collection of this fee can be ceased immediately.  Additionally, the Coast Guard should continue to actively pursue, in those locations where it is possible, the co-location of a TWIC enrollment center at each Regional Exam Center.  TSA and its contractor conducted a pilot project in two REC locations, which was by all accounts extremely successful, but it states that it has no intention to expand this concept. Open

01-13 T/S 30 MERPAC recommends that the NMC find and identify ACE-approved (American Council on Education) courses and training that are conducted by the military maritime training institutions that could then be recognized by the NMC in part or in whole for required training for merchant marine ratings, endorsements, or licenses. Members of the work group recalled NVIC 09-01 that addresses this issue.

Open

02-13 T/S 30 MERPAC recommends that the Coast Guard establish a billet whose incumbent acts as a sponsor, who:          a. Is designated to respond to the needs of the stakeholders:                  i. Separating military personnel                  ii. Industry training facilities           b. Though this recommendation is directed at the Coast Guard,           c. MERPAC recommends that a similar billet should be   established in each military branch. Closed

03-13 T/S 30 MERPAC recommends that a designated NMC staff person be assigned to the Task Statement 30 work group. Closed

04-13 T/S 30 MERPAC recommends:             That the Coast Guard apply for course approval, and maintain approved courses with the National Maritime Center.              That the National Maritime Center accepts as equivalent ACE-approved courses or training submitted by a service member in place of a NMC-approved course or training.           c. MERPAC also believes that all military branches should have their courses approved by the NMC, and maintain all approved courses when they come up for renewal. Open

05-13 T/S 30 MERPAC recommends that the National Maritime Center develop career advisement materials, and make them available at REC's. These materials would be directed to service members, and guide them in translating military service and training to merchant mariner ratings, endorsements, and licenses. Open

06-13 T/S 71 Prior to updating these 46 CFR 11.910 (Deck) and 11.950 (Engine) tables to the STCW Manila Amendments, they must first be corrected for the International as well as Domestic licenses.  We will get only one shot at making changes to the 46 Code of Regulations and everything possible should be done so that it can all be accomplished at one time without leaving obvious errors in the table in existence.  It is recommended that MERPAC be tasked with these responsibilities. Closed

07-13 T/S 71 In the review of TS 71, it was stated that many Coast Guard certified courses would be required to be completed in order to comply with the STCW Manila Amendments.  MERPAC feels that it is redundant and a waste of resources to require mariners to again be tested on these previously Coast Guard certified courses during the license exams. Closed

08-13 T/S 71 MERPAC recommends that the current license exam format for the Operational level be pared down dramatically to reflect just those subject topics that fall outside of STCW and comply with the U.S. Domestic regulations. MERPAC recommends that it be tasked with this responsibility. Open

09-13 T/S 71

MERPAC recommends that all exams and assessments for limited, DDE and OSV licenses (Motors) be looked at when it comes to anything for steam, main boilers, auxiliary boilers, etc. as some vessels may not have this equipment. Closed

10-13 T/S 71 MERPAC recommends that a group should be formed to look at the assessments for the limited licenses made up to include the industry that uses limited licenses. MERPAC further recommends that it be tasked with this responsibility. Closed

11-13 T/S 77 Recommended assessment guidelines for Electro-Technical Officer may be located at: http://homeport.uscg.mil/merpac; then click on "Meeting 38" (under Meetings/Minutes);   Closed

12-13 T/S 77 Recommended assessment guidelines for Electro-Technical Ratings may be located at: http://homeport.uscg.mil/merpac; then click on "Meeting 38" (under Meetings/Minutes);   Closed

13-13 T/S 77 Recommended assessment guidelines for Able Seafarer-Engine may be located at: http://homeport.uscg.mil/merpac; then click on "Meeting 38" (under Meetings/Minutes);   Closed

14-13 T/S 80

The work group has identified a potential training gap for US seafarers specific to the crossover between DL and LG Tankerman endorsements.  Recently, the USCG NMC has interpreted the current CFR regulations to allow an individual currently holding DL Tankerman  endorsement and seeking an LG endorsement to only comply with the provisions of 46CFR13.203 (PIC)/46CFR 13.303 (PIC-barge)/46CFR13.503 (engineer), eligibility requirements that address seatime and transfer experience, and not comply with 46CFR13.201(f)(PIC)/46CFR 13.301(f) (PIC-barge)/46CFR13.501(f)(engineer) "Original endorsement" requirements that an individual meet the requirement of a course in DL or LG appropriate for the endorsement applied for. STCW  Regulation V/1-2 requires specific LG training commensurate with the individual's duties. As it stands now a US seafarer can obtain an LG endorsement, under the current NMC understanding of 46CFR, with no LG specific training.  This directly affects the grandfathering clauses and training requirements being considered by this working group.   MERPAC recommends that the CG enforce STCW Regulation V/1-2 and require LG training commensurate with the individual's duties. That before any tankerman (LG) endorsement be issued a USCG-approved tankerman (LG) course completion certificate be presented. Open

15-13 T/S 80 Companies that are starting LNG fuel operations for the first time require consideration of alternate certification proposals to certify initial vessel crews who may not have the opportunity to observe three (3) formal bunkering operations. MERPAC recommends that the Coast Guard consider alternate certification proposals to certify initial crews who are dealing with startup or new LNG operations who cannot comply with proposed Regulation V/X3. Closed

16-13 T/S 80 When a vessel manning is not consistent with the categories outlined in MSC 285 (86), section 8.2.1, MERPAC recommends that training and certification should be required of the deck and engine crew members assigned those duties and responsibilities. We recommend proposed Regulation V/X (2) and (3), add the term after officer to "or those crew members assigned similar responsibilities". Closed

17-13 T/S 80 MERPAC recommends editing Regulation V/X (4) (line 2) by changing "4" to "3". Closed

18-13 T/S 80 MERPAC recommends that the following wording be added to Regulation V/X (3)-  Simulator training including simulated bunker transfers may be used to satisfy up to 2 of the 3 required bunker transfers. This is consistent with current practice in simulator credit in Tankerman (LG) and (DL) courses. Closed

19-13 T/S 30 MERPAC recommends that it solicit members for a Maritime Industry sponsored private/public partnership to conduct the "mapping/comparison" of the military Personnel Qualifications System tasks to align with the STCW competencies and training requirements, so as to allow easier transition into maritime industry employment.

