Our jobs on the water are full of risks, great and small. We constantly must evaluate and make judgments about what the level of risk is for any given activity, what the consequences might be if things don’t go as planned, consider what measures we can take to eliminate or minimize those risks, and then act accordingly, adjusting all the while as circumstances dictate in our fluid and ever-changing work environment.

Last week I posted about some excellent new foul weather gear that has recently come on the market. A sharp reader correctly pointed out via a comment that modern synthetic fabrics can be susceptible to building up a charge of static electricity, which merits some concern for the explosion risk from a subsequent electrostatic discharge. Personally, unless your cargo is particularly volatile or otherwise dangerous (gasoline, naphtha, benzene, coal dust, grain dust, etc.), I’m not terribly worried about it. Except for tankermen regularly leaning over the tank tops the risk-level would generally be infinitessimally small. Even then, I’d be more worried about whether or not they were following procedure to make sure the gauging tape was properly grounded while they’re strapping the tanks. But good risk-management practices require that you must still consider all of the possible consequences, which in a worst case-scenario explosion could be enormous. Sometimes relatively low-risk hazards have stunningly terrible costs if your luck runs out and the associated high-consequence event occurs. Remember the leaky O-rings of the Space Shuttle Challenger? So here is some more information to consider when choosing what you wear while you work.  

When deciding on what work wear you should buy keep in mind the general tenets of the layering system, which consists of the base layer, the mid or insulation layer, and the outer or shell layer.

The Base Layer: cotton has long been known as a killer. Although very comfortable and breathable it very readily absorbs moisture (which is why it’s used for towels), is slow to dry, and loses all of its insulating capabilities when damp or wet, therefore making it hypothermia-inducing. Consequently, as a base layer in cool to cold weather, or in any survival situation, it should be avoided like the plague.  That leaves you with two other choices: natural wool or synthetics like polypropylene or polyester, and I will pick wool (specifically, Merino wool) every time. It costs more and may be somewhat less durable if the base layer is worn as outerwear, but it’s superior in every other way, especially concerning safety. It is static-resistant and is by far the preferred choice for all occupations where exposure to fire is a risk (read: all mariners). Bonus: if it does catch on fire it chars rather than liquifies, so it won’t melt into your skin and flesh. Beyond that, Merino wool is smooth and stretchy, has a broad temperature comfort range, insulates when wet and is stink-resistant. Light and ultra-lightweight varieties are available for summer use.

The Mid Layer: it is at the mid layer that I’ll start using synthetics. Polyester and polypropylene have the best warmth-to-weight ratio and, like wool, also insulate when wet. They also wick moisture well and dry very quickly. Although all of the synthetics can be static prone, in my experience it is usually the thick, fur-like polyester fleeces that are the biggest culprits in building up a potentially dangerous static charge. In any case, this is a problem primarily for tankermen because of their tank gauging duties. Tug crew members generally aren’t going to be in a position to worry about this, but if in doubt just stick with wool.

The Shell Layer: before the invention of the modern petrochemical-based foul weather gear that we’re all accustomed to, usually made of cotton or synthetic canvas laminated with PVC for waterfroofing (polyvinyl chloride, which is some seriously bad stuff: remember that toxic new shower curtain-stink?), mariners wore what were and sometimes still are called oilskins. Originally made of oil or paraffin wax-impregnated cotton canvas, they were state-of-the-art for their time. They still exist, because they still work, and the modern versions are more user-friendly than ever.

If after careful deliberation you’ve concluded that the wearing of synthetics is inadvisable because of your particular circumstances, MTVA-approved foul weather gear manufacturer Grundens just happens to make two items that may fit your needs. The highly water-resistant cotton Canvas Workwear Hooded Parka and the waxed cotton duck canvas PT Mackey Retro Work Shirt. I’ve personally worn the parka while doing tree work at home and can attest to its quality. Give them both a look. Filson, of Seattle, Wa., also is known for its logger-quality oil-finish coats and jackets. Their heavy-duty waxed-cotton tin cloth line is as tough as you’ll ever find. If wool is what you need for base, mid/insulation, or outer layers they’ve got that too, and many of their coats and jackets are designed to be paired with their zip-in wool vests or jackets (available in four weights) for insulation. Many people are unaware that in dry and windy to drizzly conditions a heavy sweater can be the best choice. Woolrich, of course, is also a place to look for all things wool. Smartwool, Patagonia, and Ibex are all known for their high-quality merino wool base layers.

