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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.

Hello everyone, I hope you ALL had a very Merry Christmas and due to the weather around here I hope you ALL had a SAFE one as well.

If you have noticed, I do not put the names of those who write to me in my blogs.  I do this for my own reasons as well as to give you all some anonymity.  However, if you ever want me to add your names, please let me know before hand and I will gladly to do so.

Here is an e-mail I received from Mr. H.H.  This shows you that NMC CAN do things in a timely manner.

Greetings Norleen,

 We spoke yesterday about the times and trials of getting through the “New License Renewal “ system and giving my feedback to you and Mariners needing to renew. There have been some horror stories about the processing in W. Virginia. …Below is what I experienced.

 I heard of your services while attending classes at COMPASS COURSES in Edmonds, WA. I made an appointment with you in Nov 2008 and an hour later walked out with all documents professionally prepared the way they needed to be reviewed by the Seattle REC (for submittal to West Virginia). I KNOW your preparation allowed Seattle & W. Virginia REC’s to complete their review process in a quick and efficient manner.

 The only issues I ran across in the process was; the Seattle REC’s computerized finger printer was a bit cranky and  took a few try’s to record needed information. I highly recommend getting there early 0700 to allow you to be one of the first to sign in at 0730. (I was first to sign in and the process lasted till 0845). Seattle REC did a great job making sure all was attended as per regulations. Seattle REC will give you a  paper with a web site, access code, email address and phone number that will allow you to track your documents progression through their renewal process in W. Virginia. The access code never worked, my email inquiries were not returned, but twice I called W. Virginia and spoke with individuals that were competent and clear about the status of my documents. They received my documents from Seattle in 4 days (received Nov 14) and my licenses & documents were correct and returned to me in Poulsbo, Washington DEC 16. This means from mailing from Seattle REC to W. Virginia the completed process was back in my hands in a total of 34 days!  

 I appreciate your services and highly recommend Mariners to use them.

 My regards H. H.

 Thank you for your kind words Mr. H, they are greatly appreciated.

Touch Keys with you later,

N.

Here is a message I received from Mr. T.W.  Thank you for your comments, they are GREATLY appreciated and helpful to all.

Touch Keys with you later.

N.

Hi, I saw on your blog that you’d like to be kept up on mariner’s experiences with time for applications. I have an application in, so, I thought I’d share my experience with you.

This is my first time dealing with NMC.

I got my first MMD OS in February 07. I started working in May. That fall, I took several maritime courses, and applied for AB OSV and an STCW certificate with, among other things, RFPNW (Lookout Duties Only), which I was issued in January 08. I went back to work that next summer, and by that fall I gathered enough sea time for AB Special, and had completed the requirements to remove the restriction for RFPNW. I put my application in with the Oakland REC Oct 15 08, and it was sent to NMC. The NMC site says my credential is listed as Issued Dec 17 08. I have had several phone conversations with them during those 2 months, and overall, those conversations were pleasant and professional. I had misunderstood an issue regarding RFPNW, and sent in a wrong form. They worked with me, and I was able to get the appropriate certificate in to the evaluator. Had I done that originally, the turnaround time would definitely have been less, maybe 2-3 weeks.

Keep up the good work…

T.W.

I have been blessed with my customers giving me feed back on how long it is taking NMC to complete and return both renewals and original licenses and documents.

I just had a call from one of my clients who told me that he received his renewed license and STCW back from NMC in just 6 weeks with a “vision waiver”.  He was pleased that it took so little time. He said also, that the number he was given by the Seattle REC for him to be able to look up his status on line, did not work and he tried it several times.  He then called the Seattle REC and they looked up his status for him.  KUDO’S from Mr. H. for the Seattle REC’s help!  Apparently, his application was held up in the Medical Evaluation Branch (MEB) for a vision waiver.

This, “vision waiver”, I find to be very interesting.  Mr. H’s uncorrected vision was 20/70 in the right eye and 20/100 in the left eye correctable to 20/15 in the right eye and 20/13 in the left eye with a field of vision of 100 or better.

According to the newest Medical NVIC 04-08 Enclosure (5), in order to be considered for a vision waiver the mariner would have to have correctable vision of worse that 20/40 in each eye or uncorrectable vision of more than 20/200 in each eye to receive a “vision waiver”.  Obviously, the MEB can’t even read or follow their own requirements  found in their newly published NVIC or in 46 CFR 10.205 (d)(2).  By their own published requirements, Mr. H’s vision DID NOT REQUIRE A WAIVER.  I guess, the order of the day is, just toss a waiver on the license and don’t bother to look at the regulations, AND THEN, WHILE YOU ARE AT IT, TAKE 6 WEEKS TO DO IT!

Being a former REC evaluator, who used to type up these licenses and documents, evaluate sea service, give the exams, look at and use the standing regulations and the regulations for waivers to determine if a waiver was required, in my book, 6 weeks IS JUST PLAIN PATHETIC.

