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Implementation of STCW Regulations
STCW – Final Rule General Requirements Implementation of STCW Regulations
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STCW – Final Rule Part 10 46 CFR is still the definitions section. Pay particular attention to a definition of a DAY in regards to MODU’s. “When computing service on MODU’s for any endorsement, a day of MODU service must be a minimum of 4 hours, and no additonal credit is received for periods served over 8 hours.” NO 1.5 Credit for MODU - even for dynamic positioning (The Boothe Letter – now superseded by new regs) (further clarified in (2)(3)) – Service on MODU’s maintaining station by means of dynamic positioning, may be credited as service on conventional vessels for any raise in grade; however, time more than 8 hours each day will not be credited. A day of creditable MODU service must be a minimum of 4 hours, and no additional credit wil be granted for periods of more than 8 hours. (also see (h)(4)) 2
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STCW – Final Rule Part 10 Definition for Near Coastal …This would also include those near coastal waters identified by another Administration when the U.S. has entered into a treaty or an Agreement with that country respecting the recognition of the U.S. near coastal endorsement. Treaty with Canda - Inside Passage (Alaska) credited as Near Coastal waters - (further clarified in (b)(3)) – For establishing credit for sea service, the waters of the Inside Passage between Puget Sound and Cape Spencer, Alaska will be credited for a near-coastal and STCW endorsement. Doesn’t just pertain to Alaska Marine Highways or Washington State Ferries - all vessels in these waters. This does not change these waters to Near Coastal Waters – only allows these waters to be credited as Near Coastal. If mariner holds Inland MMC and has service on these waters , it is not considered outside the scope of license. 3
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STCW – Final Rule Part 10 Renewal Requirements 10.227
Closely Related Service (e) (iv) (v) Added an option to renew under closely related service - qualified instructor Taught a Coast Guard approved or accepted course relevant to the endorsement or credential being applied for, at least twice within the past 5 years. The letter from the school must state that the mariner has taught (name course(s)) and that the mariner has taught the course(s) at least twice within the past 5 years. RENEWAL SEA SERVICE REQUIREMENTS *A credential may be renewed at any time during its validity and for 1 year after expiration. 46 CFR # of Days Eval INT MMC w/Officer endorsements 360 days of service during the past 5 years, OR Pass a comprehensive, open-book exercise, OR Complete an approved refresher training course, OR Provide evidence of employment as a qualified instructor or in a position closely related to the operation, construction, or repair of vessels (either deck or engineer as appropriate) for at least 3 yrs during the past 5 years, a) Deck must pass ROR; b) Engineers (*See Note 2 below) OR Provide evidence of being a qualified instructor who has taught a Coast Guard – approved course relevant to the endorsement or credential being applied for at least twice within the past 5 years, therefore meeting the standards needed to receive a course completion certificate for that course. / 4
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(no changes at this time for STCW)
STCW – Final Rule Part 10 Re-instatement – Re-issuance of expired credentials (i): If a MMC is expired beyond the 1 year grace period, the mariner must meet ALL original requirements. This has always been in the regulations, but we did not enforce. We asked that this be deleted from the new regs and HQ states that the regulations did not excuse meeting other requirements required for original (see also (10.225(a)(2)) . Testing/course approval 1st Aid/CPR, Firefighting Recency (We would not need to evaluate for original sea service requirements as the credential held will be evidence in accordance with (a)(3). Any other determination of holding a MMC as evidence of meeting sea service requirements will be determined one a case by case basis and should be brought forward to your Section Chief.) (no changes at this time for STCW) Reinstatement of Towing and Tankerman is on the next slide… 5
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STCW – Final Rule Part 10 Re-instatement – Re-issuance of expired credentials (i): Master of Towing or Mate (Pilot) of Towing 10.227(i)(3) - Applicants applying for re-issuance of an endorsement as master or mate (pilot) of towing vessels more than 12 months after expiration of the previous endorsement must complete the practical demonstration of maneuvering and handling of a towing vessel under (e)(6)(i) of this section. (e)(6)(i) states during the validity of the license or MMC being renewed. Mariner will need to provide a current TOAR for maneuvering and handling to the satisfaction of a designated examiner. This is the same procedure that we have done in the past. Tankerman Whenever an applicant applies for reissuance of an endorsement as any tankerman rating more than 12 months after expiration of the previous endorsement, the applicant must meet the requirements for an original endorsement. All Tankerman expired beyond the grace period will have to meet original requirements including recency and valid course if applicable. 6
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STCW – Final Rule Part 10 Sea Service 10.232:
Sea service requirements/guidelines are all in one section . Direction on how Great Lakes and Inland waters can be credited Change in calculation of Military Sea Service Section for Vessels that do not get underway Section for Closely Related Service Section on crediting time and half Section for Tonnage Equivalency 7