Open

20-13 T/S 30 MERPAC recommends that the USCG insert the following type of verbiage (taken from USCG-543 Policy Letter 11-07) into Policy Letter 14-02 for the purpose of authorizing the military Commanding Officer to assess the RFPEW and RFPNW competencies and KUP's:

"iii. when serving on a seagoing military vessel of at least 200 GRT/500 GT and is either the Commanding Officer, Executive Officer or is authorized to conduct similar Assessments for the U.S. Navy or for the U.S. Coast Guard Personnel Qualifications Standards (PQS) for underway Officer of the deck (OOD)".       The rationale is to allow engineering personnel to be STCW assessed aboard military vessels. Open

21-13 T/S 30 MERPAC recommends that the National Maritime Center staff a full-time Government Services employee dedicated to providing maritime career counseling and assistance to military veterans for obtaining endorsements and licenses in order to optimize their military qualifications for conversion to USCG and STCW credentials.

Closed

22-13 T/S 30 MERPAC recommends that the military branches improve the flow of civilian professional maritime credentialing information to its members on a continual basis, emphasizing the maritime credentialing process and its value early in the service member's career, thus allowing the service member to participate in the credentialing process while still on active or reserve duty.

Closed

23-13 T/S 30 MERPAC encourages the military to utilize civilian maritime terminology   whenever possible and offer professional credentialing pathways throughout the member's careers, i.e. Deck Watch Officer equals the STCW Officer in Charge of a Navigational Watch, Engineering Watch Officer equals the STCW Officer/Rating Forming part of an Engineering Watch, etc.

Closed

24-13 T/S 30 MERPAC recommends that the USCG, Navy and Army continue to seek USCG National Maritime Center approval of their courses for STCW credentialing. Closed

25-13 T/S 78 MERPAC adopts and recommends that the Coast Guard accept the recommendations of the Intercessional Work Group which gathered at the USCG Jemal Building in Southeast Washington, D.C. on Wednesday and Thursday, July 26-27, 2013. Open

26-13 T/S 78 MERPAC recommends that supplemental guidance to COMDTPUB P16700.4 / NVIC 02-13 (30 JUL 2013) be promulgated by the USCG providing for a Point of Contact to whom seafarers can report complaints [paragraph 6. Inspection Process, sub-paragraph (14) Onboard complaint procedures (MLC Regulation 5.1.5), p.23]. Open

27-13 T/S 80 MERPAC recommends that Task Statement 80 remain open until STCW is amended, the IGF Code manning and training requirements and National Regulations finish development due to ongoing developments, at IMO and nationally, and that our positions be retained as these developments progress and that the MERPAC working group meet during the Spring Meeting of 2014. Open

28-13 T/S 80 MERPAC recommends that a gap analysis be performed to determine the differences in training requirements between Tankerman PIC (LG) and that needed for personnel aboard vessels using natural gas as fuel to ensure that the training requirements for Tankerman PIC (LG) includes the requirements of the  personnel aboard vessels using natural gas as fuel. Closed

29-13 T/S 80 MERPAC recommends that Task Statement 80 be amended to include provisions for initial training should regulations not be available. Closed

30-13 T/S 80 MERPAC recommends that the Coast Guard regularly update MERPAC and the Task 80 working group of the ongoing work of relevant advisory groups and IMO.

Open

31-13 T/S 81 MERPAC recommends a 3 tier training program as follows:    * Safety awareness for all personnel onboard.    * Approved "basic training" course for all deck officers operating in the designated polar regions with the exception of vessels that will only be in the polar regions for very short durations (example along a great circle track).    * Approved "advanced training" for masters & chief officers operating vessels in the ice fields of the designated polar regions.

