The US Office of Commerical Vessel Compliance published a policy letter, aiming to provide clarification and guidance regarding the enforcement of radar observer requirements. This policy letter will expire on July 22, 2019, which is the implementation date of the Amendments to the Marine Radar Observer Refresher Training Regulations final rule.
The final rule called ‘Amendments to the Marine Radar Observer Refresher Training Regulations’, published on June 7, 2019, revised merchant mariner credentialing and vessel manning requirements to remove obsolete portions of the radar observer requirements and harmonize the radar observer endorsement with the merchant mariner credential.
The US Coast Guard also published Policy Letter 03-19, describing the National Maritime Center’s guidance for the evaluation of continued mariner radar observer proficiency.
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Some mariners hold radar course completion certificates that have expired, or will expire before July 22, 2019. Under strict interpretation of regulations, these mariners may be required to provide a course completion certificate to prove the validity of their current radar observer endorsement. This possible action would go against the purpose and intent of this rulemaking.
Mariners will b complying with radar observer requirements if they hold a valid Merchant Mariner Credential including the necessary endorsement as Radar Observer. Mariners should not be required to provide training certificates to showcase that their Radar Observer endorsement is current and valid.
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