Sunday, September 24, 2017
   
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FAQ

 

Index to Topics in FAQ

Drug and Alcohol Testing

BVI Boat Master License

Demise Yacht Charters

Tender Operations

Rest Periods

TWIC

Digital Selective Calling

Marine Casualty

Marine Casualty:Report Them!

Military Sea Service

What You Need to Know About New PDSD & SA Requirements!

Notice of Arrival

 

CGlogo Credentialing Fact Sheet!

 

Progress continues to be made in the Merchant Mariner Credential (MMC) processing by the National Maritime Center (NMC) in Martinsburg, WV.  A Fact Sheet which was originally made available to Coast Guard Sectors highlights online services.  For answers to the following and additional information click  more….

 

1)    How do I know if a US Merchant Mariner Credential is valid (you can even check your own)?

2)    How can a Mariner check the status of their credential application (a step-by-step view of the progress on your paperwork)?

3)    Online submission of credential applications and other online service information  is also available at:

 

http://www.uscg.mil/nmc/

 

Drug and Alcohol Testing - LT Sarah Rousseau

 

This time around I want to go over the Drug and Alcohol Testing program that is required by 46 CFR Part 16. Lately, the Coast Guard has been cracking down on this program which means that inspectors are taking a more critical look at your program. Hopefully this article will provide you with a few tips so that you pass your next inspection.First, if you run a commercial vessel operation (ferries, excursion vessels, cargo ships, AND EVEN UNINSPECTED PASSENGER VESSELS!), you are required to implement a drug and alcohol testing program for your company. Regulations state the MARINE EMPLOYER is responsible for this, NOT the mariner. Most companies subscribe a consortium which covers most responsibilities for you. However, they do not cover ALL responsibilities which puts you at risk. Ultimately, YOU, the marine employer, will be fined for not complying, not the consortium.

 

So, who must be drug and alcohol tested?


Good question. Anyone who is acting in a safety sensitive position on the vessel should be enrolled. That means your Master, your crewmembers and anyone who works on the vessel. Some people may ask, "What about the woman who just takes the tickets on the ferry?" Good question. But let's take a look at a scenario where the boat is on fire and all the passengers must abandon ship. They are panicked and looking for someone from the crew to help. The passengers don't know the difference between the "ticket lady" and the "deckhand." They will ask the ticket lady for help just as soon as they'll ask anyone else, which means that a person working in an official capacity aboard the ferry is considered to be in a "safety sensitive position" and therefore is required to be enrolled in the drug and alcohol testing program. What about the lady who works back in the office but she never goes out on the boats? Good question again. No, she does not have to enrolled, as long as she is never on the boat performing safety sensitive functions.

 

For what reasons would I need to be drug or alcohol tested?

The regulations stipulate 5 reasons for chemical testing:
1. Pre-employment: That means you must take the chemical test BEFORE you start working for a company. That company must have the RESULTS IN HAND before they ever put you in a safety sensitive position. I can tell you right now, I have written up two violations in the past month for employers who put their Captain aboard a vessel PRIOR to having those results in hand. That's $1500 per violation, per day right off the bat. Violations don't come cheap. 2. Periodics: This happens when you go for a new license or renew or upgrade your license. 3. Randoms: Marine employers must ensure that at least 50% of their crew is randomly tested each calendar year. Furthermore, they must retain those records of positive drug tests for 5 years and negative drug tests for one year in a CONTROLLED ACCESS location. Meaning a safe. 4. Serious Marine Incident (post-casualty): Anytime the vessel is involved in a serious marine incident. And that does NOT just mean when someone dies. I'll discuss those incidents in a bit. side note: I just wrote a violation yesterday for a company that did not do drug and alcohol testing after a casualty - $1500 first violation. Maximum penalty is $7000. 5. Reasonable cause: That's right...employers, if you suspect your crewmembers are smoking it up behind the shed, and you observe signs (you must be able to articulate those signs and verify with a second witness), then you are required to send them for drug testing and alcohol testing. With that being said, if you are the mariner and you REFUSE to go get tested WHEN YOUR EMPLOYER SAYS YOU SHOULD GO, that is considered a REFUSAL and automatic positive drug test. Your license WILL be taken. With that also being said, marine EMPLOYERS, you are REQUIRED to tell the US Coast Guard when someone in your company has a positive drug test. If the Coast Guard discovers that you have had positive drug tests for your employees and you failed to report them, you will be fined. Inspectors will be paying closer attention to this in the future. Okay, so as a marine employer, what are some common mistakes I should be aware of so that I'm in compliance with the drug testing program?
GREAT question! Most people are aware of their random drug tests because their consortiums take care of it for them. Here's what they most often miss: Marine employers are required to provide an Employee Assistance Program which shall be conspicuously posted so that if a mariner DOES have a drug or alcohol problem, they may contact the free help line to get assistance and they may have access to educational material. There must be documentation for crewmembers of the training given to crewmembers. Supervisory personnel must receive at least 60 minutes of training.