1  -  Revise 1st bullet point of item #5 of page 2 to state "Safety awareness for all personnel onboard" to `safety awareness for all deck and engine personnel".  2 - Expand example in 2nd bullet point of item #5 of page 2 (example along great circle track to include "and not near ice i.e. 50 miles of forecasted ice"). 3  -  Working group expressed concern that calling the two certifications, basic and advanced could lead to overwhelming levels of competency and training required at the advanced level. The working group recommends renaming basic as level 1 and advanced level 2. 4  -  Add following statement onto item 1 of "Mandatory minimum requirements for the training and qualifications of masters and deck officers on board ships operating in ice-covered polar waters" of page 4 (The carriage of an "ice pilot (s)" holding an advanced/level 2 certification is adequate when a vessel master does not hold the advanced/level 2 certification). The group also proposed the definition of ice pilot be provided. 5 - In section A-V/3, item #2, added the word Polar to the advanced level training to clarify not all ice covered waters required this training. 6  -  Table A-V/3-1, the working group recommends changing basic to level 1 in the title, also recommends deletion of all requirements for all simulator training (simulator use may be an option, but should not be required at this level). And the group recommends all highlighted KUP's that refer to operations in ice be moved to the advanced/level 2 table because this table is for operation in ice free waters. 7  -  Table A-V/3-2, the working group recommends changing advanced to level 2 in the title, also recommends deletion of all requirements for all simulator training due to lack of realistic ice software. (simulator use should be optional at this time as realistic duplication of ice navigation is at best questionable at this time) 8  -  Table A-V/3-2, the working group reworded nearly every KUP to make them specific and useable by a training institution, we however did not move any of the KUP's from the basic/level 1 table to the level 2 table pending approval on that recommendation. 9  -  The working group recommends that the Awareness level training should not exceed 2 hours (either onboard the vessel, via computer based training (CBT), or in an approved course). 10  -  The working group recommends that the Basic/Level1 training should not exceed 16 hours (via an approved course). 11 - The working group recommends that the Advanced/Level 2 training should not exceed 24 hours (via an approved course). 12 - The working group recommends that No additional training be required for engineers beyond the Awareness level. 13 - The working group recommends that the existing, experienced personnel with at least 4 months of Polar ice operations experience in an STCW Management level position be grandfathered into the Advanced/Level 2 certification, Basic/Level 1 certification and Awareness level training. No further grandfathering of vessel personnel is recommended. 14 - The working group recommends that the task remain open pending further IMO action on the STCW or Polar Code. Explanation/reasoning behind request to change basic and advanced terminology to level 1 and level 2 which are reflected in items 3, 6 & 7 above:  The intent was/is to ensure there was a clear understanding of the different requirements between the two.  Basic/level 1 is the training needed for operational level deck officers on vessels who transit waters defined in the Polar Code but DO NOT INTEND/CAN NOT SAFELY ENTER THE ICE. Basic/level 1 is the training needed for deck officers in charge of a navigational watch aboard vessels transiting waters defined in the Polar Code who WILL NOT OPERATE IN ICE COVERED WATERS. In addition, the training is required for operational level deck officers in Polar Waters who MAY OPERATE IN ICE COVERED WATERS. Advanced/level 2 is the training needed for Management level deck officers on vessels who transit waters defined in the Polar Code and MAY OPERATE IN ICE COVERED WATERS.

Closed

32-13 T/S 82 Task Statement 82 asked MERPAC to review Coast Guard Merchant Mariner Credential Application Forms. The Task Statement and forms, including MERPAC's recommendations, may be accessed at http://homeport.uscg.mil/merpac, in the minutes of the Meeting 39 folder, enclosures 8-13. Closed

33-13 T/S 83 Task Statement 83 asked MERPAC to review the STCW assessment guidelines for Chief Engineer (unlimited) and Officer in Charge of an Engineering Watch and determine alternate definitions of the Knowledge, Understanding, and Proficiencies; Methods for Demonstrating Competence; and Criteria for Demonstrating Competence for vessels less than 3,000 GT (ITC) with horsepower greater than 3,000 kW.

The assessment guidelines, including MERPAC's recommended changes, may be accessed at http://homeport.uscg.mil/merpac, in meeting the meeting 39 folder, in the attachment named "Recommendations."

Open

34-13 T/S 83 In addition to recommendation 33-13, MERPAC recommended that  these same tables be utilized for STCW endorsements as Chief Engineer (OSV) for vessels of not more than 6,000 GT (ITC) since it was determined that these vessels have similar equipment and levels of technology. Open

01-14 T/S 85

Task Statement 85 asked MERPAC to review and submit recommendations to the draft update of Chapters 20 through 26 of Volume III of the Marine Safety Manual (MSM).

MERPAC's recommendations, as well as the draft update of Chapters 20 through 26 of Volume III of the MSM, nay be accessed at http://homeport.uscg.mil/merpac, in meeting 39, in the attachment named "Recommendations." Closed

02-14 T/S 30 MERPAC recommends that, in accordance with Veterans Report 5-31-2012 of the Executive Office of the President, expand the text in the Coast Guard Authorization Act related to a veteran's opportunity to obtain a merchant mariner credential to all armed forces service by matching service qualifications with national and international standards (the current text only applies to the Coast Guard). Open

03-14 T/S 30 MERPAC recommends that the Coast Guard remove the 200 GRT requirement of a "designated examiner" for RFPNW assessment in NVIC 06-14 (RFPNW). Open

04-14 T/S 30 MERPAC recommends that the Coast Guard streamline the process of obtaining a TWIC for active duty service members by utilizing existing military identification. Closed

05-14 T/S 80 MERPAC recommends that Coast Guard policy letters 01-14 and 02-14, concerning vessels using LNG as fuel should encompass all gas fuels and not just LNG. The recommendation is that the policy letters mirror the HTW work product and include all fuels subject to the IGF code. Open

06-14 T/S 80 MERPAC recommends that, with regard to Coast Guard policy letters 01-14 and 02-14, care should be taken to assure that requirements for personnel on board vessels using gas fuels are differentiated from those for a full tankerman  -  LG endorsement as appropriate.  All references to the Parts of 46 CFR that are for tankermen should be eliminated. Closed

07-14 T/S 80 With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that the applicability of existing regulations, while useful as a reference point, is not necessarily germane to gas-fueled vessels as they have different operating characteristics, service, and training requirements.  Closed

08-14 T/S 80 With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that, with respect to operations, the policy letter should incorporate or adopt the language of the operational requirements of the draft IGF Code to the greatest extent possible. Open

09-14 T/S 80 With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that, with respect to training, the Coast Guard incorporate or adopt the language of the training requirements of HTW 1-WP.4-Rev1. the intent of this policy (interim or long standing), would dictate which annex of HTW 1-WP.4-Rev1 to include. MERPAC recommends that the fewer changes, the better, meaning Annex 4 should be incorporated as much as possible, with reference to the competencies listed in the tables as the requirements at basic and advanced levels. Closed

