I AM SO PROUD TO BE AN AMERICAN - THANK YOU ALL !

If you get a chance, please look at this and I hope you feel the same way I do.

http://www.smartplanet.com/blog/cities/moving-documentary-of-911-evacuation-by-boat-shows-resilience-of-cities/881?tag=nl.e660

Touch Keys with you later,

N.

See Federal Register/Vol. 76, No. 168/Tuesday, August 30, 2011/Notices  Page 53924/53925

Announcements

Merchant Mariner Medical Advisory Committee

The Coast Guard announced the first Merchant Mariner Medical Advisory Committee (MMMAC) meeting in the Federal Register.

The Meeting is scheduled for September 19-21 in Easton, Maryland at Marine Engineers Beneficial Association.

Click here for details - Federal Register notice.

To view archive announcements and reports please click here.

If you have any questions please feel free to contact us through email at IASKNMC.

Touch Keys with you later,

N.

Hello Everyone I hope all of you are doing well, I must say my blood pressure is up a bit, Oh yes, that is because I am dealing with NMC isn’t it, I almost forgot that.  Here I go again jumping on my SOAP BOX yet again, this time it is about nonexistent, non-published IN HOUSE POLICY UP-DATES.  The only way we find out about them is when you get bitten by an NMC Evaluator whom NMC has been training NOT TO THINK and not to use common sense!  I know that consistency is imperative to a well functioning organization of any kind and I am sure you do also, so I can almost understand.  HOWEVER, if you want total automation or you want a robot, then you go build a NON-Thinking machine right?  Geeze, already my brain boggles at the thought- oops I forgot, thinking not allowed, just doing my young padawan.

Here is an exact quote out of an e-mail response I received from NMC.

“…to bring us together after centralization and treat all mariners the same, 

we train to use CG791P, verbiage on back referencing 46 CFR 16, Part B or 

Guidance Document 03-04….”

BEWARE all Evaluators at NMC have been instructed, trained, taught, turned into an automaton or what ever you want to call it, to see only BLACK AND WHITE, no gray areas thank you very much and no using common sense either.  Thinking on their own, OUT OF THE QUESTION!

Here is the latest and greatest in the IN HOUSE POLICY OF THE NEW AND IMPROVED NMC.  I am presuming here that this goes for everything being presented and sent into NMC, not just what I am about to explain to you so be prepared and be forewarned.

USE EXACT EXAMPLE VERBIAGE ONLY, no alterations, no variations.  I had a client who has been with a company for years and that I have been familiar with for the last 20 odd years who sent their mariner a letter of sea service with the drug test verbiage in it that has been acceptable for the past how many ever years.  There letter simply stated that Mr. X has been involved in our random drug testing program for the past x number of years under 46 CFR part 16 and has not failed or refused testing.   NMC is now sending it back saying it was unacceptable because it did not state SPECIFICALLY one of the following examples, and I do mean SPECIFICALLY:

Please note that each one of these say “EXAMPLE” however, I suggest that you word it exactly like one of the EXAMPLES LISTED, otherwise, I’m sure you will confuse the evaluators at NMC.

So, to all of the employers out there, take heed and be specific in your letters.  Cut and paste one of the examples into your letters of sea service until NMC comes out with another “unwritten”, “unpublished”, in house, policy.

REQUIREMENTS:

• A drug test is required for all transactions EXCEPT endorsements, duplicates and STCW certificates.
• ONLY a DOT 5 Panel (SAMHSA 5 Panel, formerly NIDA 5), testing for Marijuana, Cocaine, Opiates, Phencyclidine, and Amphetamines will be accepted.

OPTION I
PERIODIC TESTING
PROGRAM

• A USCG drug test conducted within the past 185 days by a laboratory accredited by Substance Abuse and Mental Health Services Administration (SAMHSA), Department of Health and Human Services.
• COLLECTION of a urine sample may be conducted by an independent medical facility, private physician or at an employer-designated site as long as the collection agent meets the qualification requirements to be a collection agent given Title 49 CFR Part 40.31. It is CRITICAL that the sample is sent to an accredited SAMHSA laboratory for ANALYSIS or the drug test is invalid.  A list of service agents that can assist in meeting these requirements is included or a list of service agents can be obtained at www.uscg.mil/hq/g-m/moa/dapip.htm.
• The ORIGINAL results are required. A FACSIMILE is acceptable, if it is originated from the Medical Review Officer (MRO) or the Service Agent assisting the mariner, and sent directly to our office. The drug test result must be signed and dated by the MRO or by a representative of the service agent who assisted you in meeting this requirement.