 

What about post-casualty drug and alcohol testing?


If you are involved in a serious marine incident, you as a marine employer are required to conduct drug/alcohol testing on individuals directly involved in the incident.
Who is considered directly involved?
Basically, if they're on watch when it happened, they're involved. Let's start off with what constitutes a serious marine incident: a death, any injury that involves treatment beyond first aid of a passenger OR crewmember, damage to a vessel and/or property over $100,000, actual or constructive loss of any vessel subject to inspection, actual or constructive loss of any vessel not subject to inspection that is over 100 gross tons (we don't really have those here), discharge of oil of 10,000 gallons or more, or a discharge of a reportable quantity of a hazardous substance into the water.


How and when do I do alcohol testing?


Well, if you're an inspected vessel, you should have the alcohol testing strips or some way to test for alcohol aboard your vessel. YOU may conduct testing with witnesses around (all to be documented on a CG-2692B) and it must be done within TWO hours of the incident. If you miss that time period, you must still conduct it within EIGHT hours but you must be able to articulate to the Coast Guard why you couldn't do it within the two hour time limit. Beyond eight hours, you are not required to test for alcohol anymore (although you may be held accountable for not conducting required post-casualty testing).


How and when do I do drug testing?


Drug tests must be conducted with a Department of Transportation-approved collection site and laboratory. If you belong to a consortium, then they probably have contracted with the appropriate sites. As the marine employer, you must ensure your personnel get to drug testing within 32 hours of an incident. Those results must also be reported to the Coast Guard on a CG-2692B form.

 

Finally, what if I'm a mariner that is self-employed?

 I don't work for any company; I just take out charters; do I still need to be enrolled in a drug and alcohol testing program?
Yes. Technically, in this case, you are your own marine employer and you are required to ensure appropriate drug and alcohol testing is carried out (good luck on "reasonable cause" testing! ;) Well, I know that was a lot of reading but I hope it clarifies some things for you. If not, we will be holding an Industry Day on April 24, 2013 (time and place to be announced). Or you can always stop by the office down on the waterfront or give me a call at one of the numbers below. On that note, I must say a sad farewell, as I will be leaving island in May to attend graduate school so I may be of better service to the Coast Guard and my country. It has been a pleasure working with you all and rest assured you have taught me many things and have made me a better Coast Guard inspector and investigator as a result. If you have any questions, or you just want to say goodbye, don't hesitate to call! Fair winds and following seas!

 
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BVI Operations -  VIRGIN ISLANDS SHIPPING REGISTRY

 

BVI Boat Master Application - UPDATE (November 2013)

 

It is mandatory for all Masters of Small Commercial Vessels inspected and certificated by the Virgin Islands Shipping Registry to hold a BVI Boat Masters Licence. The Virgin Islands Shipping Registry issues an endorsement accepting Master/Skipper certificates issued by other administrations such the USCG, RYA, MCA, UK white list countries etc. The VISR does not recognize the USCG Uninspected (OUPV) six pax licenses for the issue of endorsements. The BVI endorsements carry the same limitations as the licence that the endorsement is based on with the added proviso that more than 150 passengers cannot be carried on any voyage.

