Posted:
August 20, 2012
The following is excerpted from a letter sent to Department of Homeland Security Secretary Janet Napolitano Aug. 15 by American Maritime Officers National President Thomas Bethel, Seafarers International Union President Michael Sacco, Marine Engineers' Beneficial Association President Mike Jewell and International Organization of Masters, Mates and Pilots President Timothy Brown.
As presidents of our respective maritime unions, we represent the crew members of virtually all of the U.S. flag commercial ships in international trade. We wish to express to you our frustration with the lack of progress made by the U.S. Coast Guard in implementing the 2010 amendments to the International Standards of Training, Certification and Watchkeeping (STCW) Convention and Code.
The STCW Convention and Code contains mandatory standards for the training and certification of mariners working on board ships in international trades. The Code also regulates the hours of work and the hours of rest for these mariners in an attempt to avoid fatigue related accidents. The 2010 amendments to the STCW Convention and Code were adopted in 2010 and became effective on January 1, 2012, and allow for a five-year phase in period for the new provisions. Furthermore, new seafarers entering the industry as of 1 January 2013 are required to commence training in accordance with the 2010 amendments. Given the magnitude and scope of these new amendments, the transition period requires very aggressive implementation on the part of our industry.
The amendments to the Convention and Code are not self-executing and in the United States require implementation by aligning current U.S. Coast Guard regulations to the new international requirements. The Coast Guard published an NPRM in 2009 and an SNPRM in 2011 to implement the STCW requirements. The U.S. Coast Guard sought input from the Merchant Marine Personnel Advisory Committee (MERPAC) during the amendments negotiations at the International Maritime Organization (IMO). For the past two years, the U.S. Coast Guard has been meeting with maritime industry representatives in MERPAC to develop new standards to bring U.S. law into compliance. However, at the present time, the U.S. maritime industry still does not have a definitive interpretation of the international requirements by the U.S. Coast Guard providing the specific details needed by our individual maritime training facilities to plan for and implement the new training requirements.
The inexcusable delay in implementing the internationally required training, credentialing, and work/rest hour provisions is unacceptable and brings into question the ability of the U.S. Coast Guard to publish regulations in a timely fashion to further safety, security and environmental protection. This issue has been the subject of a Congressional hearing in the past and the Commandant of the U.S. Coast Guard at the time assured Congress that steps were being taken to address the situation. The U.S. Coast Guard's inability to implement the 2010 amendments to STCW Convention and Code in a timely manner is totally inexcusable.
As the Secretary of the department in which the U.S. Coast Guard operates, we are asking you for your full attention to implement these new provisions before the end of the year. Any further delay places the U.S. flag maritime industry trading internationally in jeopardy, causes our U.S. mariners' credentials to be called into question, and leaves our training centers and academies in limbo.
Seagoing labor urges action on U.S. Coast Guard implementation of 2010 amendments to STCW Convention
The following is excerpted from a letter sent to Department of Homeland Security Secretary Janet Napolitano Aug. 15 by American Maritime Officers National President Thomas Bethel, Seafarers International Union President Michael Sacco, Marine Engineers' Beneficial Association President Mike Jewell and International Organization of Masters, Mates and Pilots President Timothy Brown.
As presidents of our respective maritime unions, we represent the crew members of virtually all of the U.S. flag commercial ships in international trade. We wish to express to you our frustration with the lack of progress made by the U.S. Coast Guard in implementing the 2010 amendments to the International Standards of Training, Certification and Watchkeeping (STCW) Convention and Code.
The STCW Convention and Code contains mandatory standards for the training and certification of mariners working on board ships in international trades. The Code also regulates the hours of work and the hours of rest for these mariners in an attempt to avoid fatigue related accidents. The 2010 amendments to the STCW Convention and Code were adopted in 2010 and became effective on January 1, 2012, and allow for a five-year phase in period for the new provisions. Furthermore, new seafarers entering the industry as of 1 January 2013 are required to commence training in accordance with the 2010 amendments. Given the magnitude and scope of these new amendments, the transition period requires very aggressive implementation on the part of our industry.
The amendments to the Convention and Code are not self-executing and in the United States require implementation by aligning current U.S. Coast Guard regulations to the new international requirements. The Coast Guard published an NPRM in 2009 and an SNPRM in 2011 to implement the STCW requirements. The U.S. Coast Guard sought input from the Merchant Marine Personnel Advisory Committee (MERPAC) during the amendments negotiations at the International Maritime Organization (IMO). For the past two years, the U.S. Coast Guard has been meeting with maritime industry representatives in MERPAC to develop new standards to bring U.S. law into compliance. However, at the present time, the U.S. maritime industry still does not have a definitive interpretation of the international requirements by the U.S. Coast Guard providing the specific details needed by our individual maritime training facilities to plan for and implement the new training requirements.
The inexcusable delay in implementing the internationally required training, credentialing, and work/rest hour provisions is unacceptable and brings into question the ability of the U.S. Coast Guard to publish regulations in a timely fashion to further safety, security and environmental protection. This issue has been the subject of a Congressional hearing in the past and the Commandant of the U.S. Coast Guard at the time assured Congress that steps were being taken to address the situation. The U.S. Coast Guard's inability to implement the 2010 amendments to STCW Convention and Code in a timely manner is totally inexcusable.
As the Secretary of the department in which the U.S. Coast Guard operates, we are asking you for your full attention to implement these new provisions before the end of the year. Any further delay places the U.S. flag maritime industry trading internationally in jeopardy, causes our U.S. mariners' credentials to be called into question, and leaves our training centers and academies in limbo.