OPTION II
RANDOM TESTING

• An ORIGINAL DATED letter on marine employer stationary or, for ACTIVE DUTY MILITARY MEMBERS, an ORIGINAL DATED letter from your command on command letterhead attesting to participation in random drug testing programs.

EXAMPLE (From Marine Employers): APPLICANT’S NAME / SSN has been subject to a random testing program meeting the criteria of Title 46 CFR 16.230 for at least 60 days during the previous 185 days and has not failed nor refused to participate in a chemical test for dangerous drugs.
EXAMPLE (Active Duty Military/Military Sealift Command/N.O.A.A./ Army Corps of Engineers):  APPLICANT’S NAME / SSN has been subject to a random testing program and has never refused to participate in or failed a chemical drug test for dangerous drugs.

OPTION III
PRE-EMPLOYMENT
TESTING

•  An ORIGINAL DATED letter on marine employer stationary signed by a company official, stating that you have passed a pre-employment chemical test for dangerous drugs within the past 185 days.

EXAMPLE: APPLICANT’S NAME / SSN passed a chemical test for dangerous drugs, required under Title 46 CFR 16.210 within the previous six months of the dateof this letter with no subsequent positive drug test results during the remainder of the six month period.

I will soon be sending out an e-mail to all of the companies that I have e-mail addresses for giving them this updated information (or at least updated as of the 4th of February 2010) remember, this could change at any moment and we won’t know about it until an evaluator sends it back as being wrong.  I just hope all of the evaluators are reading the same hand book, but unfortunately, I don’t think they are.

Touch Keys with you later,

N.

Hello everyone;

It’s been a while for me to set down to do my Blog.  I am not complaining, but my plate, thanks to you, is getting fuller and fuller - bad grammar - but true none the less.

If you have not had a chance to see the latest and greatest, I suggest you read and voice your opinions on this one.

See

Federal Register / Vol. 74, No. 220/Tuesday, November 17, 2009/Proposed Rules.

It is 90 pages and covers 46 CFR Chapter 11, among other STCW items.  This is interesting to me because in the 2008 version of the CFR there was no Chapter 11.

Here is where my confusion comes in.  In the past 2-3 months, I have had many of you  send me copies of letters that you have received from the NMC requesting that you meet and comply with 46 CFR 11 . ???.  Obviously I have missed something along the way so I did a little research.  I have been on the CFR Website looking to make sure I have the most current CFR published in 2008, (2009 version has not been published yet according to those folks and they should know don’t ya think?).  I checked with several REC’s and they have also told me that there is no Chapter 11 in the current CFR so how can NMC tell you to comply with something that does not exist?

Now here are my questions. 

• How in bloody blue blazes can you, the mariner, possibly comply with something that has not been published yet? 
  
• How and where is NMC coming up with this? AND above everything else,
  
• Why is NMC permitting their evaluators to request items listed in 46 CFR 11 when 46 CFR chapter 11 does not currently exist?
• and WHAT THE H#(( have I missed?
  

That little tidbit was just the first thing that jumped out at me, I’m sure that I will have one or two more comments to send to the Coast Guard concerning these proposals.

So my suggestion to you would be to PLEASE READ THESE PROPOSED RULES CAREFULLY AS THEY AFFECT YOUR LIVELIHOOD and make your concerns and opinions and objections known.  Otherwise, YOU are going to have to live with the outcome.  Just like voting, if you didn’t vote, you don’t have a right to bitch.  Why do you think I am so good at bitching?

Hi y’all:

Here is a little ditty I received from one of my customers that I thought needed to be shared.

Here is his question.

Sirs;

   I have received my new issue MMC for Chief Engineer, Oceans,

6000HP.  I note that in the STCW Competencies listed there

appears:  ….”duly qualified in accordance with the provisions of

regulation(s) III/2;  III/4;  VI/2.”  My previous STCW Endorsement

Certificate (Engineering) listed all of these AND also:   VI/1. Please explain why competency in STCW Regulation VI/1 has not been continued and included in my newly issued MMC.