Further information on the subject of this endorsement is as follows:

  1. An appointment can be made by calling the VISR at 284-468-2902/3. The office hours are from 08:30 to 16:30. Cash is not accepted after 15:30 hrs.
  2. The fee for the endorsement is USD 150/-
  3. The endorsement is valid until the expiry of the certificate it is based on.
  4. Identification can be provided using valid Passport.
  5. A valid medical report issued in BVI is required which could cost around USD 50/-
  6. Additionally a reference letter or testimonial from the last 2 employers, two passport size photographs, STCW certificates or STCW endorsements on the licence, an FCC or BVI radio licence is required.
  7. Further information is available on our website www.vishipping.gov.vg
  8. Form BVISR-504 Boat Master Application may be requested online:  http://www.vishipping.gov.vg/ContactUs/tabid/57/Default.aspx

Capt. R. Bala
Senior Nautical Surveyor
BVI Shipping Registry



Demise Charters

(Source)Lt. Sarah Rousseau

Question: Is it true that to be considered a bare-boat or "demise charter", as owner of the vessel I must give possession and full control of the boat to the charterer and the charterer hires their own master and crew?

Answer: Yes, in order to be a valid, legal bareboat charter, the owner of a vessel must essentially give up complete control of the vessel. Liability is transferred to the charterer, including the responsibility of insurance, fuel, amenities and crew. Without turning over complete control, especially with the hiring of a crew, the vessel is considered a passenger vessel for hire and requires a licensed Master, whether it is inspected or uninspected. As a Coast Guard investigator, the criteria we use to verify a valid bareboat or demise charter are as such:

1. Although a master or crew may be furnished by the owner, full possession and control must be vested in the charterer (a provision
requiring the charterer to be guided by the advice of the furnished master
or crew, in regard to technical matters or navigation, is acceptable);

2. The master and crew are paid by the charterer;

3. All food, fuel, and stores are provided by the charterer;

4. All port charges and pilotage fees are paid by the charterer;

5. Insurance is obtained by the charterer, at least to the extent of covering liability not included in the owner's insurance. A greater indication of full
control in the charterer is shown if all insurance is carried by the charterer (of course, the owner retains every right to protect his or her interest in the vessel);

6. The charterer may discharge, for cause, the master or any crew member without referral to the owner;

7. The vessel is to be surveyed upon its delivery and return.

Tender Operations - Lt. Sarah Rousseau

Question: An inspected passenger vessel comes to her mooring, and the paying passengers are taken by the vessel’s tender (with a rated capacity of 10), up to 8 at a time to the dock. Can the mate (not licensed) take the passengers, or does it have to be a master? With 8 passengers onboard does the dinghy have to be inspected?

Answer: Because the passengers are for hire, meaning they've paid for their passage, then the dinghy must be inspected, regardless of the fact that the vessel to which the tender belongs is already inspected. The dinghy must have a licensed Master onboard as long as it is carrying over 6 passengers. However, by carrying 6 or fewer passengers, the tender does not have to be inspected and a mate/deckhand can get their OUPV license to operate the dinghy.

Rest Requirements

A number of changes to STCW requirements were made by the 2010 Manila Amendments. Among them were changes to the rest requirements which:

1) Expanded the application for hours of rest periods for mariners to include all personnel with designated safety, prevention of pollution, and security duties onboard a vessel

2) Increased the minimum weekly rest hours from 70 hours to 77 hours

3) Required use of a standardized format to record watch schedules

4) Required compensatory rest period for seafarer on call

5) Required record keeping of hours of rest

6) Required a copy of records of hours of rest to be provided to the seafarer

7) Amended the exceptions to the hours of rest requirements.

For additional details click: Hours of Rest

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TWIC Renewal Process

Effective 30 AUG 2012 there will be a new option when renewing your expiring TWIC cards. You will be able to choose to renew for 3 years at $60, with a single trip to the TWIC Enrollment Center. There is still a 5 year renewal available for $129.75.

