1. Mariner Credentialing Program Policy Division CG-5434
Mr. Luke Harden

2. Mariner Credentialing Program
Issue credentials to qualified mariners
Approximately 210,000 mariners in U.S.
Credentials issued to:
Officers
Ratings
Credentials endorsed based upon qualifications
Officer endorsements
Rating endorsements
STCW endorsements (International requirements)

3. Mariner Credentialing Program Policy Division
Division Chief GS-15
(Mr. Luke Harden)
Medical Officer (Occupational Medicine)
GS-14 Dr. Adrienne Buggs
Marine Personnel Spec
LCDR/O4
(LT Corydon Heard)
Marine Transportation Spec
GS-13
Vacant
LT/O3
(LT Dylan McCall)
GS-14
(Mr. James Cavo)
Attorney Advisor
(Mr. David Van Nevel)
Office of Maritime and International Law CG-0941

4. Principle Functions of CG-5434
Develop program policy and standards
Interpret mariner qualification standards
Prepare final action on appeals
STCW oversight
Provide program performance oversight
Public outreach
Administer Merchant Mariner Medical Advisory Committee
CG-01 memo 5400 dtd 20 APR 2007.

5. How a Mariner Goes Through Appeal Process
The Appeal Process is fairly simple.
Denial letter will explain reasons and next step in appeal process.
Mariner writes directly to CG and states clearly why she/he thinks our decision was incorrect.
Title 46, Code of Federal Regulations.
Sections ; and
Next

6. Denial of Application to Appeal Sequential Order
Awaiting Information Letter
Request for Reconsideration
Denial of Request for Reconsideration Letter
Appeal
Appeal Package to 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 NMC forwards the appeal and application package to Coast Guard Headquarters in Washington D.C..
Final Agency Action- Director of Prevention Policy decision
NMC

7. Types of Appeals Medical Safety & suitability (Criminal convictions)
Professional
Course/instructor approvals

8. Appeal Process CG-54 Final Agency Action CG-543 Clearance
Medical/Marine Transportation Specialist Review/Drafting
Subject Matter Expert Review
CG-0941 Legal Review
CG-5434 Division Chief Approval
CG-543 Clearance
CG-54 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 NMC forwards the appeal and application package to Coast Guard Headquarters in Washington D.C..
Final Agency Action- Director of Prevention Policy decision
Notification/MMLD/Administrative Processing

9. 2011 Month to Month & Yearly Amount Received
On Hand- Beginning of Month
Received
Completed
On Hand- End of Month
Jan-11 37 9 10 36
Feb-11 4 6 34
Mar-11 19 21
Apr-11 8 5 24
May-11 17 33
Jun-11 35 59
Jul-11 29 3 85
Aug-11 66
134
Sep-11 28
156
Oct-11 22 30
148
Nov-11 14
139
Dec-11 1
143
Appeals Received at HQ
2008 29
2009 62
2010
138
2011
234
As you can see from the yearly statistics, the amount of appeals have grown exponentially year by year.

10. Pending Appeals Breakdown
Branch
Number of Open Appeals
% by Issue
Safety & Suitability 4 3%
Medical
112
78%
Professional 26
18%
Other Issue 1 1%
Total
143
*Average age of pending appeals -120 days old as of December 7

11. Outcome/Number of Appeals Completed Broken Down By Years
ALL Appeals
Granted
Partially Granted
Denied
Other Outcome
Total
2008 6 10 1 23
2009 24 7 28 60
2010 34 51 4
113
2011 59 11 57
128
TOTAL
123 48
146
324
Total % out of 324
38%
15%
45% 2% 95
This statistics shows a breakdown of how many medical appeals were granted, partially granted, or denied during that year. Granting or partially granting an appeal means the Director of Prevention Policy overturned the NMC’s decision to deny the mariner.
- Many of the appeals granted in 2011 are because the mariner gathered the information previously requested by the NMC and it showed the mariner could be given a waiver or they were considered fully medically fit.