None of these items are inexpensive and you shouldn’t expect to find them in your local Walmart. The prices of some of the items, in particular the merino wool base layers, may absolutely astound you. But they last and perform like they’re supposed to and there are no cheap or mid-priced alternatives that are anywhere near as good. As with many things, you get what you pay for. It all depends upon how much your personal safety and comfort on the job is worth to you.

 

Bellevue Range Rear Light: Autumn sky over the Christina River in Wilmington, De.

For the full story on this 100 year old Delaware River landmark click here.

Spring has officially sprung, so it’s time to update you on some new foul weather gear developments.

Grundens makes some great rain gear but, notwithstanding Bering Sea crabbers and other commercial fishermen, not everyone needs or wants gear as heavy-duty as their best commercial-grade stuff. The heavy-duty PVC-coated fabric doesn’t breathe at all, so if you are involved in activities requiring moderate to heavy exertion you will sweat yourself up pretty quickly, even in winter. This can be almost as unpleasant, and just as bone-chilling, as getting soaking wet from the outside. Also, conventional rain gear doesn’t give and can be very constricting and cumbersome, sometimes dangerously so, especially for climbing up ladders. Outdoor clothing manufacturers have been making jackets and pants out of new technical fabrics known as “soft shells” for years now. The modern types are made from nylon, polyester or hybrid fabrics that are wind and water-resistant, to widely varying degrees, depending upon what type of activity and level of exertion they’re meant to be used for. There are always trade-offs: nylon is tougher but is also hydrophilic, while polyester is less durable but more breathable, very stretchy and hydrophobic. And generally, the more wind and water-resistant they are the less flexible and breathable they’re going to be. But those are all relative terms. Great advances have been made in recent years and in both categories performance can be excellent. Soft shells are, however, not really considered to be truly waterproof like the “hard shell” fabrics (for more information about layering, technical fabrics and their uses click here), but the most water-resistant types (seam-taped on the inside) are more than adequate for almost all situations other than continuous long-term exposure to sustained downpours. Even then, leakage tends to be minor. In my experience, 90% or more of your rain and snow protection needs can be very well met with a good soft shell jacket.

And now Grunden’s has gotten into the “technical fabrics” market for us commercial mariner-types with their Weather Gage softshell jackets. They’re very lightweight and stretchy, reasonably durable, highly water and wind-resistant, and yet still have enough breathability to avoid the rain forest-effect inside during all but the heaviest sustained work. The stretch fabric really stretches, so it doesn’t interfere with things like climbing up pigeon holes, scrambling up onto docks and around obstacles, or throwing mooring and heaving lines: all things that conventional rain gear isn’t terribly good for. The polyester fabric is also fine enough, and knit tight enough, that it has proven to be much more snag-resistant than I initially thought it would be. There’s no question that soft shells, by their very nature, can’t possibly be as durable as hard shells, let alone the old-school, heavy-duty PVC-coated gear. But most who try them wind up agreeing that the compromise is worth it for the benefits gained. I bought the hooded version in late fall of last year and, so far, it has met my expectations in every way. It’s very comfortable and, except for rare occasions, I won’t be needing anything more for rain or snow protection. As for sizing, at 6’3″ and 195 pounds the XL fits me just right while still leaving plenty of room for adequate winter layering underneath without it getting too tight.