For additional details click: Policy on Expiring TWIC

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Digital Selective Calling - Boat US

Technology offers solutions that can make all the difference in an emergency. Your VHF likely has a big red DSC button that can automatically communicate, allowing you time to deal with the emergency. VHF radios sold in the US after June 1999 are required to have DSC capability. Now is the time to make the proper connections to your GPS, and get your FREE MMSI #:

http://www.boatus.com/MMSI/

This video gives you the specifics on the advantages of your DSC radio operation. Click topic #4 “Digital Selective Calling?” at:

http://www.boatus.com/foundation/dsc/player.html?WT.mc_id=400090

Testing of your DSC radio can be done transmitting a *test call* (not a routine DSC call) to the identity 003669999 which will trigger a reply from any USCG Rescue 21 station within range. If your radio does not have a *test call* capability, you can test it by sending a DSC call to another DSC-equipped radio.

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Marine Casualty Reporting - Lt. Sarah Rousseau

I'm noticing a lot more people reporting their Marine Casualties. This is a good thing! (Not that they're HAPPENING, but at least that when they are happening, you are reporting them!) I'm glad we're getting more people onboard with the regulations; it keeps us more informed and it protects you and your license!

In receiving our Marine Casualty Reports (Form CG-2692), I wanted to point out a couple of things that will help you and help us get through the investigations:


- Report Marine Casualties IMMEDIATELY. That means within minutes of the casualty happening. The CG-2692 comes later, but you must report these things immediately by phone or radio or whatever means necessary. This gives Coast Guard the option of coming out to inspect the vessel if we need to and to advise you of the need for drug/alcohol testing if necessary. NOT reporting immediately is a VIOLATION and action CAN be taken against your license or fines placed on the company or individual for not reporting.
- When you fill out the narrative portion, tell us ALL YOU CAN about what happened. Answer the Who, What, When, Where and Why. With crew, I need names, contact numbers and credential numbers. If it involves equipment, tell me what went wrong, why it went wrong and what you are doing or did to fix it.
- I will be asking for documentary evidence. So, if you have a mechanic's report, I need that. If you have pictures of damage, I need that. If you have logs (which you should be keeping in case of a marine casualty), I need that.


Military or Foreign Sea Service

What is creditable?

Experience and service on military or foreign vessels is creditable towards eligibility for a U.S. Merchant Mariner's Credential (MMC). Such service is subject to evaluation by the Coast Guard to determine that it is a fair and reasonable equivalent to service acquired on merchant vessels of the United States, with respect to grade, tonnage, horsepower, waters, and operating conditions.

How do I document military sea service?

Satisfactory evidence of U.S. military service means a Transcript of Military Sea Service or certified History of Assignments (a DD-214 is not sufficient evidence of sea service). If you do not already have proof of military sea service, you must fill out a Request Pertaining to Military Records (Form SF-180) to obtain your official Transcript of Military Sea Service. Send the request with your name and a return address, printed legibly, to the address of the record custodian for your branch of service noted on the back of the request form. In addition, if you are requesting records from before 1973 you should include your service number; after 1973 include your social security number.

How do I document foreign sea service?

Satisfactory evidence of foreign sea service must meet the requirements for proof of service for qualified ratings noted in section I.C. above. If the documentation is not in English, then a certified translation should be included.

Age/Citizenship/Social Security Number Requirements

How old must I be?

You must be at least 16 years of age before obtaining a Merchant Mariner's Credential (MMC). If you are between the age of 16 and 18, then you must present a notarized statement of consent from a parent or legal guardian providing written permission for you to go to sea.

How do I provide proof of age and citizenship?

When submitting your application package for evaluation, you must include a copy of the proof of citizenship. You must present the original evidence of citizenship prior to issuance of an MMC. If your name on your proof of citizenship does not match the name you are now using, then proof of legal name change is required. Acceptable proof of name change may include original court documentation, original marriage/dissolution of marriage certificate, or original school records. Acceptable proof of citizenship and birth date is any one of the following:

  • Birth Certificate or Birth Registration
  • Certificate of Naturalization (If you are a naturalized citizen, then you must submit this certificate)
  • Baptismal Certificate or Parish Record recorded within one year after birth
  • Statement of a practicing physician certifying attendance at the birth and who possesses a record showing the date and location at which it occurred
  • State Department Passport
  • A Merchant Mariner's Credential issued by the Coast Guard which shows the holder as a United States citizen
  • Delayed Certificate of Birth issued under a state seal
  • Certificate of Citizenship issued by the United States Immigration and Naturalization Service

What if I am not a U.S. citizen?

