The US Coast Guard announced the availability of Change 1 to Guidelines for Qualification for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness.
After publication of NVIC 21-14, COMDTPUB 16721, in 2014, USCG became aware of the need to address the question of whether sea service acquired on military and government owned or operated vessels should be allowed to be used to qualify for a STCW endorsement as VSOs.
This change notice indicates that USCG has determined that certain sea service aboard military and government owned or operated vessels may be credited toward meeting the sea service requirement for the STCW endorsement for vessel security officer (VSO).
Section 33 CFR 104.215(d)(1)(v)(A) requires 12 months of sea service on a vessel subject to qualify for a STCW endorsement as VSO. Section 33 CFR 104.215(d)(1)(v)(B) requires 6 months of sea service on a vessel subject to 33 CFR 104.105, and satisfaction of a knowledge requirement to qualify for an STCW endorsement as VSO.
USCG determined that service onboard government owned or operated vessels, such as Military Sealift Command vessels, USACE vessels, and NOAA vessels, of at least 100 gross register tons (GRT) will be creditable toward both 33 CFR 104.215(d)(1)(v)(A) and 33 CFR 104.215(d)(1)(v)(B).
The Coast Guard will credit sea service earned on these vessels toward the full sea service requirements because they are operated similarly to a merchant vessel.
The Coast Guard also determined that up to 5 months of service on military vessels will be accepted towards the 6 month minimum sea service requirement in 33 CFR 104.215(d)(1)(v)(B). The remaining month could be accrued on vessels subject to 33 CFR 104.105 or the government owned or operated vessels of at least 100 GRT listed above.
The regulations at 46 CFR 10.232(d)(1) allow the use of military service towards credentials when the Coast Guard determines it is equivalent to sea service acquired on merchant vessels. The purpose of the sea service requirements for a STCW endorsement as VSO is to ensure that the mariner is familiar with general merchant vessel operations.
The Coast Guard has determined that the mariner can demonstrate the necessary merchant vessel operational experience with a combination of military sea service, a minimum of 30 days sea service on government owned or operated vessels or any vessel subject to 33 CFR 104.105, and by satisfying the knowledge requirements in 33 CFR 104.215. The policy uses a minimum tonnage of 100 gross register tons to be consistent with requirements for merchant mariners
said USCG.
Furthermore, the Coast Guard made some other minor changes to provide clarity. First, it notes in the list of requirements to qualify for a VSO endorsement, that:
The mariner must meet the physical examination requirements in 46 CFR part 10, subpart C. This requirement already exists and applies to this endorsement per 46 CFR 11.337(b). We are adding it to the NVIC so that it is more clear that the physical examination requirements are also a requirement, in addition to what is listed in 33 CFR 104.215(d)
Second, it adds a statement that the evidence of knowledge of vessel operations obtained through training or equivalent job experience required for 33 CFR 104.215(d)(3) may be documented on agency, company, or vessel letterhead.
This new instruction describes a method the mariner can use to provide evidence of training and job experience to the Coast Guard in their VSO endorsement application.