Grunden’s has also expanded into general industrial work wear with some products that should cross over very well for our needs. Their hard shell Weather Boss line (jacket, parka and pants) seemed like the perfect choice for conditions that require either 100% waterproofness and/or the very highest level of toughness and abrasion resistance, so I bought both the jacket and pants at the same time as the hooded softshell. Pants always seem to get beat up the most, especially the seat, knees, and cuffs, so I don’t know that softshell pants (if they ever do decide to make them) would really be durable enough unless they were carefully made with strategically-placed heavy nylon reinforcements in those areas for extra protection. In any case, I now wear the hard shell pants with the hooded softshell whenever I’ll be out in light to moderate rain for an extended period, otherwise I just wear the soft shell alone. I keep the hard shell jacket on standby for whenever the worst conditions warrant it. That being the case, neither the pants or jacket have seen much use in the short time I’ve owned them. What I can say is this: the Weather Boss line has every appearance of being exceptionally well-made, with extremely tough nylon shell material that seems to be as strong as any I’ve ever seen, including the very best high-altitude mountaineering shells. If they hold up like they should, given their construction and materials, I won’t be replacing them for a long, long time.

As it happens, Hamilton Marine is having a major sale on all of them right now (scroll down the page about halfway to find them), along with much of their other commercial-grade Grunden’s and Guy Cotten foul weather gear, through next Saturday, April 11th. The hooded soft shell jacket, at just $107.99 (versus the normal $169.00), is a steal at this price. The Weather Boss parka (reduced to $83.69 from $130.00) and pants (reduced to $83.69 from $127.00) are also excellent bargains. If you’ve got the cash, now is a great time to get the best gear available for the same price as the inferior stuff.

One important thing to remember maintenance-wise about modern waterproof or water-resistant clothing: they are all treated with some sort of water-repellant finish, like NIKWAX. And like the finish on a car, over time dirt and oils will build up on the surface of these treated fabrics (hard and soft shells alike) and water will no longer just bead up and roll off like it did when new. In most cases a good washing will restore the performance . Most modern laundry detergents have all sorts of additives that you don’t want anywhere near your gear. NIKWAX makes a Tech Wash, but I use Charlie’s Soap, a super-concentrated laundry powder which is just coconut-based detergent and washing soda, with no other crap in it. Unlike the tech wash, it can be used for all of your laundry. The liquid detergent is just as good but the powder is far more economical, so suit yourself. Eventually, you may notice that the fabric “wets out” on the surface even though moisture doesn’t actually penetrate to the inside. That is a sign that it is in need of re-treating and NIKWAX makes fabric-specific wash-in treatments for soft shells and hard shells, a spray-on treatment, and other products for practically everything else including leather boots. CAMPMOR sells the whole line. Knock yourself out…..

Editor’s Note: please read the follow-up post to this one, Risk Assessment & Dressing For Success: Killer Cotton, Wild & Wooly, Or Polyester Leisure Suits, which was inspired by a reader’s comment.

“Whether you’re in upper management, a safety director, port captain or captain, it’s easy to forget the real circumstances that the mariners under your direction deal with day to day. That concept was brought home to me when I found myself in Alaska working alongside the people I hire, train and dispatch.”

So begins Back on Deck, the title of the article that Captain Jeff Slesinger , Director of Safety & Training at Seattle’s Western Towboat Co., wrote for the Spring issue of QSE Solutions’ Safe Voyage e-magazine. Capt. Slesinger’s article is not just a mere breath but a full-on, Force 12 arctic blast of fresh air. A Williwaw, as they say up in Alaska, which, as it happens, is exactly where he was. He flew up to south-central Alaska to meet three of his company’s tugs that were all arriving simultaneously after being delayed in crossing the way-gnarly Gulf Of Alaska by weather (no surprise there; take a look at a random report from the Central GofA buoy). He was there to serve as a roustabout: to assist the crews and do whatever needed doing with no task being beneath him. What he got was a valuable lesson and a solid reminder of what can happen to the thought process when you’ve become too far removed from the action, an inevitable occurrence once you decide to swallow the anchor or even, to a certain extent, when you move from the deck to the wheelhouse. For those who’ve never worked a day on deck it’s nearly impossible to relate or understand. This isn’t a character flaw or personal shortcoming, it’s just a fact of life.