10-14 T/S 80 With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC recommends that the Coast Guard ensure that the transitional provisions are followed as an interim until the new HTW requirements are mandatory to allow for initial personnel training for the new technology.  closed

11-14 T/S 80 With regard to enclosure (1) of Coast Guard draft policy letter 01-14, MERPAC notes that many of its recommendations are to incorporate what will be part of STCW. There is a high likelihood that there will be smaller vessels (which may or may not have engineers) that will be using gas fuels. For these smaller operations, MERPAC recommends that companies should be given the flexibility to work with local OCMI's to develop procedures, policies and training that may be more appropriate to the scope of their operation than the fuller STCW requirements and which would achieve equivalent levels of safety (similar to allowances currently in 33 CFR 155.715). Closed

12-14 T/S 80 With regard to enclosure (2) of Coast Guard draft policy letter 01-14, MERPAC recommends that this enclosure be deleted in its entirety.  The MSC resolution will be superseded by HTW1-WP.4-Rev1. MERPAC recommends that HTW 1-WP.4-Rev1 be inserted as an enclosure to the policy letter if possible. Closed

13-14 T/S 80 MERPAC recommends that the Coast Guard work towards approving courses that meet the requirements of part A (Annex 4) of HTW 1-WP.4-Rev1 and look to begin issuing endorsements for the same as quickly as possible. With the expected growth of gas as a fuel in industry, this is going to be a pressing need sooner rather than later, and training providers and companies will need these approvals. Closed

14-14 T/S 81 MERPAC presented a red-line version of Annex 2 of the HTW 1/WP.4 document to the Coast Guard for consideration.

This document can be located at http://homeport.uscg.mil/merpac in the attachments to Meeting 40.

Closed

15-14 T/S 81 MERPAC recommends that consideration be given to require Polar Familiarization based on the risk assessment for all crew members. Closed

16-14 T/S 83 MERPAC presented to the Coast Guard a table to discuss various aspects of possible grandfathering.

Open

17-14 N/A MERPAC presented recommendations on the Coast Guard Authorization Act of 2015 and 2016: (H.R. 4005, Section 309c, CREDITING OF UNITED STATES ARMED FORCES SERVICE, TRAINING AND QUALIFICATIONS) This section requires the Secretary to maximize the extent to which armed forces service, training, and qualifications are creditable toward meeting merchant mariner licensing requirements and the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 (STCW Convention).   MERPAC supports this section and has been working on this issue for more than 12 years and will continue to work on the implementation of these programs. closed

18-14 N/A     (H.R. 4005, Section 319, MERCHANT MARINE PERSONNEL ADVISORY COMMITTEE) This section directs the Secretary to establish a Merchant Marine Personnel Advisory Committee to: (1) advise the Secretary on personnel matters relating to the U.S. merchant marine, including training, qualifications, certification, documentation, and fitness standards; and (2) comment on personnel regulations proposed by the Coast Guard. The section permits the Committee to conduct studies and make its recommendations available to Congress.  The section also requires the Committee to report to the Commandant regarding: (1) merchant mariner licensing, certification, and documentation programs; and (2) state maritime academy problems with implementation of amendments to the STCW Convention that entered into force on January 1, 2012.  The section also directs the Commandant to forward such report to Congress with recommendations for actions to implement the report's recommendations.   MERPAC does not support this section.  In the proposed rewrite of MERPAC's charter, several amendments were added that could change the makeup of the Committee and potentially render it less effective. As presently written, the development of a report on the comparison of the U.S. mariner credentialing program with that of other IMO member states creates the following issues:    a. Comparison should be made to 3 flag states that are comparable to the United States, such as Norway, United Kingdom, Australia, etc. which are involved in the administration of the training and credentialing of their merchant marine.  Flag administrations with the greatest tonnage generally do not have a training program for merchant mariners, but rely on the recognition of credentials from other administrations.    b. That being said, any expectation that we can compare the U.S. system with other countries is unrealistic even if we could compel other IMO member states to provide the information necessary for the comparison.    c. MERPAC members are volunteers with jobs and expertise in their individual fields. It is unrealistic to expect that a MERPAC member could participate in the completion of such a study. Considering that this task would require significant time, this would translate to more meetings and extensive travel as the members would need to travel to the selected countries in order to obtain the required information and, therefore, Congress would need to significantly increase the budget allocation for MERPAC. The time period to submit the report is totally unrealistic for many reasons including those stated above. open

19-14 T/S 80 The applicability of the IGF Code and training for vessels using fuels subject to the IGF code is for vessels greater than 500 gross tons (ITC). There are likely, however, to be vessels of less than 500 GT (ITC) that will be using such fuels in the future, and MERPAC recommends that personnel serving aboard such vessels should be subject to similar training requirements. open

20-14 T/S 80 MERPAC recommends that, on vessels that carry a licensed engineer, masters and engineers should have Coast Guard approved advanced training or Coast Guard accepted training (as defined in this paper).  Personnel with safety response duties should have Coast Guard approved basic training or Coast Guard accepted training. open

21-14 T/S 80 MERPAC recommends that, on vessels that do not carry a licensed engineer, masters and personnel with direct responsibility for bunkering and/or operation of gas fuel systems should have Coast Guard approved advanced training or Coast Guard accepted training as defined in this paper).  Personnel with safety response duties should have Coast Guard approved basic training or Coast Guard accepted training. open