You may still be considered for an MMC, but you must provide documentation that you are a permanent resident in possession of an Alien Registration Card issued by the U.S. Immigration and Customs Enforcement (ICE). In addition, you must also submit proof of foreign citizenship. Documentation that is not in English must include a notarized translation.

What is the Social Security Number (SSN) requirement?

If you are applying for an original MMC, then you must establish proof of having a Social Security Number (SSN). Acceptable proof is a Social Security Card issued by the Social Security Administration (SSA). When submitting your application package for evaluation, you must submit a copy of your card. You must present the original card prior to issuance of an MMC. Your card must bear the same name appearing on your proof of citizenship and your application. If you have lost your card, you must apply for a duplicate card from the SSA. If you present a duplicate card or letter from the SSA, it must have your SSN on it. Plastic, metal or laminated cards are not acceptable.

Physical Requirements and Drug Requirements

Medical Downloads and Forms:
  • Physical Exam Report (submit pages 3-4): CG-719K
  • Certification of Fitness for Entry Level Ratings: CG-719K/E
  • Medical and Physical Evaluation Guidelines: Medical NVIC USCG 2006-25080
  • Medical Waiver Submission Form: MLD-FM-REC-171
  • Article Regarding the Importance of Physical Evaluations: NVIC Outreach Article March 2007

When is a physical examination required?

The table below lists when a physical examination is required for renewal:

Credential to be renewed: Physical examination required?
License: Yes
Certificate of Registry1: No1
Merchant Mariner's Credential (with qualified rating other than Lifeboatman): Yes
Merchant Mariner's Credential (with Lifeboatman or without qualified rating)1: No1

Note:

1. If you are renewing a Certificate of Registry, Merchant Mariner's Credential (MMC) with Lifeboatman, or MMC without qualified ratings and you plan to serve on a seagoing vessel beyond the boundary lines, then you need to provide proof of physical agility, strength, and flexibility. For more information, see Section D below.

What is required for a physical examination?

If you are renewing a License or a Merchant Mariner's Credential with a qualified rating other than Lifeboatman (LBMAN), then you must submit an original physical examination report ( Form CG-719K ) completed by a U.S. Licensed physician, physician's assistant, or nurse practitioner within one year of the application. This report must certify that you are in good health and have no physical impairment or medical condition which would render you incompetent to perform the ordinary duties allowed by your credential. Please ensure this form has been completed entirely. Delays in approving applications are frequently the result of incomplete physical examination reports. For example, if you are taking any medications prescribed by your physician, then your physician must have all of the medications disclosed in block 15 of the form with a statement regarding whether or not you experience any side effects from them. If side effects are experienced, they must be listed. If no side effects are experienced, then a statement to that effect must be included.

What are some examples of the physical examination standards?

Renewal of a License as deck officer or Merchant Mariner's Credential as Able Seaman (AB) or Tankerman (TKMAN): You must have uncorrected vision of at least 20/800 in each eye, correctable to at least 20/40 in each eye. You must also possess normal color vision as determined by one of the methods listed on the CG-719K Physical Examination Report. Renewal of a License as engineer officer or Merchant Mariner's Credential as Qualified Member of the Engine Department (QMED): You must have uncorrected vision of at least 20/800 in each eye, correctable to at least 20/50 in each eye. However, you only need to possess the color sensing ability to distinguish between red, green, blue and yellow. For renewal of all licenses or Merchant Mariner's Credentials with qualified ratings other than Lifeboatman, you must not have blood pressure higher than 160/100 if under the age 50 or higher than 175/100 if over 50, regardless of treatment or medication.

If you want more information on the Coast Guard's physical examination standards, connect here to NVIC 2-98

What are the physical agility, strength, and flexibility standards?