Originally, I felt inspired to write a lengthy post about this subject. But as I went through the piece a second time, trying to decide on which of the many gems that I should quote from, I abandoned the effort. Slesinger nails it dead on, and trying to improve on it would be a useless exercise. Instead I’ll simply quote the second to last paragraph in its entirety. “I have years of sea-going experience, and I hold the expertise of professional mariners in high regard. Yet, if I don’t periodically get down on deck, or in the wheelhouse or engine room I lose the feel for the work. And that loss becomes a barrier to understanding and appreciating what I’m asking our mariners to carry out in the execution of their duties.”

Some may shrug and say, so what? That’s the wrong attitude to take. The barrier he speaks of, when it becomes wide and high enough, tends to manifest itself in the form of institutionalized indifference to the challenges of our dangerous and watery workplace as well as unrealistic or overly burdensome regulations, policies, procedures and additional duties that compete for our limited time. Well-intentioned though they may be, they can sometimes overwhelm the working mariner and distract us from the real business at hand: arriving at the dock with everyone and everything in one piece. The poor communications between the boat crews and shore-side support staff that normally results when the barrier becomes well-established will measurably reduce the overall efficiency of the enterprise and make operations with a high safety-factor more difficult to achieve and maintain. Bottom line: we’re all involved in the enterprise to make a living, and we all want to go home intact and at least semi-sane at the end of our hitches.

His four pages , numbers 2-6 in The Art of Towing section (yes, at its highest level of skill and expression towing and ship assist/escort work is most certainly an art form), are required reading for all managers, shore-side support staff, Coast Guard regulators and every captain, mate and pilot too. By all means, avail yourself of Capt. Slesinger’s clear-eyed wisdom. While you’re there, go through the rest of the issue. It’s their finest yet and is loaded with good information from people who are making a serious effort to help the maritime industry’s safety culture change for the better. I personally look forward to reading more excellent writing like this and passing it on to you.

If you would like an e-subscription to Safe Voyage for yourself, or to see the back issues, click here.

While I’m at it, in answer to the many queries I continue to receive from licensed deck officers from the other marine industry sectors that want to go straight to the wheelhouse of a tugboat while skipping the important phase of learning how to deck, I’ll direct you to the Hit The Deck post from back in November. The problems are the same as desribed in Slesinger’s post, only more difficult to quickly overcome: you can’t relearn or relate well to  that which you never knew in the first place, so hit the deck without complaint and learn that job thoroughly first before trying to learn how to steer.

 

Outbound on the Reedy Island Range for New York Harbor: the best is saved for last as the winter sun sets on the Delaware River.

The Coast Guard’s Advanced Notice of Proposed Rulemaking for the TWIC Reader Requirements was published this past Friday in the Federal Register and, on first read, it looks like something that, with some tweaking, we may possibly be able to live with. Having said that, the administrative burden still looks fairly labor intensive and I feel sorry for whoever gets stuck with writing the amended facility and vessel security plans that will be used to implement this.

The proposed procedures to follow depend upon what the current MARSEC Level is and what type of cargo is carried by the barge or barges you have in tow (which determines your “risk group”). The Table Of Potential Reader Requirements, on page 13365 (6th page in the ANPRM), shows the three categories of TWIC verification functions that must be achieved (identity verification, card authentication and card validity check) and the specific protective measures or actions that must be taken to achieve them depending upon where in the MARSEC – Risk Group matrix you land. We’ll be categorized into Risk Groups A through C in descending order of  risk. You’re in Risk Group A if you’re carrying  Certain Dangerous Cargoes (or CDC’s), as defined in 33 CFR § 160.204, in bulk. If you are carrying hazardous materials (HAZMAT) other than CDC’s, as defined by the Table Of Hazardous Materials in 49 CFR § 172.101, or crude oil you’re in Risk Group B. You’re in Risk Group C if you’re carrying Non-HAZMAT, which would be everything else not qualifying as HAZMAT or Certain Dangerous Cargoes. Basically (unless you’re moving toxic chemicals or gases, blasting agents, radioactive materials or ammonium nitrate fertilizer), most of us will fall into groups B & C (Group B if you move petroleum), thereby avoiding the strictest of the procedures (a biometric match of your fingerprints every time you enter your facility) unless the MARSEC Level is at 2 or 3.