22-14 T/S 80 The Coast Guard retains the authority to exempt the number and/or the training level for personnel, if there are other safety precautions in effect.  An operator may submit, as part of their safe manning proposal, an appropriate number of personnel carrying basic, advanced, or accepted training. This may include, but not be limited to, providing exemptions based upon the quantity of fuel carried, shore based availability of emergency response with route limitations, method of bunkering or other provisions that adequately allow for safe operations.  MERPAC recommends that the Coast Guard consider the ability of personnel to safely and comprehensively respond to emergency situations and the ability of the personnel on board to safely operate the equipment, keeping in mind specific hazards associated with IGF fuels. open

23-14 T/S 80 With regard to the HTW 1/21, Annex 7, Interim Guidance, MERPAC recommends that the U.S. implement paragraph <IP_ADDRESS> by requiring documentary evidence from the trainer/course provider. open

24-14 T/S 80 With regard to the HTW 1/21, Annex 7, Interim Guidance, MERPAC recommends that the Coast Guard accept training that is given by qualified personnel, such as, engine manufacturers or other vendors, as being acceptable under paragraph 1.1.5 for the appropriate training elements. open

25-14 T/S 80 STCW Regulation V/3.1.7 requires that masters, engineer officers and all personnel with immediate responsibility for the care and use of fuels and fuel systems on ships subject to the IGF Code shall have completed at least one month of approved seagoing service that includes a minimum of three bunkering operations on board ships subject to the IGF Code. Two of the three bunkering operations may be replaced by approved simulator training on bunkering operations.  MERPAC recommends that the Coast Guard develop grandfathering provisions for crews on vessels subject to the IGF Code.   open

26-14 T/S 30 Meeting 41 MERPAC recommends that the NMC website be made more  military-user friendly, i.e.  military to merchant mariner transition tab content such as;                a.      USCG Military File Evaluation Manual; and                b. Cross-walked endorsement competencies. Open

27-14 T/S 30 Mtg 41 MERPAC recommends that TGPS, TAPS, and other professional  development centers include merchant mariner credentialing  information. Open

28-14 T/S 30 Meeting 41 MERPAC recommends that the Coast Guard and NMC work together with MERPAC to identify and develop the crosswalks/gaps for military ratings/qualifications to civilian mariner credentials, i.e. MK to QMED, Officer of the Watch  or Bosun's Mate/deck rating  to Master Towing Vessels, etc. open

29-14 T/S 30 Mtg 41 MERPAC recommends that Navy and Coast Guard Offices of Cutter and Boat Forces submit their underway qualifications to the NMC for assessment. open

30-14 T/S 30 Mtg  41 MERPAC recommends that the Navy and Coast Guard offer funding for prospective deck and engineering officers to obtain a merchant mariner credential with appropriate endorsement. closed

31-14 T/S 30 Mtg 41 MERPAC recommends that the Coast Guard consider approving courses for tonnages above 200 GRT in lieu of examinations. closed

32-14 T/S 86 Mtg 41 For non self-propelled MOUs, MERPAC recommends removing the requirement for Able Seaman-MODU. This credential is currently not authorized under regulations. open

33-14 T/S 86 Mtg 41 While Basic Training as defined by A.1079(28) is appropriate for  those levels indicated in Table 1, MERPAC strongly recommends  that certification in the form of training certificates be considered adequate for proof of training and that non-mariners not be  required to receive credentials from the Coast Guard. To require credentialing would necessitate TWICs, which could be highly problematic for foreign crews.  Additionally, this would create a substantial additional burden upon the already stretched resources at the National Maritime Center. open

34-14 T/S 86 Mtg 41 In order to facilitate compliance with BSEE SEMS rules, MERPAC recommends that it should be the responsibility of the employer to ensure that their personnel are appropriately trained and qualified. As such, any requirement to verify training has been met should fall upon the employer and not the OSV/MOU crew members. Validation of this training should be done at the  leaseholder's dispatch location. open

35-14 T/S 81 Meeting 41 MERPAC recommends amendments to the tables of competence provided for review.  The annexes in this document include the recommended amendments.  The documents are  based on drafts from Norway (HTW 1/11/1), Argentina (HTW 1/11) and Canada (STW 44/13).   The group created two tables, which are attached as enclosure (6):          *    "Specification of minimum standard of competence in basic  training for ships operating in polar waters;" and           *    "Specification of minimum standard of competence in advanced training for ships navigating in polar waters."          *     The Tables of competence may be located at http://homeport.uscg.mil/merpac in the attachments to Meeting 41 minutes. Closed

36-14 T/S 81 Meeting 41 MERPAC recommends sea service requirements for mariners working onboard vessels operating within the polar regions; specifically:     *    Recommend a minimum 60 days of sea time serving in an         operational or management level deck position within either          Polar Region prior to certification of Advanced Polar Water         training; and     *    No sea time service should be required to qualify for a Basic         Level Polar certification. closed

37-14 T/S 81 Meeting 41 With regard to grandfathering for existing mariners, MERPAC   recommends for:      *       An advanced endorsement for Polar waters, a minimum of 180   days of deck officer service within the previous ten years in Polar waters, of which at least 90 of these days are in a management deck officer position.  No additional training should be required.      *    A basic endorsement for Polar waters, a minimum of 90 days of         service within the previous ten years in Polar waters in an         operational or managerial deck officer position.   No additional         training should be required. closed

38-14 T/S 81 Meeting 41 MERPAC recommends that the information in this report becomes the basis to the U.S. position to HTW 2. closed

39-14 No T/S Meeting 41 MERPAC recommends that the Coast Guard prepare a list of all exam questions which require the use of CFRs for MERPAC.

open

40-14 No T/S Meeting 41 MERPAC recommends that the NMC produce and publish module descriptions for every examination module for all grades of licenses.  This information should be posted on the NMC website no later than January 2, 2015.   open

