A History of the USCG’s Merchant Mariner Licensing and Documentation Program
1940 - 1989
Congress amends the Motor Boat Act of 1910 to establish safety requirements for mechanically-propelled vessels under 65 feet. The law also authorizes the Bureau of Marine Inspection and Navigation to issue licenses to operators of mechanically-propelled vessels that carry passengers for hire.
As a temporary wartime measure, President Roosevelt transfers the Bureau of Marine Inspection and Navigation to the control of the USCG.
The Bureau of Marine Inspection and Navigation is abolished and its marine safety duties are transferred to the USCG which is under the control of the Treasury Department after World War II. This marks the first time that responsibilities of the COTPs and OCMIs are the function of a single federal agency, and mariner licenses are now issued by the USCG.
Congress passes the Small Passenger Vessel Act of May 10, 1956 to become effective in 1958. The law requires OCMI inspection of vessels carrying more than six passengers for hire regarding lifesaving and firefighting equipment, machinery and electrical installations, hull strength, and stability. It allows the USCG to prescribe a maximum number of passengers and establish routes and conditions of operation. Also operators must be licensed by the USCG, and vessels must meet minimum manning requirements.
The USCG is transferred to the newly-formed Department of Transportation (DOT).
In order to address towboat accidents, Congress mandates Operator of Towing Vessel licenses for that segment of the marine industry. Mariners who were already operating uninspected towboats were allowed to “grandfather” for the new license in 1973 by simply proving their United States citizenship and passing a rudimentary physical exam. Written exams were not required to “grandfather.”
The USCG removes the licensing departments from 35 of the 52 Marine Safety Offices (MSOs) and Marine Inspection Offices (MIOs), and creates licensing Regional Examination Centers (RECs) at the remaining 17 marine safety units. All 52 marine safety units used their own interpretation of USCG licensing regulations, which resulted in too much variance around the country. Mariners would visit a MSO/MIO, apply for a particular license transaction, and see if it would get approved. If not approved, they would simply go to a neighboring MSO/MIO and try again. The mariner would continue to “shop” at subsequent units until he/she could find a licensing officer who would approve the application. Note that this was before user fees and before a USCG-wide licensing computer system was established, so a licensing department would have no idea that the mariner may have been denied just a day earlier at another unit.
The creation of 17 RECs reduces incidences of “shopping” due to the great distance between RECs and the fact that there were now fewer units for regulatory evaluation inconsistency. But inconsistency still exists, as each REC Senior Inspector of Personnel (SIP) and his/her superior OCMI have authority to interpret and apply the regulations as he/she sees fit. OCMIs report to USCG District Commander, who reports to the Commandant of the USCG.
Due to how far apart RECs are geographically, mariners are allowed to conduct transactions entirely by mail if no written exam is needed for the transaction. Even if a written exam is required, the application could be mailed in for approval. Once approved, the mariner could then schedule the exam at the REC or even at remote locations. The RECs have Travelling Exam Teams (TETs) who would travel to a site remote from the REC to proctor the exams to groups of mariners whose applications were “approved to test.”
Over the next few decades each REC establishes its own reputation and personality. Some become more mariner-friendly and accessible than others. Some develop backlogs due to a combination of their own management practices and a heavy local presence of the marine industry, while others issue licenses the same day an application is received. Some RECs are managed using a rigid checklist system and literal interpretation of what each mariner was asking for, while others are managed using a negotiation-type system where the license evaluator communicates with the mariner and suggests other license levels or ratings that the mariner may not have asked for, or lets the mariner know that he/she would not qualify for what was being asked for and suggests more realistic alternatives. Most people in the marine industry recognize the “better-performing” RECs from the “under-performing” RECs. The REC personalities grew so different that a single centralized licensing center was envisioned for consistency, but was not established until 2008.
A downside to the creation of RECs was that the USCG’s corps of commissioned officer marine inspectors would start to lose licensing expertise. Prior to RECs, all marine inspectors would rotate between the vessel inspection, investigations, and licensing departments at an MIO. And if assigned to an MSO, there was a fourth department (port operations) where COTP responsibilities were carried out. Thus before RECs, all marine inspectors became “fully qualified” and had knowledge/experience in all aspects of OCMI duties. Only if assigned to one of the MIOs or MSOs that had a REC could a marine inspector obtain licensing experience. Besides retirements and attrition, over the next few decades many of the commissioned officer billets at RECs were civilianized. These factors result in fewer “fully qualified” USCG officer marine inspectors, such that 30 years after RECs were established there were literally only a few still working in the marine industry.
The USCG recodifies, rewrites, and updates the mariner licensing regulations. Of note is that the new regulations no longer require industry-specific licenses such as Master of Passenger Vessels, Master of Freight and Towing Vessels, etc. A master or mate license issued for inspected vessels is valid for use on any type of vessel regardless if it was a passenger, freight, or uninspected towing vessel. For example, mariners holding master licenses for inspected vessels could operate tugboats/towboats without any specific training or experience in that industry. This towing vessel ideology only lasted 14 years and would be changed in 2001.
The 1987 changes also establish new license tonnage categories that will more closely align with looming international requirements. And the USCG licensing requirements start to incorporate more international requirements. An example would be that applicants for master or mate licenses over 200 GT must qualify for Able Seaman. Before these changes, mariners/mates could get licenses over 200 GT without having to qualify for Able Seaman.
The tankship Exxon Valdez grounds in Prince William Sound, Alaska and causes the largest oil spill in U.S. history.