Originally posted on the USCG Maritime Commons blog:
The Office of Commerical Vessel Compliance published a policy letter July 12, 2019, to provide clarification and guidance regarding the enforcement of radar observer requirements.
The final rule titled Amendments to the Marine Radar Observer Refresher Training Regulations published 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 Coast Guard also published Policy Letter 03-19, which outlines the National Maritime Center’s guidance for the evaluation of continued mariner radar observer proficiency. Editor’s note: Read our recent post about the final rule and policy letter.
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 existing radar observer endorsement. This potential action would go against the purpose and intent of this rulemaking.
Mariners will be considered in compliance with radar observer requirements if they hold a valid Merchant Mariner Credential containing the appropriate endorsement as Radar Observer. Mariners should not be required to provide training certificates to show their Radar Observer endorsement is current and valid.
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.
For full details, download or view the policy letter. Questions concerning this policy letter and guidance should be directed to the Coast Guard Domestic Vessel Compliance Division at CG-CVC@uscg.mil.