01-15 Meeting 41 TS 87 MERPAC submitted one report and seven tables with recommended revisions to be made to Coast Guard NVICs.   These documents may be accessed at http://homeport.uscg.mil/merpac; then click on "meetings/minutes" and click on "Meeting 41A". Open

02-15 Mtg 42 TS 87 MERPAC submitted one report spanning 24 NVICs with 10 recommended revisions.  This can be found as Enclosure 7 to the meeting 41 minutes. Open, being reviewed by CVC-4

03-15 Mtg 42 TS 30 MERPAC recommends that the military develop business rules in their training programs that support the crosswalks for military to mariner transitions.  These crosswalks need to include on the job training, basic and advancement schools.  This could also have the effect of providing an added value to the recruitment process by providing incentive to potential candidates who may be considering a possible civilian maritime career. Open

04-15 Mtg 42 TS 30 MERPAC recommends that each military service define a process so that individual military members can get the information needed so that they can properly determine what experience and training transfers to a mariner credential endorsement. This information will identify any (gap) so that they can efficiently be processed through the NMC for the highest credential for which they are eligible.  Open

05-15 Mtg 42 TS 30 MERPAC recognizes that implementation of the Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281. and Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291 for Coast Guard personnel is divided among different USCG offices (CG-1, CG/7 and FORCECOM).  MERPAC recommends that the USCG identifies the single point of contact (from CG-1, CG-7 or FORCECOM) responsible for implementation of the legislation.  Furthermore, MERPAC recommends that the USCG briefs the full committee on their efforts and progress to fulfill the legislation requirements. Open

06-15 Mtg 42 TS 30 MERPAC recommends that the Chief of Naval Operations provide resources and support for the development and permanent maintenance of a crosswalk to develop a military to mariner process as defined in Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281 and Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291 Open

07-15 Mtg 42 TS 30 MERPAC recommends that each military branch develop an in-house team dedicated to developing credentialing processes, crosswalks and maintain communications with the USCG NMC.  This communications with NMC should include updates so that the NMC can serve as an information source for potential military to mariner candidates.  See Sec 305(a) of Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281 Open

08-15 Mtg 42 TS 30 MERPAC recommends an expeditious rulemaking, if necessary, to implement the Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281, Section 305(a) amendment to Section 7101 (j) of title 46, United States Code and Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291 by the end of FY 15-16.Furthermore, the USCG should amend the MSM to reflect the contents of same legislation. Open

09-15 Mtg 42 TS 30 MERPAC commends SOCP on their work to date on this subject and continues to value all industry input to this process.   Closed

10-15 Mtg 42 TS 30 MERPAC recommends that the Coast Guard publicize progress made in the military to mariner processes as it occurs.  This could include, but not be limited to, publication within commercial maritime industry publications, "Proceedings", online blogs, websites and internal publications. Open

11-15 Mtg 42 TS 30 MERPAC recommends that the Coast Guard regularly communicate with MARAD the developments of crosswalks and training programs to further develop the mariner pool and that this pool of mariners be considered in MARAD's development of a National Maritime Strategy.  Open

12-15 Mtg 42 TS 30 MERPAC recommends that in accordance with Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281, Sec 305, regarding maximizing creditability of military training, the NMC accept alternative assessment methods, including Coast Guard and Navy Performance Qualification System (PQS) and Army Duty Performance Tests (DPT), which substantially meet the requirements of the NVIC. Open

13-15 Mtg 42 TS 30 MERPAC recommends that the Coast Guard brief this committee on all recommendations that have been generated under Task Statement #30 and the subsequent outcomes. Open

14-15 Mtg 42 TS 30 The working group also recommends that the full committee amend Task Statement 30 as follows in order to reflect the Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, PL 113-291 and Howard Coble Coast Guard and Maritime Transportation Act of 2014, PL 113-281: Open

15-15 Mtg 42 TS 88 MERPAC submitted ten tables with recommended revisions.  These can be found as Enclosures 1a and 1b to the minutes. Open

16-15 Mtg 43 No TS MERPAC recommends that the Coast Guard go to TSA and request a modification to the TWIC requirement that allows flexibility for those who have applied for a renewal to be able to sail foreign for up to 90 days or first U.S. Port after the 37 day extension. This would allow those who may be joining a vessel for which they may be underway for an extended length of time without access to receive a TWIC to continue working in the event of a delay in issuance.  Open

17-15 Mtg 43 No TS MERPAC also recommends that communications and meeting minutes from the TWIC Stakeholders Communication Committee (TSCC) are provided to MERPAC so we may know of possible issues or concerns in advance.  Open

18-15 Mtg 43 No TS MERPAC recommends that the NMC review their procedures to allow for visual verification by the evaluator to be adequate proof of authorization by the mariner that the third party can discuss their evaluation.  Open

19-15 Mtg 43 No TS .MERPAC recommends that the NMC review their procedures to allow for evaluators to contact sea service letter authors, who provide contact information, directly in efforts to clarify the sea service information provided. MERPAC believes this direct line of communication will expedite the receipt of AI requests, reduce the need for future AI requests and facilitate more efficient credentialing. Open

20-15 Mtg 43 TS 30 MERPAC recommends that necessary policy for PL 113-281  be developed for implementation of the statute while the rulemaking process goes forward.

Open

21-15 Mtg 43 TS 30 MERPAC recommends that PL 113-281 Sec 305(a) be implemented immediately.

Open

22-15 Mtg 43 TS 30 MERPAC recommends that USCG CG-7, CG-1 and ForceCom be invited to MERPAC meetings for continuity of the USCG Military to Mariner effort.

