Marine Link
Monday, September 25, 2017

Another Licensing

August 31, 1999

As discussed in a recent article, the USCG is now talking openly about centralizing the nationwide administration of the licensing and certification of seamen and officers into one location (the actual examinations will be "privatized"). They speak of the success they have had performing this feat for the vessel documentation offices and now want to repeat if for the licensing system. Obviously, they have forgotten the problems that occurred with the centralization of vessel documentation and for reasons of their own are reluctant to admit they will probably have serious problems with this new venture because of the different clientele. In 1995, the USCG centralized the vessel documentation process into one office located in Falling Waters, W.V. The original plan had called for reducing the number of documentation centers from 15 or so offices around the country to four and then after 10 years to consolidate into one office. It is not clear why the USCG did not stick to the original plan. Speculation is it was probably some budgetary need, i.e. the greater the reduction in employees used in vessel documentation, the more money could be spent elsewhere, presumably where the USCG wanted to spend it. Shipbuilders and vessel owners along the Gulf Coast insisted the USCG keep the New Orleans documentation office open with a token staff to be capable of responding to various quick turnaround issues in order to prevent delaying the sailing (foreign) of a vessel. After all, the USCG documentation offices act as the county courthouses for vessels and record important monetary transactions. At the time of consolidation, terrific and almost unmanageable backlogs occurred. This was in part due to large backlogs that had been present in many ports. Relocation of the records from the various individual ports caused confusion. Computerization did not work as well in all aspects of the consolidation as had been promised. Professional personnel also became a problem, as many documentation officers would not relocate to West Virginia. Training then became an obvious problem. Most customers of the new documentation center speak of serious problems, delays, and horror stories they have encountered over the first years of operation. As an example, the vessel documentation center answers the phone with a voice mail system. I personally (two years ago) left more than 10 telephone messages pleading for a real person to speak with to help me. Out of all the messages I left at the time, only one was affirmatively responded to and that was 12 days after the message was left. The archiving activities the USCG is required to maintain have become extremely difficult, if not impossible, to access in many cases. To its credit, the USCG has been able to overcome many of the problems that occurred and today seem to provide timely, reasonable service, at least to most customers. Many of the problems that occurred in the first year or two of operation have been overcome. It would seem the USCG believes they can overcome the problems they would encounter with centralizing the licensing offices in the same manner they dealt with the vessel documentation. I believe they are wrong. In case they haven't noticed, seamen are different than vessel owners. Vessel owners are generally more focused on self-interest than are seamen and licensed individuals. Vessel owners could survive a serious disruption of vessel documentation services for a period of years without causing them to "quit the trade". I'm not sure the same is true for seamen and licensed officers. Remember a seaman and a licensed officer cannot ply their trade if they cannot renew their z-card (Merchant Mariners Document) or license. The same is not true for a vessel owner. Today, all seamen and licensed officers must renew their documents and licenses every five years in order to continue to sail. The USCG, in general terms, does not treat seamen or licensed officers with respect, as USCG management is not made up of personnel that have sailed in the maritime. Any disruption in the ability to conduct the mandatory renewals will mean these potential crewmen are not available to go to sea. As a consequence vessel operators will have even more trouble finding licensed and unlicensed personnel to man their vessels. They will no doubt apply pressure to our government to solve their problem. This can be done using often-overlooked provisions of the Kuwaiti Tanker legislation (1988). This act provides the U.S. citizenship requirements for U.S. flag vessels may be waived by the Secretary of Transportation or the President if, after an investigation, it is determined qualified seamen who are U.S. citizens are not available. Seamen and licensed officers whose authority to go to sea cannot be effectively renewed, are not technically qualified to go to sea. The decision to waive the citizenship requirements is political and not a part of USCG responsibility. No action by the USCG is necessary, or for that matter, possible. It would clearly be an issue beyond their control. It does not take a change in law to "solve" the problem. This could happen under current U.S. law. We could easily find foreign seamen and licensed officers manning our vessels engaged in domestic, inland and international trade. Once we allow foreign seamen and licensed individuals to sail on U.S. flag vessels in domestic waters, I do not believe we will ever get them off our vessels. Is there an agenda here? Does someone want the USCG to make licensing and documentation more difficult? While the USCG freely acknowledges the licensing system is broken, they also freely acknowledge they do not know how to fix it. They seem to believe they can change it radically to suit their needs because it doesn't work properly today. To change from one system that doesn't work to another system that doesn't work is not a serious problem for them. We have been told, after centralization, the USCG will concentrate on finding out how to repair the system. It seems to me, by then, it could be too late. Charley Havnen is a Commander USCG Ret. His organization can help with owner's representation, vessel construction projects, regulatory problems, vessel manning issues, procedure manuals, accident analysis or expert witness. He can be reached by contacting the Havnen Group 800-493-3883 or 504-394-8933.
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