NVIC 04-97: Company responsibilities under STCW 1995 Amendments

Encl. (2) to NVIC 4-97 COMMANDANT 2100 Second Street, S.W. United States Coast Guard Washington, DC 20593-0001 Staff Symbol: (G-MSO-1) Phone: (202) 267-0230 Fax: (202) 267-4570 COMDTPUB P16700.4 NVIC 4-97 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 4-97 Subj: GUIDANCE ON COMPANY ROLES AND RESPONSIBILITIES UNDER THE 1995 AMENDMENTS TO THE INTERNATIONAL CONVENTION ON STANDARDS OF TRAINING, CERTIFICATION AND WATCHKEEPING (STCW) Ref: (a) Title 46, Code of Federal Regulations, Part 7 “Boundary Lines”

(b) International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended

(c) Interim Rule, Federal Register, Vol. 62, No. 123, pp. 34505-34541, dated June 26, 1997.

(d) Navigation and Vessel Inspection Circular 8-97 “Issuance of International Form Required by the STCW to Validate Merchant Mariner Licenses and Documents”.

(e) Title 46, United States Code, Part F “Manning Vessels”.

(f) Navigation and Vessel Inspection Circular 6-89 “Physical Evaluation Guidelines for Merchant Mariner’s Documents and Licenses”.

(g) Navigation and Vessel Inspection Circular 5-97 “Guidelines on STCW Training Record”.

(h) Navigation and Vessel Inspection Circular 5-95 “Guidelines for Organizations Offering Coast Guard Approved Courses”.

(i) Navigation and Vessel Inspection Circular 6-97 “Guidelines on STCW Qualified Instructors and Designated Examiners”.

(j) Navigation and Vessel Inspection Circular 7-97 “Guidance on International Convention on Standards of Training, Certification and Watchkeeping for Seafarers

(STCW) Quality Standards Systems (QSS) for Merchant Mariner Courses or Training Programs”.

(k) Title 46, United States Code, Chapter 32.

(l) Navigation and Vessel Inspection Circular 2-94 “Guidance Regarding Voluntary Compliance with the International Management Code for the Safe Operation of Ships and for Pollution Prevention”.

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — PURPOSE. This circular establishes guidelines for applying certain U.S. regulations

implementing the 1995 Amendments to STCW. Specifically, it provides guidance to companies owning or operating U.S.-documented, self-propelled vessels that operate beyond the boundary line (seagoing) as defined in reference (a). The intent of the company responsibility provisions is to ensure that U.S.-documented seagoing vessels are appropriately manned with personnel fully competent and fit to perform all routine and emergency duties on board. 1 of 3

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — DIRECTIVES AFFECTED. None

DIRECTIVES AFFECTED. None

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — BACKGROUND.

a. In 1993, the International Maritime Organization (IMO) embarked on a comprehensive revision of STCW to establish the highest practical standards of competence for mariners and to reduce human error as a major cause of marine casualties. On July 7, 1995, a conference of Parties to STCW, including the U.S., adopted a package of amendments to the convention which establishes requirements for qualification of masters, officers, watchkeeping and other crew personnel on seagoing merchant vessels and the responsibilities of companies that operate such vessels (reference (b)). The STCW amendments entered into force on February 1, 1997. b. The Coast Guard published an Interim Rule on June 26, 1997 (reference (c)) implementing the requirements of the 1995 STCW Amendments to ensure that U.S. merchant mariners and vessel owners/operators conform to the new provisions. This Rule modified Title 46, U.S. Code of Federal Regulations (CFR), Parts 10, 12, and 15. c. If you own or operate a seagoing, U.S.-documented, self-propelled vessel, 46 CFR Part 15 requires that:

(1) Personnel serving as crewmembers on board your vessels hold an appropriate STCW endorsement;

(2) Your vessels are adequately manned;

(3) You maintain records of crew experience, training, and competency and medical fitness; and

(4) You provide ship specific familiarization and crew coordination training or instruction. These requirements do not apply to non self-propelled Mobile Off-Shore Drilling Units

(MODUs) or to industrial personnel on self-propelled MODU’s or research personnel on research vessels. Such industrial personnel, however, are subject to the familiarization and basic safety training requirements of 46 CFR 15.1105. d. Personnel serving on small passenger vessels subject to 46 CFR subchapters T or K or vessels less than 200 gross registered tons (other than passenger vessels subject to 46 CFR subchapter H) are considered in compliance with STCW due to their special operating conditions and status as small vessels engaged in domestic voyages. However, if these vessels make international voyages, foreign port state control officers may look for compliance with the following STCW standards:

(1) All licensed officers hold an STCW Certificate (unlicensed crewmembers on vessels that admeasure 500 gross tons or more may be required to hold an STCW Certificate);

(2) Watch schedules are posted in compliance with the STCW rest hour requirements;

(3) All crewmembers are familiar with the systems and procedures related to their duties; and Encl. (2) to NVIC 4-97

(4) All crewmembers have basic safety training or instruction or vessel familiarization training, as appropriate. e. The provisions of STCW do not apply to U.S. -documented commercial fishing vessels or fish tender vessels. f. The information provided in this NVIC is a consolidation of requirements and guidance extracted from the STCW Regulations and STCW Code as well as the implementing U.S. Regulations found in the Coast Guard’s Interim Rule CGD 95-062 (reference (a)). Clarifying information has been included where appropriate.