Open

23-15 Mtg 43 TS 30 MERPAC recommends that Navy SWOS, NETC, U.S. Navy CNO(N42) and other programs be invited to MERPAC meetings for continuity of the Navy Military to Mariner effort. Open

24-15 Mtg 43 TS 30 MERPAC recommends that, if invited, the USCG participate in the military to mariner panel that is anticipated to be formed at the January 2016 Surface Navy Association Symposium. Open

25-15 Mtg 43 TS 30 MERPAC recommends the Coast Guard collaborate with MARAD and DOL to correct the O*NET titles and produce an accurate number of active merchant mariners.  This affects the demand signal for the federal government and affects the disbursement of financial support for military to mariner training. Open

26-15 Mtg 43 TS 30 MERPAC recommends that the National Maritime Center track first time applications for Merchant Mariner Credentials from military applicants, retired or otherwise.  This is to establish a database to determine the effectiveness of MERPAC task Statement #30 and in anticipation of a request from the Federal Military to Mariner round table of CMTS. Open

27-15 Mtg 43 TS 30 MERPAC recommends that each service institute permanent assigned billet(s) to ensure the continuous maintenance of crosswalks and course approvals.  Also,  each service should maintain a permanently assigned billet(s) as a Mariner Credentialing Specialist and Mariner Career Counselor.  This should be a mixture of civilian and military personnel so that the continuity of experience and processes can be maintained.  (Fort Eustis Model). Open

28-15 Mtg 43 TS 30 MERPAC recommends that the military services authorize tuition assistance payments for credentialing courses that are not accredited  by the American Council on Education (ACE) Open

29-15 Mtg 43 TS 30 MERPAC commends SWOS for participating and offers its assistance with the development of crosswalks. They also thank the Radio Technical Commission for Maritime Services RTCM for their support of the August Working Group. Closed

30-15 Mtg 43 TS 30 MERPAC recommends that all of the services meet regularly and represent their constituency in order to develop a common framework of crosswalk assessment tools for National Maritime Center submissions. Open

31-15 Mtg 43 TS 30 MERPAC recommends holding an added intercessional at Yorktown, VA or Fort Eustis, VA to facilitate discussions on the development of deck crosswalks for the impacted services. Open

32-15 Mtg 43 TS 30 MERPAC recommends that the working group revisions to MSM Volume III, Chapter 2 and Table in Figure 2-1 be considered for the latest revision of MSM Volume III and be returned , with comments  at the recommended MERPAC intercessional  in (l) above. Open

33-15 Mtg 43 TS 30 MERPAC recommends that the MSM Volume III, Chapter 2 be considered for STCW equivalence and determine acceptable military assessment protocols.  Open

34-15 Mtg 43 TS 58 Industry would also like to thank you for the new DE verification tool on the NMC website. We would request that it be corrected to ask for the license number as this is what is listed on the TOAR and is the only number that companies can currently use to verify the validity of the DE and therefore the mariners completed TOAR. There is not a separate DE ID number issued at this time and if there was it is not the same language as the TOAR uses. Open

35-15 Mtg 43 TS 58 It was shared that one long standing process for vetting questions is through the protest process during an exam. We know that if this protest question can be the difference between passing or failing, it is addressed immediately, however we are interested in what the process is if it does not impact passing or failing for that specific mariner since it may still be a problematic question. If not already done, can there be a process where the RECs send ALL protests to NMC exam team for review and revision of question if warranted? Open

36-15 Mtg 43 TS 58 Lead instructors actively teaching an approved course should be credited at least equally to a student for purposes of renewal/revalidation. Open

37-15 Mtg 43 TS 58 With respect to AI letters due to clarification of sea service (i.e. job title, missing info, format of letter, time in department, etc.) and where there is contact information for the author of the letter, the NMC should develop a standard process wherein they contact the author of the letter directly. This would accomplish two things:

		a.	It would clear the inventory backlog of AI items faster as the current process requires contact of the mariner directly, and the mariner then contacts the author for assistance and it would also

		b.	Prevent future issues from the same author for other mariners they are writing letters for as they could revise their template to better suit and more closely align with the needs of the NMC. Open

38-15 Mtg 43 TS 58 The NMC evaluation process needs to include a feedback mechanism for AI that affirms or rejects when the clarifying or additional information provided by the applicant was adequate.

		a.	It was brought to my attention that if a mariner submits the requested AI information, thinking they satisfied the request, but it was inadequate, the evaluator does not send another AI letter as they assume the applicant is sending more information. Rather the mariner needs to contact the NMC when they don't hear anything to inquire as to whether or not what they sent was sufficient.

		b.	Make nmc evaluator training available either digitally or in person for maritime educators when procedural or form changes occur that would impact their candidates. This would help us help you and alleviate the AI burden to mariners and the nmc. Open

39-15 Mtg 43 TS 58 I would like to thank the NMC team for their continued efforts to redraw and publish the engineering illustrations and ask that this be done as quickly as possible to assist mariners in properly studying for their respective examinations. Having an ETA for completion would be very helpful. Some of the diagrams refer to very old manuals that in some cases are out of print and unavailable to the mariner for the purposes of study (such as MO-20, and MO-45 for example which are out of a manual from 1954). Is there a way to use more updated manuals that mariners have greater access to for study purposes? This actually highlights why the publishing of the questions and answers is critical for the mariners' ability to properly prepare for his/her examination. Open

40-15 Mtg 43 TS 58 It has come to our attention that the Coast Guard Authorization Act of 2015, will make the USCG exempt from FOIA requests relating to any merchant mariner examination question, etc. Can you tell us how this happened and why it MERPAC would not be tasked with this before such a controversial piece of legislation would be drafted and put forward? This could be very damaging to the mariner credentialing process and yet it seems to have been done without any public or industry feedback. Why?