If you are renewing a Certificate of Registry, Merchant Mariner's Credential (MMC) with Lifeboatman, or MMC without qualified ratings, you are not required to submit a physical examination report (Form CG-719K). However, if you plan to work on seagoing vessels beyond the boundary lines, you will have to submit documentation from a U.S. licensed physician, physician's assistant, or nurse practitioner certifying that you have the agility, strength, and flexibility to:

  • Climb steep or vertical ladders,
  • Maintain balance on a moving deck,
  • Pull heavy fire hoses up to 400 feet, and have the ability to lift fully charged fire hoses,
  • Rapidly don an exposure suit,
  • Step over door sills of 24 inches in height, and
  • Open or close watertight doors that may weigh up to 56 pounds.

What if I don't meet the physical requirements?

Not meeting the vision, hearing, or general physical condition required for renewal does not automatically cause you to be denied. The Commandant of the U.S. Coast Guard may consider you for a physical waiver if extenuating circumstances warrant special consideration. The REC reviewing your application may request that your physician provide additional information to support a waiver in such cases.

What are "dangerous drugs?"

"Dangerous drugs" - under the Department of Transportation rules are: marijuana, cocaine, opiates, phencyclidine (PCP), and amphetamines. Proof that you are free of dangerous drugs is required with your renewal application. Only a screening that tests for the five dangerous drugs is accepted. All tests must be conducted in accordance with "Procedures for Transportation Workplace Drug Testing Programs" in Title 49 Code of Federal Regulations (CFR), Part 40 and done by laboratories certified by the Substance Abuse and Mental Health Services Administration (SAMHSA), an agency of the Department of Health and Human Services. All qualifying random and periodic drug-testing programs must also meet these requirements.

A listing of approved laboratories is also available online at www.drugfreeworkplace.gov. When the main page comes on screen click on "Drug Testing" and then click on "Certified Labs". By contacting one of these labs they will direct you to the collection facility that is nearest to your location

How do I prove that I am free of dangerous drugs?

Acceptable proof of meeting the drug testing requirements can be any one of the following:

A completed drug test form (report or letter) signed by the Medical Review Officer (MRO) or authorized representative of a consortium showing that you passed a chemical test for dangerous drugs conducted in accordance with 49 CFR 40 within the previous six months with no subsequent positive drug tests during the remainder of the six-month period.

A letter on company or consortium stationary signed by the authorized official that administers the drug testing program stating that you passed a pre-employment or periodic test for dangerous drugs within the previous six months with no subsequent positive drug tests during the remainder of the six month period.

A letter on company or consortium stationary signed by the authorized official that administers the drug testing program stating that you have been subject to random drug testing required by 46 CFR 16.230 for at least 60 days during the previous 185 days and did not fail or refuse to participate in any required chemical test.

If you are an active duty U.S. military member, a letter from your command stating that you have been subject to random drug testing for the past six months and have not failed or refused to participate in any required test. Random testing letters are not accepted for reserve military members since they are only subject to testing during monthly drills. However, if you are a reserve or active duty member and passed a required chemical test for dangerous drugs within the previous six months, then you may submit a letter from your command stating this.

What You Need to Know About New PDSD & SA Requirements!

As qualified Security Officers (VSO, CSO & FSO) already know, training of personnel has been an ongoing part of their duties for the last few years.  With the Manila STCW Conference in 2010, the IMO instituted *new additional* requirements to formalize certain aspects of that required training.  The US Coast Guard and BVI authorities (along with over 130 other countries) are now phasing in the additional requirements.

In particular, training of “Personnel with Designated Security Duties” PDSD (both vessel/ship and facility/port), as well as all “other” staff who must meet the lower level “Security Awareness” SA standards are now included.  Those fully qualified as VSO, CSO and FSO already exceed these new requirements by their previous training and Security Officer endorsement.

The US Coast Guard is in the final stages implementing these new STCW requirements which came into effect worldwide 1 January 2012.  Interim measures (CG-CVC Policy Letter No. 12-06) are currently in effect.  Effective 1 January 2014, the IMO (ISPS Code as Amended 2010) specifies full compliance with Regulation VI/6.