HERE IS NMC ANSWER -

Dear Mr. ———:

THE REGULATION VI/1 IS THE “BASIC SAFETY TRAINING”, IN WHICH WAS NO LONGER REQUIRED ON THE STCW. SINCE THE BST’S ARE A PREREQUISITE QUALIFICATION FOR THE STCW IT WASN’T NECESSARY TO BE PLACED ON THE INTERNATIONAL ENDORSEMENT.  HOWEVER, WITH THAT SAID, DUE TO REGULATORY CHANGES; CREDENTIALS ISSUED AFTER SEPTEMBER 11, 2009, ALL INHERENT REGULATIONS WILL APPEAR ON THE CREDENTIAL.  SINCE YOUR CREDENTIAL WAS ISSUED PRIOR TO SEPTEMBER 11, 2009, THAT REGULATION WAS CONSIDERED INHERENT AND LEFT OFF.

Thank you for contacting the Mariner Information Call Center.

Soooo, it appears that Bitching really does work, and boy am I good at it.  I cannot take credit for this change (regulatory changes my … —lazy is more like it), but I can tell you this much, this was one of the issues I had addressed LOUDLY with NMC.  Not everyone knows what is “INHERENT” in a license.

Touch Keys with you later,

N.

Hi everyone, it’s been a long time and this time I am not on my soap box.

I had someone ask me today if my “Package Preparation” service was really necessary.

He asked; “Can’t I just put the stuff together my self?” OF COURSE you can put it together for your self!

Do any of you need my services?  NO, of course not.  You can spend the time looking up all of the regulations on your own; you can research on the CG website; the MSM; the CFR’s; the NVIC’s, the Policy Letters; and the U. S. Code to find everything that is necessary for you to have when apply for your MMC.

However, from a business stand point my services are, invaluable, what else can I say.   I am selling my knowledge and expertise at a more than reasonable price and I will work for you with NMC should the need arise using my “Third Party” Durable Power of Attorney and I also guarantee my work or your money back.

Remember, the choice is ALWAYS yours to make.

Touch Keys with you later,

N.

This Federal Register is making many changes to the CFR, a few changes to 33 but many changes to 46.  It is 72 pages of intense reading.  Enjoy!

Go to: http://www.thefederalregister.com/

VOL. 74., NO. 49/MONDAY, MARCH 16, 2009/RULES AND REGULATIONS

Touch Keys with you later,

N.

Good day to you all, here is an e-mail I received from the Coast Guards Office of Operating and Environmental Standards in response to questions I asked as well as others from MITAGS; Vessel Alliance; Mates Org. and Dunlap Towing to name a few.  It says quite a lot.

Touch Keys with you later,

N.

To All;

I received a number of emails and phone calls from industry members seeking clarification on the application of the VSO training and certification requirements to towing vessels less than 200 GRT, in 46 CFR 15.103(e) and (f). After reviewing all of the regulations and discussing it with the various offices I offer the following interpretations to the three possible scenarios that the Coast Guard will be considering with regard to implementation of the VSO requirements:

1. Persons serving as VSO on vessels of less than 200 GRT (other than passenger vessels subject to subchapter H of title 46 CFR) engaged in domestic voyages between ports in the contiguous United States (does not include Alaska or Hawaii) that operate inside the boundary line are not required to carry a VSO certificate.

2. Persons serving as VSO on vessels of less than 200 GRT (other than passenger vessels subject to subchapter H of title 46 CFR) engaged in domestic voyages between ports in the contiguous United States (does not include Alaska or Hawaii) that operate beyond the boundary line, but within near coastal waters (as defined in 46 CFR 10.103 — within 200 miles of the coast of the United States), will be required to meet the certification requirements for VSO. These persons will be issued an STCW VSO endorsement with a near coastal limitation, but will not be required to undergo any additional training in order to receive the endorsement. Affected mariners may request the endorsement from the National Maritime Center and need not show proof of having completed a Coast Guard-accepted training course in order to receive it.

3. Persons serving as VSO on vessels of less than 200 GRT (other than passenger vessels subject to subchapter H of title 46 CFR) engaged in domestic voyages (between US ports) that go beyond the boundary line and either 1) travel outside U.S. near coastal waters as defined in 46 CFR 10.103 (i.e., beyond 200 miles offshore) or 2) enter the waters of another Administration will be required to meet the training and certification requirements for VSO. These persons will be issued an STCW VSO endorsement with no limitations. Affected mariners may request the endorsement from the National Maritime Center and need to show proof of having completed a Coast Guard-accepted training course in order to receive it.