12. Since all appeals require almost the same amount of research time, we focus more on getting older appeals. Appeals that are older than 90 days normally are from additional information being requested. As a courtesy to the mariner, some appeals that have the potential of being granted are held onto much longer than our targeted complete date so the mariner can retrieve what is required/needed in order for the appeal to be granted. Otherwise, all denial decisions require a new application to be submitted if the issue would eventually be resolved. 19

13. The Merchant Mariner Medical Advisory Committee (MMMAC)
The hopeful solution in developing better standards

14. The Merchant Mariner Medical Advisory Committee (MMMAC)
Previously established in May 2009 as a discretionary committee
Members were solicited over the summer 2009, received 41 applications
The selection & appointment of the members to MMMAC were on hold while DHS was undergoing a review of all their currently established advisory committees
A quick history and timeline about the establishment of the Merchant Mariner Medical Advisory Committee (MMMAC)

15. The Merchant Mariner Medical Advisory Committee (MMMAC)
October 2010 CG Authorization Act of 2010 established MMMAC as a statutory committee
Dec 2, 2010 MMMAC charter as a statutory committee was approved by DHS
August 8, 2011 the Secretary selected and appointed the members to MMMAC
September 19-21, 2011 the inaugural meeting was held at the Calhoon MEBA School in Easton, MD

16. Purpose of MMMAC
MMMAC shall advise the Secretary/Coast Guard on matters related to: (A) medical certification determinations for issuance of licenses, certificates of registry, and merchant mariner documents; (B) medical standards and guidelines for the physical qualifications of operators of commercial vessels; (C) medical examiner education; and (D) medical research.

17. MMMAC Member Composition
14 members total
10 health-care professionals with particular expertise, knowledge, or experience regarding the medical examinations of merchant mariners or occupational medicine
4 professional mariners with knowledge and experience in mariners’ occupational requirements
Members serve five year terms
Except for three members (one professional mariner and two medical professionals) appointed for a term of two years.

18. Inaugural Meeting of MMMAC
The Coast Guard presented 6 Task Statements for the Committee to work on:
NVIC REVISION
TOP MEDICAL CONDITIONS
REVIEW OF PART 10 SUBPART C SNPRM
REVISING 719K MEDICAL EVALUATION FORM
CREATING MEDICAL EXPERT PANELS
DESIGNATED MEDICAL EXAMINER PROGRAM
1) NVIC REVISION
-Determine appropriate testing to assess the condition (if applicable)
-Determine the minimum compliance for the condition that should allow the mariner to safely operate under a credential
-Determine the parameters for which a waiver should be set (if the medical condition can be waived). This will allow limited credentialing for some mariners with conditions previously deemed disqualifying.
2) Top Medical Conditions
Review and discuss the most common medical conditions leading to denial of merchant mariner medical credentialing. Prepare recommendation(s) for the full Committee to present to the Coast Guard a list of proposed changes to the current NVIC to improve transparency in medical decision-making until full NVIC revisions can be made.
3) Review of Part 10 Subpart C SNPRM
Review Part 10 Subpart C of the STCW SNPRM and provide comments/recommendations to the Coast Guard regarding the proposed regulations on medical certification of mariners by the conclusion of this inaugural meeting.
4) Revising 719K Medical Evaluation Form
Evaluate and prepare recommendation(s) for the full Committee to present to the Coast Guard propose corrections and improvements to current 719K Medical Evaluation Report Form.
5) Creating Medical Expert Panels
-Evaluate and prepare recommendation(s) for the most common medical conditions leading to denial of merchant mariner medical credentialing and develop a list of topics and/or conditions to be addressed by MEP’s. Prioritize list for order of completion.
- Evaluate and prepare recommendation(s) for outline for creating MEP’s, reporting requirements, and MMMAC’s procedures for considering MEP results.
6) Designated Medical Examiner Program
Evaluate and prepare recommendation(s) for the full Committee to present to the Coast Guard program outline with implementation ideas for DME Program. Outline to include suggestions for training, certification/recertification, and duration of certification.

19. Getting Information about MMMAC
Detailed recommendations, member names and POC information, minutes of meetings can be found on Coast Guard’s HOMEPORT website:
Missions => Ports and Waterways => Safety Advisory Committees => MMMAC
Or contact Assistant Designated Federal Officer LT Dylan McCall
Phone:

20. NVIC Revisions

21. Questions
If you have specific questions regarding mariner credentialing policy, please contact: Luke Harden Chief, Mariner Credentialing Program Policy Office of Vessel Activities (CG-5434) Phone: (202) / Fax: (202) nd St, SW Stop 7581 Washington, DC