The 2010 amendments to the STCW require all mariners serving on a vessel to which the STCW applies to have endorsements for security awareness. All persons assigned specific security duties must have the VPDSD endorsement. (USCG-NMC FAQ Policy Letter 12-06 #6 Dated 6/6/2013)

What does this mean for you?

  1. Both Vessel / Ship and Facility / Port personnel are affected by these new regulations. The good news is that qualified Security Officers (SO) already exceed these requirements!  While PDSD and SA are two separate additional levels of required training, anyone with PDSD certification will exceed the SA requirement so PDSD certification will cover *both* PDSD and SA with just one course.
  2. Examples of someone required to meet the “PDSD” requirement might be an engineer or deckhand on a vessel (and even the Captain if they do not hold SO certification).  On shore it would be a gate guard, security staff, or baggage / cargo handler in a facility.  Included are any persons with security related responsibilities as part of their duties.
  3. Examples of someone required to meet the “SA” requirement would be any others; including cleaners, food handlers, docents, certain vendors and support people, (even many shoreside company staff and officials).  Included are all TWIC holders and certain individuals who interact with vessels or facilities on a regular basis, among others.
  4. Individuals who commenced their service after January 1, 2012 will meet the new training requirements by completing an approved course.  The Captain School now offers a one day Coast Guard approved Personnel with Designated Security Duties course  which meets both the PDSD and SA requirements.  The first training session will be available at our Red Hook Training Facility on Saturday 23 NOV 2013 (call 340-775-2278 to reserve your seat).
  5. For those individuals who commenced their service prior to 1 January 2012 (5.f.2),  CG-CVC 12-06 does include an alternative means for demonstrating PDSD competence where a company official must certify that the employee has one of the following:
    1. 5.f.2.a Seagoing service with “Designated Security Duties” for a period of six months in total during the preceding three years…
    2. 5.f.2.b Performance of security duties considered to be equivalent in scope to shipboard designated security duties for a period of six months…
    3. 5.f.2.c Successful completion of a Coast Guard accepted or approved course…

Similar alternatives for prior service certifications are specified for SA competence under 5.f.3 

It’s important to note for employers who make the official alternative certifications, these are for those employees working prior to 1 January 2012.  Company officials should also be fully aware of what the alternative ongoing security training requirements are, as set forth in their approved Security Plans and by the ISPS and CFR regulations.  A good overview of what is included in the specified training is given in IMO MSC.1/Circ.1341 which is an example for Port Facility Personnel with “SA” (Table 1; page 4) and “PDSD” (Table 2; pages 5-6) requirements.  Vessel Personnel training requirements are similar in scope.

After some of the recent shipping incidents, many employers may find the completion of an approved training course the most efficient method of easily meeting these new STCW requirements. 

Marine Casualties: Report Them!

 In an effort to provide vital information to our U.S. Virgin Islands commercial boating community, Coast Guard Marine Safety Detachment St. Thomas distributed details a few weeks ago regarding the need for proper reporting of marine casualties.  I would like to use this opportunity to get this information to the readers of The Captain School newsletter as well.

The owner, master, operator, or person in charge of a commercial vessel (which includes UPVs) is responsible for immediately reporting a marine casualty consisting in:

  • An unintended grounding
  • An intended grounding that creates a hazard to navigation or affects the safety of the vessel
  • A loss of main propulsion or steering that reduces the maneuverability of the vessel
  • An incidence, such as fire or flooding, that adversely affects the vessel’s seaworthiness
  • A loss of life
  • An injury that requires treatment beyond first aid (first aid is defined in 29 CFR 1904.7)
  • An occurrence causing property damage in excess of $25,000
  • An occurrence causing significant harm to the environment as defined in 46 CFR 4.03-65

 The Coast Guard tries to make the burden of reporting as easy as possible.  A simple VHF channel 16 call or a cell phone call to the 24-hour Coast Guard Sector San Juan Command Center at 787-289-2041 satisfies the reporting requirement.  You can even email the Command Center at This e-mail address is being protected from spambots. You need JavaScript enabled to view it .  In some cases, Command Center personnel may instruct you to fill out a CG-2692 report within five days of the casualty, or to take an alcohol or drug test if the casualty is determined to be a Serious Marine Incident (SMI).