We recognize that this interpretation is somewhat different from the one we originally provided in response to questions submitted by AWO. However, after reviewing these scenarios and all of the underlying STCW regulations applicable, we believe this interpretation accurately reflects the requirements of STCW. Please feel free to contact me if you have any further questions.

How-Deeeee!  Yup, I’m a wear-en my Minny Pearl hat today.  Some of you may be to young to remember her but, like Maxine (My hero) she told/tells it like it was/is!

Wake up and Smell the Coffee folks, this is YOUR LIVELY HOOD here and you better know what the H*(( you are holding or you will be left standing at the Pier wondering what happened.  I can’t do all of this for you, I can help to a point, but jeez, give me a break.  I know for a fact that the CG won’t do this for you (it just ain’t their job).

Have you ever looked at your STCW Certificate?  I mean really looked at the top of it and noticed all of those wonderful Roman Numerals and wondered exactly what the H*(( they meant?  NO?  Then I  have a real treat for you.

Below is a very short listing of some of the codes and what they mean:
ROMAN NUMERAL = REFERENCE TO STCW (Regulation Code) and
KEY TERM OR PHRASE (what they mean)

These are just a few of the Roman Numerals / Key terms or Phrases you will find on the top of your STCW Certificate.  PAY ATTENTION TO THEM, THEY ARE VERY IMPORTANT.

VI, A-VI/3 = Advanced Firefighting
VI/1, A-VI/1 = Basic Safety Training
III/2, A-III/2 = Chief Engineer Officer
II/2, A-II-2 = Chief Mate
VI/1, A-VI/1 = Familiarization training (all seafarers)
V/1 = Familiarization training (tankers)
VI/2, A-VI/2 = Fast Rescue Boats (proficiency in)
VIII/1, A-VIII/1 = Fitness for duty (watchkeeping personnel)
IV, A-IV, II/1, II/3 = GMDSS (Radio Communication)
II/2, A-II/2, II/3- A-II/3 = Master (general qualifications)
VI/4, A-VI/4 = Medical First Aid/Medical Care (persons designated to provide)
II/1, A-II/1, II/3, A-II/3 = Officer in Charge, Navigational watch
III/1, A-III/1 = Officer in Charge, Engineering watch
III/4, A-III/4 = Ratings forming part of engineering watch (RFPEW)
II/4, A-II//4 = Ratings forming part of a navigational watch (RFPNW)
VI/2, A-VI/2 = Rescue craft (proficiency in)
VI/2, A-VI/2 = Survival craft (proficiency in)

Of course you will not find ALL of these on your STCW if you don’t or haven’t qualified for them so don’t expect to see them all, but know which ones you should have.  If you don’t have them and you know or feel that you should have them SPEAK UP AND FIND OUT or you will be standing shore-side watching your job go bye-bye.

Touch Keys with you later,

N

Yes my friends, this question has reared it’s ugly head once again.

“I only hold a 6 pack and I will never be going on a “Secured facility” so why do I need a TWIC”?

If you are under the impression that the TWIC does not apply to you,

YOU ARE DEAD WRONG

YES, you are required to have a TWIC 

As of this writing, the TWIC regulations have not been changed.

TWIC

Are you currently holding or are you planning to get one of these?

1. Master  25-100 gross ton license?
2. Operator of Uninspected passenger vessels (OUPV or 6-Pac) license?
3. Mate 25-200 license?
4. Master or mate of Uninspected Fishing industry vessels?
5. Master or mate of 500-1600 gross register tons license?
6. Master or mate Towing vessels?
7. Master or mate of any gross tons?
8. Designated Duty Engineer 1000 HP/4000 HP/Any HP
9. Chief or Assistant Engineer (Limited)?
10. Chief or Assistant Engineer?
11. Merchant Mariners Document (MMD/Z-card) for Ordinary Seaman?
12. Merchant Mariners Document (MMD/Z-card) for Able Seaman?
13. Merchant Mariners Document (MMD/Z-card) for Qualified Member of the Engine Department (QMED)?
14. Certificate of Registry for a Doctor/Nurse/Hospital Corpsman?

Any one of these require that you apply for and receive a TWIC Card.  TWIC stands for Transportation Workers Identification Card.

.    Make sure that you apply for your TWIC card on the TSA.gov website

Touch Keys with you later,

N.