Fortunately, it seems as if the towing industry will be spared the ridiculous and heinously expensive burden of having to keep a card reader on board each vessel for providing access control, as the proposed crew size cut-off is 14 for that requirement. If you have a bigger crew than that then a reader would be necessary. While that might wind up applying to some of the biggest oilfield vessels, no tug would ever get close to it. In any case, the card readers will be located at the shoreside facilities. The need for the use of your PIN every time you have to show your card is being reconsidered, as described on pages 13365-13367 (pages 6, 7 & 8 in the ANPRM) . 

So far, we can be cautiously optimistic that this regulatory proceeding is moving in a generally okay direction and the Coast Guard appears to be reasonable in its approach. Nevertheless, I urge everyone to wade through the 11-page ANPRM and make some comments, particularly about the potential PIN-use requirements. They’re being taken through May 26th and you can comment online at Coast Guard docket number USCG-2007-28915 by clicking the little yellow balloon icon beneath Add Comments on the far right of the Documents section. It’s easy, so give it a try.

On March 23, 2008 the F/V Alaska Ranger sank in 6,000 feet of water in the Bering Sea , 120 miles west of Dutch Harbor in the Aleutian Islands, with a loss of 5 of the 47 crewmen. It’s incredibly fortunate that a nearby sister-ship, the Alaska Warrior, and two Coast Guard helicopters were able to rescue the rest before they died of exposure, otherwise it would have become one of the worst U.S. fishing industry disasters on record. The Bering’s a cruel mistress, not to be trifled with…..conditions during the dramatic night rescue were 20-25 foot seas with blinding snow squalls.

It’s an ugly story, on several levels, but buried deep inside it is one big safety lesson to be learned: know your boat. Know your boat because that’s what professional seafarers are supposed to do. Know your boat because it’s difficult to perform your job properly if you don’t, especially in an emergency. Know your boat because that knowledge may one day save your life and the lives of your fellow crewmembers. This isn’t aimed primarily towards tug masters and mates, although a lack of knowledge of the boat on the part of the master certainly contributed to the sinking of the Tug Valour. It applies to everyone, no matter their position, on every vessel. Commercial or pleasure, on the high seas or on a small lake. Know your boat.

It seems that the Alaska Ranger‘s very experienced captain, the latest in a long line of them, didn’t know a critical detail of the boat well enough. He didn’t fully understand all of the operational aspects of the variable-pitch propeller system and, more specifically, what effect a loss of electrical power would have on the pitch. This lack of knowledge ultimately led, with the vessel flooding by the stern, to it backing down uncontrollably and “plunging its stern into the sea” during the crucial final moments before the sinking when crewmembers were attempting to evacuate from the vessel into the life rafts. This caused the rafts to be washed forward along the hull, making the attempts at boarding them very difficult to impossible and eventually putting them beyond the reach of the remaining crew, who then had to jump into the 36-degree water and swim for the rafts. The sobering truth, as quoted from this article in Professional Mariner magazine, “All of the 22 crewmembers who were able to enter the life rafts survived. All five mariners who perished were among the 25 people who never made it into a life raft, the Coast Guard said.” An additional related story from PM can be read here.

In his confusion, the captain is quoted as saying “why the hell are we going in reverse?” At that point the boat was essentially “not under command.” Knowing the vessel better would likely have prevented that particular mistake and saved some lives, maybe even all of them. Any mate, engineer, or even a sharp AB, could potentially have possessed the knowledge that might have prevented this. Although the Coast Guard’s final investigation report has yet to be released, their preliminary findings were alarming enough that it prompted them to publish a Marine Safety Alert on July 2nd of last year, less than four months after the sinking, titled Controllable Pitch Propeller Systems and Situational Awareness.

And now I’ll veer abruptly off topic, sort of…..

