Uniform approach on treatment of mariner security training certification under STCW

USCG Marine Safety Information Bulletin

USCG has issued MSIB 06-14 to encourage owners and operators of subject U.S. vessels to ensure that mariners obtain all endorsements in accordance with2010 Manila amendments to the STCW as soon as possible.

The IMO Sub-Committee on Human Element, Training and Watchkeeping (HTW) reviewed the implementationof the security endorsement requirements of STCW and recognized that many seafarers world-wide had practicaldifficulties obtaining either security awareness training or the training for personnel with designated securityduties, before the end of the transitional period on 1 January 2014.

This is required by regulation VI/6 of theSTCW Convention and section A-VI/6, paragraphs 4 and 6 of the STCW Code. For U.S. vessels subject to theSTCW, the USCG recently published a final rule with regulations to implement these provisions.

RelatedNews

USCG: New VHF marine radios now displaying four-digit channel numbers

Liberia: Key requirements for security related familiarization training

Recognizing these challenges, the IMO promulgated circular STCW.7/Circ.21 urging that Administrations informtheir port state control authorities, recognized organizations and recognized security organizations that, until 1 July2015, it would be sufficient to accept compliance with Section 13 of the International Ship and Port FacilitySecurity (ISPS) Code, Part A if a seafarer does not carry certification in security awareness training or the trainingfor personnel with designated security duties as required by STCW.

The USCG agrees with circularSTCW.7/Circ.21, and has adopted a modified enforcement posture for securityawareness training and seafarers with designated security duties certification on subject U.S. vessels until 1 July2015.

This is contingent upon a mariner’s compliance with 33 CFR 104.220 and 104.225, which have beendetermined to meet the requirements of Section 13 of the ISPS Code, Part A. USCG Marine Inspectors willcontinue to verify mariner certification with regard to the security awareness training and/or training for personnelwith designated security duties in accordance with regulation VI/6 of the STCW Convention.

If certification is notin accordance with the STCW Convention, but the mariner meets the criterion of 33 CFR 104.220 and 104.225,and thus Section 13 of the ISPS Code, Part A, no control action will be initiated.

However, for vessels to whichthe ISPS Code applies, Marine Inspectors should document non-compliance as deficiencies on Form CG-835 witha compliance date of July 1, 2015, citing 46 CFR 15.1113(c) and (e), respectively. Separate guidance has beenprovided to USCG Port State Control Officers via CGMS.

Also read article