Several of my friends are now in the throws of renewing their MMD's and Captains and Mates licenses. Without exception, they are frustrated, angry, and at wits' end.
One guy had to suffer through three days of stress tests because a few years earlier he had gone to a doctor for an arrhythmia. The guy was put on medication for a brief period, but the issue basically resolved itself after the guy cut out half his coffee. The "arrhythmia" was, however, still in his chart. Oops! This same guy also went to a sleep clinic to see about his snoring. Apparently, HUGE mistake, because he ended-up with the words "potential sleep apnea" in his chart. Guess what? The C.G. told him he had to go back to the sleep clinic for three days of testing to get a doctor to sign off on the potential sleep apnea. Incidentally, this guy works for the state, so the cost for these six days and nights of testing were paid for by the insurance company, i.e. the taxpayer.
Two other friends discovered their STCW certifications on their MMDs were going to lapse and not be renewed. Why? Because, even though both of these guys are full time professional mariners who work on tugs and ferries, they work inshore (inland) routes as designated by the COLREGs demarcation lines, which, as we all know, are geopolitical boundaries that have almost no practical relationship to weather, wind or sea state.
The U.S. has one of the most heavily regulated Merchant Navies in the world, and yet we're being asked to comply with international laws so that other countries professional mariners can be brought up to higher standard. And because we can't get the IMO to acknowledge that the same drills and training used by ships at sea are used (and have been used for years) by U.S. vessels operating in inland waters, experienced and knowledgeable merchant mariners in the U.S. are losing their ratings and certifications.
Slowly but surely, the IMO (the International Maritime Organization), is whittling away at the Merchant Marine Corp of the Unites States of America. And with congressional approval, too. Trust me, if the liberals and globalists in our government get their way, and they shave the teeth off the Jones Act, it won't be long before foreigners start manning the decks, wheelhouses and bridges of our inshore fleets. U.S. mariners will be pushed out of the way by out-of-control regulation, incomprehensible renewal instructions, ham-fisted bureaucrats and knee-jerk legislation.
My MMD and Master License doesn't expire for two years, but I'm heeding the warning and I think you should, too. Here's my advice:
1) If your life depends on your job, don't go to the doctor. There's not much point in having the doctor give you blood pressure meds or some other drugs and then have the Coast Guard come back in two years and say, "Oh, sorry, we can't give you your license back. You might have a heart attack at the helm." But, of course, it's OK to drive your car on some highways at 80 mph, or fly your Cessna across country. And it's OK if we give your job to a twenty-three year old who just got his captain's license and has almost no real experience.
2) Before sending in the paperwork for your renewal, make sure you have everything there. To get your STCW you'll need about one year out of five years of documented sea time in Near Coastal Waters. Inshore/Inland waters won't suffice, even though we both know -- from an STCW perspective -- there is no difference between working and training inside of the three mile limit and working and training outside of the three mile limit. Think about it, STCW - Basic Safety Training: Elementary First Aid, Fire Prevention/Fire Fighting, Personal Survival Techniques, and my all time favorite, Personal Safety and Social Responsibilities (e.g. how to wash your hands with soap and water while singing the Happy Birthday song, and how not stare at the first mate's tits when you're talking to her) . . . Come on! These things are exactly the same inshore as they are offshore.
Oh, and how well is the IMO's STCW plan working? Let's see. There's the Costa Concordia. And the other Costa ship, the one that went adrift after an engine room fire. How many ferries in the far east have capsized and sunk lately?
3) If you have an endorsement or a second rating, such as a Master of Auxiliary Sail or a Master of Towing, but you no longer work on a sailing vessel or a towboat and haven't for five years, then you won't have the sea time to renew those licenses. The best thing to do, if you want to keep those licenses, is place them In Continuity. This means they can stay in your file and if need be you can re-acquire them. I'm not sure how you would do this. You may have to retest, or re-aquire the sea time. Whichever, you need to fill out another application that requests that the C.G. Examiner place these ratings or certificates into Continuity.
4) If you want to hold onto a master of towing license or endorsement, and you can't supply the Coast Guard with a letter from a company stating clearly that you have been working for five years in this capacity, have participated in all drills and training and have accumulated 360 days of sea time in the last five years, you're screwed. Because if you can't get this letter, you'll need an Approved Designated Examiner to sign a statement confirming you are competent to perform all the duties required of you in the given rating. What is an Approved Designated Examiner? I don't know. Neither, apparently, does Peggy at the U.S. Coast Guard's National Maritime Center. I asked her yesterday and she said the Coast Guard does not have a list of Approved Designated Examiners. This is interesting, because the Coast Guard sent my friend a letter stating they were giving him 90 days to find one of these examiners and complete the renewal application process.
I suppose some of this makes sense to somebody. Clearly, you want a person at the helm of a tug and fuel barge who knows what he or she is doing. But what does In Continuity mean? If you need a job with a tug company, can you use it to get the job and then re-establish your certificate? I don't see how. Having the endorsement or the license In Continuity doesn't mean you can legally operate with it. So why would anyone hire you? They're not going to hire you at a captain's or mate's wages just so you can accumulate 360 days of sea time. Do you have to hire one of these mysterious Approved Designated Examiners, rent a 4,000 hp tug and an empty fuel barge and drive it around for a while?
For me, the writing is on the wall. Washington wants to eviscerate this country's merchant fleet and open domestic shipping to foreigners.
OK, rant off. Back to regularly scheduled programming.