By all means, read the compelling article from the Seattle Times that rekindled my interest in this tragic story. It’s a damned fine piece of real reporting by Hal Bernton, with reporter Mike Carter and reasearchers David Turim and Miyoko Wolf contributing to it as well. Another great take on the story comes from the Anchorage Daily News. It was written by Sean Cockerham. Why should you really care about who wrote these stories, let alone who assisted them? Because…..

The next time someone tries to convince you how fucked up all of the “mainstream media” is just remember this: while the now countless-as-the-stars bloggers like me may (I repeat, MAY, not will) be able to provide some thoughtful and useful analysis from time to time, in general only full-on professional newsrooms with real reporters, editors and their support staff, have the resources, knowledge and experience to conduct genuine, fact-checked, in-depth investigative reporting of high quality and reliability. All bloggers, including me, depend on them for the original stories which we further analyze as our interests dictate and without them we’ve got no solid base from which to start. So don’t be a sucker for the tiresome liberal-conservative news bias crap that the political operatives of both main parties use (very successfully) to dumb down, divide and turn against one another the citizens of this country. Read from multiple sources. Never blindly accept just one argument without scrutiny, especially when it fits too neatly into your world view. And support real journalism, whether print, web-based or whatever the future may bring. The practice of journalism, to be sure, has never been perfect. And the old adage of “no page refuses ink”, or the modern version of “no LCD screen refuses a pixel”, is certainly true. Professional newswriters sometimes flat out lie, though it’s very rare, or have a bias strong enough that they just can’t see past it, or just plain get something wrong.  Most of the time the editors catch it, occasionally not. But, flawed though it may be, it’s way better than any alternative out there. Without it we’re deaf, dumb and blind.

Nevertheless, blogging does serve another very important purpose that traditional newspapers and magazines themselves generally haven’t provided. I like to call it The Scatter, that wonderful, “viral” nature of an internet blog post that catches someone’s eye and then spreads far and wide like mold spores on the wind to people who might never have heard of  it otherwise. I found out about this story because I read about it on Capt. Richard Rodriguez’ excellent BitterEnd Blog. Another PNW blog source, Puget Sound Maritime, wrote about it, which led to the gCaptain Daily Blog picking it up via Fred Fry’s Maritime Monday roundup of worthy maritime-related writing. All of them led back to the originator, the Seattle Times. The internet tentacles reach everywhere. Way cool…..but don’t forget that modern technology now allows any jerk-off with a pc to go live with a world-wide blog, literally in minutes, spew out whatever bullshit that crosses their mind, and there is absolutely zero quality control. Since you’re decision-making is only as good as the quality of the information you use to arrive at your decisions (garbage in = garbage out), it pays to remember that fact. 

The Shelby hauls a wide load, getting by with a little help from a friend: eastbound around the Brothers with the Weeks 533 after transiting Hell Gate. East River, NYC.

I was intending to post again about the Coast Guard’s Merchant Mariner Credentials and Licenses communique from Mr. Jeffrey Lantz, the Director of Commercial Regulations and Standards, but Capt. Bill Brucato saved me the trouble and nailed it already, so read his fine post, and many others, at the NY TUGMASTERS WEBLOG instead.

I’ll take this opportunity to again commend the Coast Guard for finally showing signs of life and acknowledging mariners’ existence, even if it is way after the fact. If this sounds to some of you like a lot of praise for very little, simply doing what they should be doing anyway, you’re right. But with the CG-mariner relationship as bad as it is you have to acknowledge even the smallest of baby steps in the hope that it will encourage them to move further in that direction. I’ll also point out that we shouldn’t have to resort to the functional equivalent of running down the hallways at school and pulling all of the fire alarms just to get the “adults” attention. Had the comments received been paid due attention and respect this could have gone very smoothly and without any animosity at all. Another opportunity lost….. 

