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USCG: Guidance On the Enforcement of Radar Observer requirements prior to July 22, 2019

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Originally posted on the USCG Maritime Commons blog:

POSTED BY LT AMY MIDGETT ON JULY 12, 2019 • ( LEAVE A COMMENT )

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.

USCG: Nat’l Maritime Center Announces Additional Credential Extensions Due to the Lapse in Appropriations

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Originally posted on the Coast Guard Maritime Commons on 07/02/2019

POSTED BY LT AMY MIDGETT ON JULY 2, 2019

The National Maritime Center posted a bulletin to alert mariners that due to a continued backlog of credential applications and increased net processing time of both mariner credential applications and medical certificate applications caused by the lapse in appropriations and shutdown of National Maritime Center operations, the following updated actions are being taken:

  • Merchant mariner credentials (MMC) and medical certificates (national endorsements only) that expire in December 2018, January 2019, February 2019, March 2019, April 2019, May 2019, June 2019, or July 2019 are extended as valid until August 31, 2019. Mariners who are actively working on expired credentials that meet the expiration criteria must carry the expired credential with a copy of the attached letter. 
  • This extension does not change the time frame during which a credential may be renewed. A credential may be renewed at any time during its validity and for 1 year after expiration based on the expiration date printed on the credential. 

If you have questions, visit the NMC website, or contact the NMC Customer Service Center by using the NMC online chat system, by e-mailing IASKNMC@uscg.mil, or by calling 1-888-IASKNMC (427-5662).

USCG: ‘Findings of Concern’ focuses on the hazards of corrosion

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Originally posted on the USCG Maritime Commons 07/25/2019

The Coast Guard recently published Findings of Concern 009-19, “Corrosion Caused Casualties,” in order to bring awareness to unsafe conditions discovered last year on a Louisiana towing vessel during a marine casualty investigation. 

The Incident.

An Inspected Towing Vessel (ITV) pushing a loaded tank barge experienced a loss of steering and subsequently ran aground, Sept. 25, 2018. The marine casualty investigation determined the initiating event to be the port shaft propeller nut wedged into the rudder, which prevented the free and full movement of the steering gear. (Figure 1)

Photo of propeller nut wedged into the rudder and photo of deteriorated propeller nut locking strap.

Contributing Factors and Analysis. 

The investigation identified the initiating event causal factors to be a material failure of the port shaft propeller nuts locking strap (missing), the lack of a secondary securing mechanism (second nut/cotter pin) on the port propeller nut, and an inadequate corrosion mitigation preventative maintenance program. Visual analysis of the starboard shaft locking strap noted significant deterioration of the locking mechanism (Figure 2), requiring immediate replacement. Based on the analysis of this casualty, marine inspectors inspected the locking nut straps of several other ITV’s during scheduled dry-dock exams, which showed similar corrosion issues.

The Coast Guard recommends the following preventative measures:

  • Review company corrosion prevention systems/programs. If necessary, engage with a corrosion specialist from the American Boat and Yacht Council and/or National Association of Corrosion Engineers. 
  • Ensure adequate primary and secondary propeller shaft securing devices (cotter pins, double nut, locking strap, etc.) are in place at all times, with consideration given to vessel operations and environmental conditions.
  • Inspect propeller fasteners routinely/during every dry-docking and replace in accordance with manufacturer’s instructions. 

The Coast Guard issues findings of concern to disseminate information related to unsafe conditions identified as causal factors in a marine casualty and that may cause a similar casualty on other vessels. Findings of concern are intended to educate the public, state, or local agencies about the conditions discovered so they may address the findings with an appropriate voluntary action or highlight existing applicable company policies or state/local regulations. 

These findings of concern are provided for informational purpose only and do not relieve any domestic or international safety, operational, or material requirements. For any questions or comments please contact Marine Safety Unit Lake Charles Investigations Division by phone at (337) 491-7811 or by email at msulcinv@uscg.mil.