by
MET Staff | Monday, October 7, 2013 |
A little noticed article in the Federal Register of August 9th contained important draft revisions to Volume 3 of the Coast Guard Marine Safety Manual – Chapters 20 thru 26. The importance of Volume 3 of the MSM is that it deals with Merchant Marine Personnel, and there are big changes afoot. To view the documents go to http://www.regulations.gov and use “USCG-2013-0240” as your search term. There are over 150 pages containing dozens of changes and updates that brought alarming responses from two of the largest trade associations representing towing vessel and offshore supply vessel owners. It is clear that both associations did their homework and highlighted a number of controversial points. What time will tell is how steady the Coast Guard will hold its ship on this course.
The substantive changes include: (1) updated provisions for vessel manning, including guidance for the issuing of safe manning documents; (2) clarifying roles, responsibilities, and facilitation of communications with the appropriate offices at Coast Guard Headquarters and (3) revised discussion on the impact of multiple international standards, including the Officer's Competency Certificates Convention (1936), the International Convention for Safety of Life at Sea (SOLAS), the Global Maritime Distress and Safety System (GMDSS), and the Principles of Minimum Safe Manning (IMO Resolution A.1047(27)).
Additionally, this draft clarifies the applicability of tonnage measurement systems to U.S. flag vessels, and it also includes changes resulting from the consolidation of merchant mariner qualification credentials, including the removal of references to the outdated operator of uninspected towing vessel (OUTV) endorsement.
This is a forward-looking document that will provide more weight to an already weighty document. It is an open question as to whether the Coast Guard will be able to adequately enforce some of these draft policies although they will have a number of years to try.
We would also connect the dots with a Marine Safety Information Bulletin (#021-12) issued in July titled “Compliance with Canadian Marine Personnel Requirements.” Our neighbor to the north has given sectors of the U.S. commercial vessel industry until next year to “shape-up” if they plan to send their commercial vessels to Canadian ports. This is a real wake-up call that calls into question the formal training of limited-tonnage engineers.
Job # unma1024.1A
Richard A. Block, B.A., M.S. (Ed.) Master #1186377, Issue #10 | 124 N Van Ave Houma, LA 70363-5895 | Tel: (985) 851-2134 | Fax: (985) 879-3911 | www.marineeducationtextbooks.com richardblock@nationalmariners.us