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STCW Final Rule Part 10 10.232(b) – Service toward an oceans, near-coastal, or STCW endorsement will be credited as follows: Service on the Great Lakes will be credited on a day-for-day basis up to 100% of the required service. When crediting service for Near Coastal/Ocean sea service requirement, Great Lakes service is counted at day-for-day at 100% for both National and STCW endorsements. The Final Rule contradicts this when giving individual requirements for the specific credential. Checklists will reflect crediting Great Lakes day-for-day up to 100%. § Requirements for master of near-coastal self-propelled vessels of less than 200 GRT. (a) The minimum service required to qualify for a master of near-coastal self-propelled vessels of less than 200 GRT is-- (1) Two years total service on ocean or near-coastal waters. Service on Great Lakes and inland waters may substitute for up to 1 year of the required service. 8
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STCW – Final Rule Part 10 (d) – Sea service as a member of the Armed Forces of the United States and civilian service on vessels owned by the United States as required service: For calculation of sea service we are going back to using 60% of the total time onboard (vs. 70%). The new regs state in (d)(4) that in addition to service on vessels that get underway regularly, members may obtain creditable service for assignment to vessels that get underway infrequently, such as tenders and repair ships. Normally a 25% factor is applied. (Mariners with sea service on or before March 24, 2014 will be calculated under the old Regs.) (a)(3)- An MMC endorsement, in certain cases, may be considered as satisfactory evidence of any qualifying experience for obtaining other endorsements. (This is credited on a case by case basis at NMC) Previously “in addition to underway service, members of the Armed Forces may obtain creditable service for periods of assignment to vessels at times other than underway, such as in port, at anchor, or in training. 9
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STCW – Final Rule Part 10 (e) – Sea Service for vessels that do not get underway (COI mandated that vessel is in operation but do not get underway or occasionally get underway for short voyages; not vessel specific, Policy Letter cancelled- MSM overridden) : Engineering may be credited day-for-day for up to 50% of the service for each day the engineering plant is operational for: renewal RIG original issue Deck: Original Issue and RIG Creditable on a 3-for-1 basis (12 months of experience equals 4 months of creditable service) up to 180 days Renewal Service in any capacity in the deck department is creditable as CRS. When this CRS service is submitted along with underway service, CRS is only creditable on a 3-for1 basis (12 months of experience equals 4 months of creditable service) up to 180 days. 10
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STCW – Final Rule Part 10 10.232 (g) – Closely Related Service:
Previously Port Engineer, Port Captain, Shipyard Superintendent, and Qualified Instructor were listed in accordance with a RIG. CFR now specifies in conjunction with CRS. (h) – Day: Day is equal to 8 hours Vessels operating in a 2 watch system may be credited as 1.5 credit Vessels less than 100 GRT credited as 8 hr (unless COI indicates otherwise) MODU – no less than 4 hours and no more than 8 hrs credit Cadet service on a training ship may be credited as 1.5 credit 11
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STCW – Final Rule Part 11 General Requirements for National and STCW Officer Endorsements : No Character References CPR/First Aid: First Aid – CG approved course; American Red Cross or valid BT CPR – CG approved course; American Red Cross; American Heart Assoc. Creditable Service and Equivalents for National and STCW Endorsements : (d) now includes Dual Mode ATB (previously only ITB) Requirements for STCW Officer Endorsements : Standard of Competence (assessments) New NVIC’s (not yet published) will be created with new STCW assessments We will continue to evaluate, with regard to assessments, as normal Transitional NVIC gives this guidance as follows in the next slides. 12
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STCW – Final Rule Part 11 Basic Training (formerly Basic Safety Training) UNTIL January 01, 2017, mariners may qualify for the BT endorsement by providing evidence of meeting the previous requirements for BST by completion of approved training or one year of sea service in the last five years. AFTER January 01, 2017, mariners must provide evidence of maintaining the standards of competence in BT as described in 46 CFR (b) or 46 CFR (b). Impact to evaluations – no change from current practice until 1/1/17. Advanced Firefighting Until January 01, 2017, mariners may apply for an original endorsement or renew an existing endorsement by providing evidence of successfully completing approved training in Advanced Firefighting, or by holding a national officer endorsement that required Advanced Firefighting training. AFTER January 01, 2017, mariners must provide evidence of maintaining the standards of competence in advanced firefighting as described in 46 CFR (b). 13
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Contact The Maritime Center with any questions Or just email us at:
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KEY POINTS NO 1.5 Credit for MODU
Re-instatement – Re-issuance of expired credentials (i): If a MMC is expired beyond the 1 year grace period, the mariner must meet ALL original requirements. Service toward an oceans, near-coastal, or STCW endorsement will be credited as follows: Service on the Great Lakes will be credited on a day-for-day basis up to 100% of the required service. Military Sea Service: For calculation of sea service we are going back to using 60% of the total time onboard (vs. 70%) No Character References 15
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