AMO Currents - Update: Important information regarding your U.S. Coast Guard documents

AMO Currents - Posted: October 14, 2014

Update: Important information regarding your U.S. Coast Guard documents

By Mike Murphy
National Vice President, Government Relations

Recent discussions with the National Maritime Center and a polling of AMO members reveal a need for greater awareness regarding current requirements pertaining to the documents we all need for employment on ships, particularly in the deep-sea sector.

First, however, I must preface my remarks with a "heads-up" concerning processing times at the National Maritime Center. Currently there is a significant backlog at the NMC and processing of upgrades and renewals is taking as long as four months. While NMC is working diligently to reduce this, the upcoming implementation of the 2010 Manila Amendment to STCW will probably cause extended processing times well into 2017.

Delayed issuance of documents

Recognizing the uncertainty of long processing times, the Coast Guard has changed their policy on "Delayed Issuance" of documents.

Previously, we could submit our documents up to a year in advance when renewing. This usually cost us time on the old document unless a "Delayed Issuance" was requested on the application. Then the Coast Guard would hold the new document until just before the old document expired.

The Delayed Issuance policy has changed for the better. The renewal application may only be submitted a maximum of eight months in advance now, but the Coast Guard will automatically issue the new document as soon as it is approved with an effective date the day after the old document expires. This means we no longer have to "burn" time on the old document. It also means we will have to have two documents in our possession when making the transition from one document to the other.

At the moment, I recommend submitting a routine application not less than four months in advance of the expiration date. If there are medical issues involved, you must allow time for the medical processing, too. However, recognizing that a delayed issuance doesn't cost time on your document anymore, a general policy of submitting eight months in advance would preclude worry about getting your document renewed before its expiration date.

Medical Certificate

The second point of discussion is the new Medical Certificate - and there seems to be a considerable amount of misunderstanding regarding this document. These certificates were first issued in January 2014 as part of the new STCW implementation. It is important that you have this document with you at all times on the ship as the Coast Guard will be checking them. It is even more important that you examine the dates on the medical certificate closely. You will find three expiration dates listed: STCW, National and Pilot.

For STCW qualified officers, the STCW expiration date governs the length of time between physicals. This date "should be" two years from the date of your last physical, unless you have a medical waiver that reduces the time. There were some anomalies on the first issuance and the Coast Guard adjusted some dates so they didn't expire immediately, but in the future, all STCW expiration dates will be generated off the date of your last physical. Now, for the most important point of this paragraph: YOUR MERCHANT MARINER CREDENTIAL STCW ENDORSEMENT IS NOT VALID IF YOUR MEDICAL CERTIFICATE HAS EXPIRED.

The difficult part is that the tracking of this date falls squarely on your shoulders. AMO is building a tracking system so we can provide a reminder six months in advance, but right now it is completely incumbent on the mariner to ensure they have a current certificate at all times. I am recommending that you start six months in advance in order to get the physical, allow time to work out any medical problems and give NMC time to update and mail the new certificate. This means the certificate is really only good for eighteen months. For those of you required by your company to get an annual physical, make sure the medical provider fills out the Coast Guard medical form (CG-719K), and make sure to submit it annually. There is no cost to renew your medical certificate.

For Great Lakes and inland waters mariners, the problem is less complicated. The National Expiration Date governs the validity of your document. This date should be five years from the date of the last physical examination, unless a medical waiver is issued for a shorter period of time.

For pilots, the period will be two years, BUT each pilot is still required to submit a physical every year.

STCW gap closing training

Earlier, I mentioned that the U.S. Coast Guard is now implementing the 2010 Manila Amendments to the STCW. We were supposed to have five years to meet the new requirements starting January 1, 2012. Due to a number of factors -mostly outside of the agency's control - the Coast Guard was unable to publish the governing documents until December 24, 2013. The net effect of the late implementation is a significant delay of our STAR Center training courses, which now effectively begin November 10, 2014, and run continuously through 2016. This means that U.S. mariners have only two years rather than five to get the required training - we are calling it STCW gap closing training - and it must be completed and you must have the endorsement on your credential prior to December 31, 2016.

STAR Center is ramping up to 150 percent of the normal student load and can accommodate all AMO officers for their training. However, in order to do this, they have to "level load" the courses. This means you need to go as soon as possible and not wait until the last minute because there may not be room to accommodate a large rush in 2016. And, the most important point that I haven't discussed, and you probably haven't noticed on your document: ALL CURRENT STCW ENDORSEMENTS EXPIRE ON DECEMBER 31, 2016, UNLESS YOU COMPLETE STCW GAP CLOSING TRAINING.

The take away here is that training time is short - classes are filling quickly and you have to allow time to apply to NMC and receive a sticker for your Merchant Mariner Credential in order to have a valid STCW endorsement for sailing deep-sea. Get your training done as soon as possible or you may not be able to work after the deadline.

I have discussed several important issues here and I know that the changes can be confusing and irritating. Both STAR Center and your AMO officials are here to help. Watch the STAR Center courses in the AMO paper and online for guidance, and if you aren't clear on something, contact STAR Center or call/ me. My cell phone number is listed in the paper and on the AMO website.