Cummings on Maritime Credentialing

Friday, July 10, 2009

In a prepared statement for Congressman, Elijah E. Cummings (D-Md.), Chairman of the House Subcommittee on Coast Guard and Maritime Transportation, addressed a hearing on The National Maritime Center and Maritime Credentials. A live webcast of the hearing is available at http://transportation.house.gov.

“We convene today to review the operations of the National Maritime Center and the issuance of merchant mariner credentials.

“Over the past 18 months, the Coast Guard has consolidated the credentialing functions that were previously provided at 17 Regional Exam Centers into the National Maritime Center – and the Center opened at a new facility in West Virginia.

“The Coast Guard has also made significant changes to the actual credential that it issues.  Specifically, it has consolidated the licenses, documents, certificates of registry, and endorsements that it previously issued as separate items into a single new Merchant Mariner Credential, which is essentially a passport-sized booklet. MMCs began to be issued on April 15th of this year.

“Finally, the Coast Guard has issued new guidelines to govern the type of medical information mariners are required to submit at the time they apply for a new or renewal credential as well as the specific review processes to which this information will be subjected to assess mariner fitness for duty.

“Each one of these changes is a significant alteration in the way the Coast Guard manages mariner licensing and I am hopeful that each change will, over the long term, significantly improve the licensing process and the services provided to mariners.

“That said, these hoped-for improvements have not yet been realized.  To be frank, it appears that the Coast Guard did not adequately plan all aspects of the consolidated credential production process and the roll-out of the MMC – and this has led to extensive delays in the issuance of credentials. 

“Further, as one specific area of delay has been resolved, subsequent bottlenecks have developed – and it appears that no significant progress has been made in speeding credential processing times.

“In fact, in a report issued on January 22nd, the Coast Guard indicated that the average gross processing time between July 2008 and January 2009 – meaning both the time required by the Coast Guard to process an application and the time the service waits for a mariner to provide additional information – totaled 83 days. 

“Fifty percent of the credentials issued during this period were processed in under 52 days. Looking just at the time that it took the Coast Guard to process an application – and excluding all time spent waiting for a mariner to provide additional information – the Coast Guard reported that its average processing time in that period was 41 days, and that 50 percent of credentials were processed in 31 or fewer days.

“By comparison, in a report issued on June 29, 2009, the Coast Guard reported that average gross processing time for a credential between the beginning of 2009 and June 23rd was 80 days, while 50 percent of credentials processed during that period were processed in 54 or fewer days. 

“That same report indicated that the length of time required by the Coast Guard itself in that period to process an application was 48 days, and only 35 percent of credential applications were being completely processed in 30 or fewer days.

“In other words, between January and June 2009, total processing time remained in the 80-day range – and it was actually taking the Coast Guard itself longer to process credential applications in the January to June 2009 period than in the six months leading up to January 2009.

“A credential is a mariner’s ticket to work.  If the mariner does not have that credential – for whatever reason – the mariner cannot work. 

“Unfortunately, the Subcommittee has heard of instances in which mariners’ credentials have expired before a renewal application could be fully processed – and these mariners have been left without an income while they were waiting for the bureaucratic wheels to grind.

“This is simply unacceptable.  Given all that we are doing to stimulate our economy and to support the growth of jobs, it is inexcusable that any person should be out of work because the government cannot process a professional credential in a timely manner.

“I look forward to hearing from Admiral Cook, the Coast Guard’s new Director of Prevention Policy, and Captain Stalfort, the Director of the National Maritime Center, specifically what is being done to ensure that the new credential processing systems finally yield real benefits to mariners.

“As I mentioned, the Coast Guard has also instituted new guidelines regarding the assessment of mariner fitness for duty.  This guideline, known as Navigation and Vessel Inspection Circular 04-08, is intended to provide the level of specificity regarding mariner fitness for duty that previous guidance and even statute and regulation have lacked.

“The NVIC was the product of extensive work and consultation – and the National Transportation Safety Board indicated in its report on the Cosco Busan accident in San Francisco that it is “responsive” to much of what the Board called for in recommendations made after the 2003 allision of the Staten Island Ferry. 

“Nonetheless, despite this improvement, there remain issues related to the assessment of a mariner’s fitness for duty that we look forward to examining today. 

“Currently, pilots are required to submit to the Coast Guard the results of annual physicals.  However, most mariners submit medical exam results only once every five years when they seek the renewal of their credentials.

“In its report on the Cosco Busan incident, the NTSB noted that the Coast Guard has not moved to require mariners to report changes in their medical condition during the 5-year period between credential renewals as the Board had recommended after the Staten Island Ferry accident.  We wish to understand why this recommendation remains unaddressed.

“Additionally, in its marine casualty investigation report on the Cosco Busan incident, the Coast Guard Senior Investigating Officer recommended that ‘the Commandant of the Coast Guard amend the existing standards in Marine Safety Manual (MSM) Volume III, for medical professionals performing mariner physicals, to ensure that physicals are performed only by designated physicians with a thorough understanding of the physical and mental demands of a mariner’s position.’

“The Coast Guard responded to this recommendation by stating that “we believe the guidance provided in NVIC 04-08 is sufficient to provide medical professionals with the necessary understanding of the occupational demands of mariners to perform marine physicals” and that the service therefore does not intend to change its requirements regarding the medical personnel who perform mariner physicals.

“We look forward to examining these and related issues in more detail today – and we look forward to the testimony of industry witnesses assembled on our second panel, who will provide a variety of perspectives on these issues.”

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