As it happens, several months ago, I contacted a Coast Guard official by phone and informed him that both the Master of Towing Vessels Association, and our close associates the National Mariners Association, were willing to publicly and enthusiastically support and endorse the new MMC plan if the traditional license option was retained. The leadership of the United Marine Division – Local 333 in New York Harbor, representing over 2,000 mariners, was also willing to publicly endorse it and I passed that info on as well. The result? I never heard a word back from them, and the final rule speaks for itself. We tried to offer the olive branch and, for whatever reason, it was declined. Given our deep disillusionment with the Coast Guard after their poor handling of last year’s 30-Day Wonder rulemaking and final rule, which also featured an unwillingness to listen to the valid and substantial concerns of mariners, we’d pretty much given up on the idea that they were an agency that could be worked with. But still, we thought, the MMC, not being a safety issue, might be something relatively simple that could be worked out satisfactorily. We were wrong.

So, it would appear that maybe when the volume gets turned up loud enough the Coast Guard IS able to respond in some fashion. Below, in italics, is a response to the Monday post sent to us yesterday via Mr. Ronald LaBrec, the Coast Guard’s Chief of Public Affairs. The post is written by Mr. Jeffrey Lantz, the Coast Guard’s Director of Commercial Regulations and Standards. Presumably this means that we’re getting it straight from the horse’s mouth. For the record, we at the MTVA are glad to see that there is finally an official and public acknowledgement of the fact that traditional licenses are, to quote from the post, an “important issue for many mariners”, including the Coast Guard personnel that are themselves licensed. Judging by the big spike in readership on Monday, about double the norm for us, we can conclude that this isn’t something that will go away on its own.

So read the post. I’ll respond with more commentary in a separate post, but leave you with this parting thought: If the Coast Guard was truly serious about working with mariners and addressing this issue to everyone’s satisfaction (simultaneously or separately, sooner or later) shouldn’t the information below have been incorporated into the text of the final rule in the Federal Register? As published, it offers no credible suggestion or assurance that the Coast Guard was seriously considering anything but getting rid of the traditional license for good.

Merchant Mariner Credentials and Licenses

Yesterday, 16 March 2009, the Coast Guard promulgated the Final Rule titled Consolidation of Merchant Mariner Qualification Credentials, commonly referred to the MMC Rule.  Through this rulemaking multiple merchant mariner qualification documents will be consolidated into one credential, which is significantly different than the current version.  Instead of one or several large certificates that resemble a diploma, the MMC resembles a passport.  The Coast Guard did this for many reasons, including ease for mariners to maintain and provide proof of all qualifications and to meet international standards. 

However the old licenses are quite impressive and suitable for framing and some mariners are suggesting the Coast Guard continue to also issue them for sentimental, historical and traditional reasons.

The Coast Guard considered whether or not to continue issuing the current certificates; not for proof of qualifications but for sentimental and traditional reasons.  The Coast Guard asked the Merchant Personnel Advisory Committee (MERPAC) to consider the alternatives for MMC format.  MERPAC recommended that the MMC be a booklet similar in size and design to a U.S. passport.  MERPAC also recognized that the current form of license has traditional and sentimental value to many mariners, and recommended that a “suitable for framing copy of the license” remain an option that a mariner can choose to obtain for a nominal fee.

There are numerous factors to consider in deciding whether or not to also provide a “suitable for framing copy of the license.”  These include the availability of Coast Guard resources, including personnel, paper stock, hardware, software and equipment, and the process for determining and collecting fees.  And as a rulemaking process matter, since this traditional document would not be considered a required or a valid credential, we would need to address other administrative and legal issues that go beyond the Merchant Mariner Qualification Credentials final rule.

However, we know this is an important issue to many mariners. Traditional Coast Guard licenses also proudly adorn the walls of the Coast Guardsmen who have earned them nationwide. The Coast Guard continues to look at this issue from all angles and today’s MMC Rule does not preclude a “suitable for framing copy of the license” at a later date provided all administrative and legal issues are addressed. What the rule does do is provide for a single easily issued, maintained and updated credential aligned with international standards to certify the qualifications of the holder.

I appreciate the opportunity to provide this information to your readers and your continued sharing of information relevant to the professional mariner and Coast Guard operations.

Jeffrey Lantz
Coast Guard Director of Commercial Regulations and Standards

This is an official U.S Coast Guard posting for the public’s information. Our posting does not endorse this site or anything on it, including links to other sites, and we disclaim responsibility and liability for its contents.