Mr. H. Thank you for your feed back and I am glad that you received your license and are happy.

Touch Keys with you later.

N.

Hi everyone, sorry it has been awhile since I last did this, busy, busy and it is not just the Holiday season.  Y’all are working me hard.  I Love it!

Here is something that I am sure we are going to see lots of in the future if you haven’t already been smacked in the face with it.

I had a customer send me an e-mail with this question.

“What does “ready to be evaluated MEB” mean? That’s been the status of my CG application for almost two weeks now. Bad time of year to do this I would assume, holidays and what have you… .”

Well, you know me, I immediately jumped on my SOAP BOX and here is my response to my customer.

Dear Mr. W.

MEB stands for Medical Evaluation Branch, and I don’t think the holidays even enter into it.

I called 1-888-427-5662 at the National Maritime Center and started to explain who I was, and that I was calling on behalf of a client, the person answering the telephone interrupted me and asked me for your Mariner ID number or the last 4 digits of your social and when I gave that information to her, I was told, even before I completed my statement that, and I quote:  “Mr. W’s application was received on December 5th, it is a long process that takes anywhere between 2 to 6 months and you will just have to be patient.” end quote.   The person who answered the telephone, did however take the time to take my name and business information for future reference or so she said.  Hum, that must mean that I am on their “S” list and I don’t mean Santa.  Yahoo, I’ve done it again and topped their list, my career is made.

Of course the person I spoke to was not in the medical evaluation branch and said she could not transfer my call to them because they were not accepting telephone calls due to the fact that they are trying to get “caught up” and did not want any interruptions.

I then asked if she could see a reason, on her screen, why your application was sent to the MEB and she said she could not tell me why and asked if you were “over weight” or had vision problems or on some type of medication or any thing like that.

I said no and then I asked her if she could tell me exactly what “over weight” was and what the weight standards were.  She said she had no idea what they were but that she had seen and heard that weight had been an issue in the recent past.

SO, I got to thinking about your physical and pulled down the copy I have and decided to do a little investigation of my own.  Your vision is within the normal range according to the CG, your field of vision is perfect, your hearing is good, your blood pressure is excellent, you are not color blind and passed one of the prescribed color vision tests, you are not on any medications, you have not had any medical issues that were noted on the physical, your doctor stated that you were competent, so what could possibly be the problem?  Hum.

Using the new Medical NVIC 04-08 and then looking at the Body Mass Index (BMI ) discussed on page 1 of enclosure 2, I then went to the below website and low and behold - you are considered “over weight”.  Using their guide at 5-11 (71″) @ 213 pounds, your BMI is 30 and this puts you in the “Over weight” category.
http://www.cdc.gov/nccdphp/dnpa/healthyweight/assessing/bmi/adult_BMI/about

Now, exactly what the MEB at NMC will do or ask you to do, I don’t have a clue.  Are they going to say you can’t have a license because you are over weight?  Are they going to tell you that before they issue your license you must lose “x” number of pounds?  Are they going to put a waiver on your license?  Are they going to say, sorry for the delay (after 3 or 4 months) and by the way here’s your license?

I just don’t know and can’t even guess at this point.  Furthermore, I can’t even guess as to how long this process is going to take for crying out load.

What can you do about this.  Well you can,

1. call the telephone number above; OR
2. you can e-mail the MEB at marinermedical@uscg.mil (I can’t guarantee that this e-mail address will get you where you want or need to be, but that is the address listed in the NVIC); OR
3. you can “patiently” wait for your license to magically appear sometime next year; OR
4. you can take other measures and contact your congressman and ask them to find out why your application has been delayed in the Medical Evaluation Branch.

At this point you cannot “Appeal” because you have not been disapproved for anything yet.

I wish I could do more for you but I don’t think I can at this point.  If you need anything, just let me know.

In the mean time, if you don’t mind and with your permission, I would like to post this to my BLOG.  I will not use your name so don’t worry.

Norleen Schumer
MaritimeLicensing.com

Mr. W promised to keep me posted and I, in turn, will keep you posted.

MERRY CHRISTMAS TO YOU AND YOUR’S AND HAVE A VERY HAPPY AND HEALTHY NEW YEAR.

Touch Keys with you later,

N.

Information I thought I should pass along.

Touch Keys with you later,

N.

December 16, 2008
Coast Guard Towing Safety Homeland Security Department (DHS); United States Coast Guard (USCG) (F.R. Page 71664)
Meeting by teleconference of the Towing Safety Advisory Committee to discuss and vote on three issues: Task Statement 08-02 regarding clarification of the Apprentice Mate (Steersman) license; the revised report of the Economic Analysis sub-group of the Towing Vessel Inspection Working Group; and a revised Resolution from the Commercial/Recreational Boating Interface Working Group. [Note: Call-in, 877-950-5410; passcode, 9876776]
Location: None given. 12:30 p.m. (December 16, 2008)
Contact: Gerald Miante, 202-372-1401, gerald.p.miante@uscg.mil