 I frequently hear mariners tell me that they are worried to report because they fear the Coast Guard will pursue some sort of enforcement action against them for the casualty.  My primary job as a Coast Guard Investigating Officer is to determine any causal factors that may have led to the casualty.  I understand that accidents happen on the water and I am not going to issue you a ticket for telling the Coast Guard about them.  I will most likely contact you following the casualty to ask you some questions about what happened and get your perspective about the root cause of the casualty, which often points to defective parts.  If my investigation reveals faulty parts or marine equipment, I contact the manufacturers of those parts, boat builders, and supply outfits to communicate the need to get these products off the shelves.  Thus, your report directly increases safety for the marine community at large.  This is why the Coast Guard needs you to tell us when casualties happen.  We must communicate!

 Unfortunately, my secondary job is to take enforcement action when I discover that a casualty went unreported.  The commercial vessel fines are steep: For a first offense, I issue a $5000 ticket.  If you simply report the casualty, you are protected from this fine and the Coast Guard will help you through the rest of your legal obligations (i.e. drug testing), if any are required.  Please, report the marine casualties listed above to Sector San Juan immediately after addressing any resultant safety concerns following the accident.  A good rule of thumb: If you’re unsure if you should report it, protect yourself by reporting it and let the Coast Guard direct you through the process.

 LT Luke Elder

Marine Safety Detachment St. Thomas
St. Thomas, VI 00802

Upcoming Classes

2017 COURSES 

September 2017

4-16 OUPV Captains License (Nights / Weekends) $800

11-15  STCW Basic Safety Training $1200 (5 Day)

18-22 Upgrade to Master (Nights ) $300

25 Aux Sail (1 Night) $125

26 Assistance Towing Endorsement (1 Night) $125

27-30  Management & Leadership $1200

 October 2017

2-14 OUPV Captains License (Nights/Weekend) $800

2-6 STCW Basic Safety Training (5 Day) $1200

9-11 Medical Care Provider $750

16-20 Upgrade to Master (Nights ) $300

21 Aux Sail (1 Night) $125

22 Assistance Towing Endorsement (1 Night) $125

25-29 STCW Basic Safety Training (5 Day) $1200

30 Crowd Management (1 Day) $250

31 Oct-2 Nov Bridge Resourse Management ($900)

November 2017

3-7 STCW Basic Safety Training (5 Day) $1200

6-18 OUPV Captains License (Nights/Weekend) $800

27-Dec 1 STCW Basic Safety Training (5 Day) $1200

Dates Subject to Change

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Training Flow Chart

Certifications Required for Crew-

Working on 6 passenger boats in the USVI

-CPR & First Aid

-Random Drug Testing Program

-add TWIC (from TSA) if entering secure port areas in US & BVI

Working on 6 Passenger Boats in the BVI

-add: STCW Basic Safety Training

Working On Vessels with more than 12 passengers in BVI

-add: STCW Crowd Managment

-add TWIC (from TSA)

Additional: Helpful but not required by Law

-STCW Crisis Management

This information is not intended to answer all questions regrading licensing- use it as a guide only- information subject to change. Call for a personal consultation 340-775-2278

Certifications Required for Captains-

Operating 6 passenger boats in the USVI

-USCG OUPV Near Coastal License

-CPR & First Aid

-Random Drug Testing Program

-FCC Marine Radio Operator Permit

-TWIC Card (TSA.gov)

Operating 6 Passenger Boats in the BVI

-Add: Master Upgrade to 50 or 100 Gross Ton Master Near Coastal

-add: STCW Basic Safety Training

-add: BVI Boatmaster License (from BVI Shipping)

-add: STCW Endorsement on License II/3

Operating Vessels with more than 12 passengers in BVI

Same as above and

-add: STCW Crowd Managment

-add: STCW Crisis Management

-add: Vessel Security Officer

This information is not intended to answer all questions regrading licensing- use it as a guide only- information subject to change. Call for a personal consultation 340-775-2278