	a.	Questions need to be vetted and with over 25% of the 700 reference pubs out of date it would be impossible for a mariner to prepare for exams without the publication and exchange of information relating to the exams.

	b.	When compared to other commercial license exams the merchant mariners carry a much heavier burden.

	c.	Please help us understand the intended outcome.

	d.	Recommendation that merpac discuss this legislation and render an opinion as to our position on the matter for the record. Open

41-15 Mtg 43 TS 58 Military to mariner website access would be better on the homepage and must be updated to reflect present legislation. Closed

42-15 Mtg 43 TS 87 MERPAC would like a report from the USCG on the status of our previous comments and recommendations. Open

43-15 Mtg 43 TS 87 MERPAC recommends for immediate action that the USCG give credit to the principal approved instructors of Coast Guard approved courses with full course credit equal to the students taking the course.        Open

44-15 Mtg 43 TS 87 MERPAC recommends that the USCG provide clarification and guidance as to how instructor and closely related service will apply towards renewal requirements for national and STCW endorsements pre- and post- December 31, 2016. Open

45-15 Mtg 43 TS 87 MERPAC also recommends that the USCG provide  a sample letter or language that training and educational institutions can use to document an instructor's service. Open

46-15 Mtg 43 TS 87 MERPAC recommends that the USCG update NVIC 3-14 to accurately reflect the correct language that should appear on certificates.  MERPAC also recommends a harmonization of course numbers, content, course approval and certificate language and that information provided in NVIC 3-14. Open

47-15 Mtg 43 TS 87 MERPAC recommends that certificates for specific STCW courses (specified by name in NVIC) need not include the specific tasks listed, other than the course name and CFR reference, where appropriate. Open

48-15 Mtg 43 TS 87 MERPAC recommends a global check for similar inconsistencies in wording. Open

49-15 Mtg 43 TS 87 MERPAC recommends, as above, a global check for similar inconsistencies in wording. Open

50-15 Mtg 43 TS 87 MERPAC accept the recommended changes to the following Modules          o Guidelines on Fatigue          o Shipboard Fatigue and the Owner/Operator/Manager          o Fatigue and the Seafarer

Open

51-15 Mtg 43 TS 87 MERPAC recommends forwarding to Australia Open

52-15 Mtg 43 TS 87 That an intersessional be scheduled to review draft changes from Australia of modules	          o Guidelines on Fatigue          o Shipboard Fatigue and the Owner/Operator/Manager          o Fatigue and Ship Design Closed

53-15 Mtg 43 TS 91 The choice to have harmonized credentials should be non-mandatory as an "opt-in" choice for the mariner.  Open

54-15 Mtg 43 TS 91 For those who do opt-in, they may experience a one-time shortening of their medical certificate or MMC. These consequences should be explained to the mariner if they elect to do so and it will result in a shortening of one credential. Open

55-15 Mtg 43 TS 91 Medical certificates should have an issue date at any time up to the valid term of the physical exam, i.e. if a physical is taken 1/1/2014 the issue date can be any date 12/31/2014 or sooner. This should be considered for both national and STCW medical certificates. This recommendation should not apply to those with medical issues. Open

56-15 MTG 43 TS 91 The CG should take for action a review of whether requiring training for RADAR renewal every five years makes sense or if underway service on a vessel equipped with RADAR should be considered adequate experience for renewal. This should be reviewed for both national and international credentials. The original requirement appears to be linked to STCW 1978 requirements for refresher training which no longer exists. Open

57-15 MTG 43 TS 91 If mandatory training is deemed appropriate, there are a lot of considerations for harmonization of the RADAR to the credential to consider. These include:          a. If harmonized, what happens when a mariner raises grade and wants a full five year certificate (which includes a new physical)  -  would they need to retake radar?          b. Is there truly a need to print radar observer on the credential? Most would prefer to keep it there, but if it helps harmonization it may be worth consideration to just stop printing. Open

58-15 MTG 43 TS 91 There are about 95k mariners who have a medical certificate without STCW. Mass harmonization may result in serious NPT increases at the NMC. If harmonization is allowed, an implementation strategy should be developed to try and mitigate this risk. Open

59-16 MTG 43b TS 87 MERPAC recommends that these modules be forwarded to Australia in order to provide initial input into their paper on this subject.  Open

60-15 MTG 43b TS 87 MERPAC recommends that the U.S. submit the MERPAC approved Module 2 to HTW as a separate paper and include the following points for HTW to consider regarding the revision of MSC 1014.    * A FRMS is not the only option for Companies to address fatigue in a risk based manner, as illustrated in our version of module 2.    * A FRMS would be difficult to implement for many operators    * Must avoid any additional administrative burdens for the seafarer and the company(e.g. formal FRMS)    * Must avoid any additional PSC burden on seafarers    * Must protect the privacy of seafarers    * Guidance should be written for intended audience (not technical experts, but written at the reading level of general seafarers, KISS keep it short and simple, etc.)    * Avoid confrontational tones and language in writing (e.g. insidious)    * Reference all referred to research as per IMO guidelines    * Measures should be scalable to all modes of maritime transportation.     * If HTW accepts the US version of module 2 then module 3(seafarer) must be amended to delete the seafarer's obligations under the FRMS

61-15 MTG 43b TS 87 The USCG should ensure whenever the  topic or discussion of fatigue comes up at IMO they should support and ensure proper reference and comment is made that" vessels should at all time be appropriately manned in order to encompass all aspects of maintaining safe operations on board (in accordance with the Principles of minimum safe manning, adopted by the Organization by resolution A.1047(27)).