A History of the USCG’s Merchant Mariner Licensing and Documentation Program
2008 - 2014
As workload increases at the RECs due to regulatory changes and an increase in the number of mariners applying for credentials, processing times increases. In an effort to reduce backlogs, many RECs begin reducing the hours they are open to the public and also stop answering telephone calls from mariners. Further, regulations and policies, which are issued by USCG Headquarters and the NMC respectively, are subject to varying interpretation between the 17 RECs and complaints about lack of consistency begin to increase. This decline in overall customer service led the USCG to officially openning the NMC in Martinsburg, WV. Throughout 2008, RECs transition one by one and are not allowed to process applications and issue credentials. REC Boston is the last REC to transition in September 2008. Applications must still be submitted to a REC, but the paperwork is forwarded unreviewed to NMC in West Virginia for processing through background checks, medical screening, and professional qualifications review. Once the application is approved, the license/MMD/STCW95 certificate is mailed from NMC to the mariner.
The USCG establishes much more comprehensive mariner medical standards/policy in NVIC 04-2008 that replaces NVIC 2-1998.
New USCG regulations become effective that require mariners to apply to the Transportation Security Agency (TSA) for a Transportation Worker Identification Card (TWIC) before the USCG will entertain a license/MMD transaction. Though TWICs are costly for mariners and have dubious security rewards, mariners no longer have to travel to a REC for live-scan fingerprinting. Applications can again be mailed to a REC. A single passport-type Merchant Mariner Credential (MMC) is created and issued to mariners to replace four separate types of previously-issued credentials (licenses, MMDs, STCW95 certificates, and certificates of registry). Photos on the new MMC are obtained electronically from TSA, so mariners no longer need to provide passport-type photos.
The USCG regulations that created MMCs mandate that upgrades be issued as endorsements that do not extend the validity date of a MMC. Previous license upgrades resulted in a brand new license being automatically renewed with a new expiration date five years hence. This new provision results in hardships for mariners who now need to renew their upgraded license earlier than when certificate-type licenses were automatically upgraded and renewed at the same transaction. More drug tests will be required even though a new drug test cost/benefit analysis is not done. Additionally, mariners will be required to pay user fees sooner for renewals with no new user fee cost/benefit analysis having been done. When this issue is brought to the attention of program managers at USCG Headquarters, the USCG responds by stating that mariners can now renew a MMC at any point of its five year validity period. While this renew-at-anytime provision could be of value to mariners at certain times, it does not constitute a reason as to why automatic renewals at upgrade transactions were taken away from mariners.
A Credential Verification link is established on NMC’s website, so mariners and employers can easily verify the validity of MMCs. Also, each application’s status is e-mailed to the mariner as the file moves through the transaction process.
Last month that license holders/applicants can use the 2-page physical form CG-719K. Effective on January 1, 2010, all physicals for license transactions must be on a new, more comprehensive 9-page form CG-719K.
Mariners are allowed to scan and e-mail application packages to a REC.
USCG offers Merchant Mariner Certificate Suitable for Framing. The certificate is for display purposes only, and is not authorized to substitute for a MMC where the requirement to post a credential exists.
The Medical Evaluation Branch (MEB) backlog reaches 2,600 files (3+ months) as NMC underestimated the number of mariners who have medical issues. And mariners who have unremarkable physical exams (and no history of medical issues) do not bypass the MEB review backlog. These mariners with no medical issues have their transaction files sitting in the backlog with mariners who have medical issues. This problem is addressed later in 2011 when a screening procedure is finally established and mariners with no medical issues are finally quickly “screened through.”
Mariners with licenses 100 gross tons and less are not required to renew their TWICs.
As a reminder to mariners with a license that is about to expire, NMC starts sending e-mail notices to mariners 90 days prior to the credential expiration date.
The backlog of appeals of NMC transaction decisions to the Commandant of the USCG grows to six months. A majority of non-medical appeals are decided in favor of the mariner. These numerous successful appeals demonstrate that many procedures and internal policies at NMC are not in accordance with USCG regulations. And the backlog of appeals at times forces mariners to comply with an improper NMC policy in order to meet a renewal deadline (for example), rather than appeal and have the MMC expire while the appeal is being processed.
With NMC having been in operation for a few years now, other alarming USCG practices and management decisions are slowly being realized by the marine industry. Examples include:
Mariners applying for increases-in-scope or upgrades of lower-level licenses are having approvals withheld until the mariner resubmits previously-submitted sea service. In many instances, the mariner does not have copies of that previously-submitted sea service and cannot get the application approved despite the fact that the USCG does have access to the previously-submitted sea service that is in mariners files at RECs.
Mariners submitting for ratings such as Able Seaman and entry-level licenses up to 100 GRT are having their application approvals withheld, and being forced by NMC to take USCG-approved courses that substitute for the required exams and submit the course certificates within 90 days. NMC is not offering mariners the regulatory option of taking the required exams at a USCG REC up to a year after approval of the application.
Mariners submitting military sea service for original or upgrade transactions are assigned to the general pool of USCG evaluators. During the course of their training, USCG evaluators do receive an introductory lesson on how to compare military sea service to commercial vessel sea service. However this basic lesson does not substitute for an in-depth knowledge of the military vessel billet structure. Many license applicants with military sea service are being denied the level of license that he/she should receive. The USCG’s Marine Safety Manual acknowledges that military sea service evaluations are “challenging”. Therefore, applications with military sea service should be assigned to a cadre of evaluators who do have the required in-depth knowledge.
Many in the marine industry encourage NMC to improve these practices, but changes are either stymied, not fully implemented, or have implementation delays.
NMC orders RECs to prematurely archive all mariner files that are still at the RECs. This action not only adds another work burden to the RECs, but also is not in compliance with the USCG Paperwork Management Manual that requires archiving of mariner files after six years of inactivity. The reasons for this action seem questionable to the maritime industry, because retrieving files from the archives results in delays in obtaining legacy information that is needed for mariner upgrades.
The USCG updates medical standards/policy with a change to NVIC 04-2008.
The federal government shuts down for about three weeks, and as a result the USCG is unable to process mariner transactions. An inevitable backlog occurs. To mitigate the effects, NMC extends the validity date of some expiring MMCs and also extends the “due by” dates of some outstanding mariner paperwork for transactions started before the shutdown.
The USCG publishes regulations to incorporate the 2010 Amendments to the STCW Convention into the USCG regulations. Most of the new training requirements will not impact mariners holding existing STCW endorsements, but there are some exceptions that must be completed before January 1, 2017. Most of the remaining STCW requirements will not be mandatory for existing mariners until on or after January 1, 2017.
Changes are also made to national (non-STCW) regulations for the purposes of reorganization, clarification and needed updates. Included in the changes is reopening some grandfather provisions for Master of Towing Vessels licenses that had ended in 2004. These changes go into effect in March 2014.
The regulations also create USCG-issued medical certificates to comply with the International Labour Organization’s Maritime Labour Convention that requires that mariners have a separate medical certificate issued by the flag administration.
The USCG starts to automatically issue medical certificates to all holders of valid STCW endorsements, and will phase in issuance of medical certificates to all mariners through March 2019. The medical certificate requirement, October 2013 government shut down, and multiple NMC closures due to severe winter weather, all contribute to additional processing delays.