Mariner Credentialing Program Policy Division CG-CVC-4 Mr. Luke Harden MERPAC March 2015

Current MCP Initiatives/Projects Merchant Mariner Medical Advisory Committee (MEDMAC) Implementing Section 809 of the Coast Guard Authorization Act of 2010 – TWIC Implementation of the STCW Final Rule STCW Policy Advisory Committee 26 STCW Final Rule NVICs Appeals

MEDMAC Committee’s current/proposed tasks: Revision of NVIC 04-08, Medical and Physical Guidelines for Merchant Mariner Credentials; Evaluation of merchant mariners with impaired color vision Conduct of general medical exam Return to service following a positive chemical test Health risk analysis (joint task with MERPAC) Last meeting: March 16-17, 2015 Next meeting: Fall 2015 MEDMAC has made recommendations to the Coast Guard on the revision to NVIC 04-08 however the task is not officially closed. The task will be closed once the NVIC goes out for public comment and re-circulates thru the Committee.

Section 809 of the 2010 USCG Authorization Act – TWIC Evaluate the implementation of changes to the TWIC requirements as mandated by the Coast Guard Authorization Act of 2010, Section 809

STCW Final Rule NVIC Publication: 24 NVICs have been published: Medical Certificates Grandfathering Course Approval Proficiency in Survival Craft/Rescue Boats Proficiency in Fast Rescue Boats RFPNW RFNEW Basic Training Advanced Firefighting We plan to publish 28 NVICs to implement the final rule. Each NVIC will provide a process to provide comments or submit questions regarding the NVIC. Once signed by the Coast Guard, these NVICs will be made available for use on the NMC website. Once placed on the website it will be announced through the NMC listserv.

STCW Final Rule Master/Chief Mate 3,000 GT or More Master/Chief Mate 500 GT to 3,000 GT OICNW Master/OICNW Less Than 500 GT Near Coastal Able Seafarer-Deck Chief Engineer/Second Engineer Officer 4,000 HP or More Chief Engineer/Second Engineer Officer 1,000 to 4,000 HP OICEW Able Seafarer-Engine Qualified Assessor 28 NVICs to implement the final rule. Each NVIC will provide a process to provide comments or submit questions regarding the NVIC. Once signed by the Coast Guard, these NVICs will be made available for use on the NMC website. Once placed on the website it will be announced through the NMC listserv.

STCW Final Rule High-Speed Craft Type-Rating Endorsements Vessel Security: VSO, VPDSD, SA Endorsements for Oil, Chemical, and Liquefied Gas Tank Vessels Endorsements as Electro-Technical Officer (750kW/1,000 HP or more) Endorsements as Electro-Technical Rating (750kW/1,000 HP or more) 28 NVICs to implement the final rule. Each NVIC will provide a process to provide comments or submit questions regarding the NVIC. Once signed by the Coast Guard, these NVICs will be made available for use on the NMC website. Once placed on the website it will be announced through the NMC listserv.

STCW Final Rule NVIC Publication: NVICs under development: 4 NVICs to address Offshore Supply Vessel Endorsements Revision/Rewrite of Medical Evaluation Guidelines Guidelines for Credentialing Officers of Towing Vessels NVIC Currently under development Crediting Sea Service Aboard Liftboats Policy Letter Drafted and waiting publication We plan to publish 28 NVICs to implement the final rule. Each NVIC will provide a process to provide comments or submit questions regarding the NVIC. Once signed by the Coast Guard, these NVICs will be made available for use on the NMC website. Once placed on the website it will be announced through the NMC listserve.

STCW Final Rule Questions/Feedback: Questions specific to the final rule: submit to STCWASK@uscg.mil Feedback on the NVICs: submit to MMCPolicy@uscg.mil Questions on individual applications will be forwarded to the NMC for further action Answers to STCW related questions will be posted on the NMCs FAQ section of their web page As we receive questions to STCWASK we (STCW PAC) will provide answers on the NMC website to the questions. A Frequently Asked Questions section has been developed. Comments on the NVICs will be considered when we consider revisions and/or changes to that NVIC.

STCW Final Rule STCW Final Rule FAQ Categories: General Questions- 31 Grandfathering, Transition, Effective Dates- 18 Medical Certificates- 41 Safety and Security Evaluations- 1 General Sea Service- 10 Course Approval, Course Completion Certificates- 11 Examinations- 7 Use of Non-U.S. Personnel- 2 Recognition of Foreign Certificates- 2 Security Endorsements- 21 Recently there has been a drastic drop in the number of questions received related to the STCW final rule implementation. These have been the most frequently asked about topics with the # of questions/comments responded to by the CG since the publication of the Final Rule. The responses to the questions can be found on the NMCs website. If you have specific questions please submit via the methods I just discussed. TOP 3 HIGHLIGHTED IN RED.

STCW Final Rule STCW Final Rule FAQs Categories: STCW-Rating-Engine- 4 Tankerman Endorsements- 6 QMED Endorsements- 1 OSV Endorsements- 7 Towing Endorsements- 4 Basic Training- 17 National-Officer-Deck- 11 National-Officer-Engine- 3 National-Rating-Deck- 2 STCW-Officer-Deck- 17 STCW-Officer-Engine- 5 STCW-Rating-Deck- 6 STCW-Rating-Engine- 4 These have been the most frequently asked about topics with the # of questions/comments responded to by the CG since the publication of the Final Rule. The responses to the questions can be found on the NMCs website. If you have specific questions please submit via the methods I just discussed.

Appeal Process Appeal Package to CGHQ Applicant Final Agency Action Awaiting Information Letter Request for Reconsideration Denial of Request for Reconsideration Letter Appeal Appeal Package to CGHQ CGHQ Applicant Final Agency Action AI Letter- Letter sent by the NMC to the applicant describing the error found in the application and the correct information required to continue the application. Request for Reconsideration- Applicant believes there is no error in the application. The application is forwarded to a specialist which issue gets re-evaluated. Denial of Request for Reconsideration Letter- Letter sent by the NMC to the applicant which describes more in-depth the error found in the initial application and any additional info submitted in the request for reconsideration. This letter from the NMC states that the applicant has a right to an appeal. Appeal- Mariner appeals the NMC decision and appeal and application package mailed to Coast Guard Headquarters in Washington D.C.. Final Agency Action- Director of Inspections and Compliance NMC

Annual Appeal Trends

Safety & Suitability Appeals The 2015 data is a projection if the SSE appeals increase at the same rate.

This bar graph represents the last 18 months. For example, in the last 18 months, approximately 65% of medical appeals have been denied.

Appeal Processing Numbers & Processing Time at HQ (Last 3 Months)   On Hand- Beginning of Month Received Response Drafted (In Route) Completed On Hand- End of Month Jan-15 41 16 12 57 Feb-15 8 5 60 Mar-15 4 56 Number of Credential Extensions Issued Pending Appeal Decision Number of Appeals in Routing to CG-CVC/CG-5PC 6 Average Age of Open Appeals 96 as of March 10, 2015 Average Age of All Open Appeals: For example, the average age of open appeals in February of 2015 was approximately 100 days.

Questions?