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — DISCUSSION.

a. What are my company’s responsibilities with respect to STCW? You are responsible for ensuring the requirements of STCW Regulation I/14 and section A-VIII/1 of the STCW Code are met for each of your vessels to which the STCW Convention applies in each of these areas:

(1) Certification of mariners on board;

(2) Safe manning;

(3) Documentation and record keeping of mariner training, competency; and medical fitness;

(4) Ship-specific familiarization training or instruction for new crewmembers;

(5) Effective coordination of crew activities on board; and

(6) The fitness of each mariner for duty including work/rest hours and watch schedules. You are also responsible for ensuring that:

(1) No crewmember is employed unless they possess evidence that they have received appropriate vessel familiarization or basic safety training in accordance with STCW Regulation VI/1; and

(2) Any on-board training and assessment activities, conducted to comply with STCW, conform to the provisions outlined in sections A-I/6 (Qualified Instructors, Assessors, and Supervisors) and A-I/8 (Quality Standards System) of the STCW Code. Sections B-VIII/2.4 and 2.5 of the STCW Code provides recommended guidelines on bridge resource management and procedures that should also be taken into account in the operation of your vessels. b. How do I meet these responsibilities? To fulfill these responsibilities, follow the guidance provided below: 3 of 3

(1) Certification of Mariners. Ensure that each seafarer assigned to any of your ships holds an appropriate certificate in accordance with the provisions of the STCW Convention, as amended, and with 46 CFR Parts 10 and 12. Before allowing a mariner to serve in a capacity requiring STCW certification or endorsement, verify that the person concerned possesses the appropriate documents. Where any doubt exists, call the U.S. Coast Guard National Maritime Center at telephone number 703-235-1951 or 703-235-0002 to confirm that licenses, merchant mariner documents, and STCW endorsements presented are valid and authentic. NVIC 8-97 (reference (d)) provides guidance on issuance of international endorsements prescribed by STCW.

(2) Safe Manning. In accordance with 46 CFR 15.515, before departing any port you should verify that the complement of licensed and unlicensed personnel on board your vessels meets the manning requirements set out in the relevant manning, watchkeeping, and workhour requirements and, when applicable, the Certificate of Inspection subject to the manning provisions of Title 46, United States Code (USC), Part F (reference (e)).

(3) Documentation and Record-keeping. You must ensure that your vessels are manned by persons who are competent and fit for duty. You must establish procedures to ensure records are maintained for each licensed and documented merchant mariner serving on board vessels subject to STCW throughout the mariner’s service. These records must be readily accessible to those in management responsible for vessel safety and the prevention of marine pollution. This information includes:

(a) The results of a recent evaluation by a medical professional (i.e., a state-licensed medical practitioner, such as a medical doctor, licensed nurse practitioner, or physician’s assistant). The medical evaluation should be within 12 months prior to employment and at 30 month intervals thereafter during the mariner’s period of employment. This evaluation must certify that the mariner is physically able to perform the routine and emergency tasks and duties normally associated with a particular shipboard position or does not have an apparent disqualifying medical condition. You should provide to the medical practitioner information on the physical requirements the mariner must meet to perform his or her duties. The medical practitioner should use NVIC 6-89 (reference (f)), the Seafarers Health Improvement Program (SHIP), or other Coast Guard accepted criteria as a guide to conduct the physical evaluation. A full personal medical history is not required.

(b) The experience, training, or instruction relevant to assigned shipboard duties. (For example, a record of training completed and on-the-job experience acquired.)

(c) Records of competency in assigned shipboard duties evidenced by copies of current licenses, documents, or endorsements held by the mariner.

(d) A record of the most recent basic safety assessment and documented instances where ship-specific familiarization has been achieved and maintained. You are responsible for keeping appropriate records for mariners in your employ but you may use a third party agent (such as a labor union with a collective bargaining agreement) to maintain and hold physical custody of these records.

(4) Ship-specific Familiarization. Encl. (2) to NVIC 4-97

(a) In accordance with 46 CFR 15.1105(b), upon first assigning your employees to a vessel, you must provide them a reasonable opportunity to become familiar with all ship arrangements, installations, equipment, procedures and ship characteristics relevant to their routine and emergency duties. (This is in addition to the familiarization and basic safety training required under 46 CFR 15.1105(a) and (c) discussed in paragraph 4.b.(7) below.) Section A-I/14 of the STCW Code requires you to provide written instructions to the master that documents the policies and procedures to follow with respect to all newly employed or newly arrived vessel personnel. These written procedures, which may be in the form of a checklist, should direct new or newly arrived employees to: 1. Visit spaces where they will perform their regular and emergency duties; 2. Locate muster stations, alarms, life-saving appliances, and emergency escape routes, as well as any fire-fighting and pollution response equipment they may use; 3. Meet their supervisor or other person(s) assigning duties; 4. Locate equipment necessary to perform their duties and learn the control and display features for that equipment;

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — When convenient to vessel operations, observe the equipment in use by someone

whose duties already require its use;

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — Activate the equipment and perform functions using the controls on the

equipment, when conditions permit;

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — Locate operational manuals or other documentation needed to perform their

duties;

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — Locate any personal protection gear required to perform their duties, as well as

first aid/medical kits available at the work site;

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — Read and understand relevant standing orders, safety and environmental

protection procedures, and company policies, clarifying any unclear or confusing material;

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — Read and understand the vessel's safety management system which includes:

· The owner's safety and environmental protection policies; · Company responsibility and authority statements; · Master's responsibilities and authorities statements; · Crew members chain of command; · Duty requirements regarding vessel safety and pollution prevention operation plans; 5 of 3 · Personnel procedures and resources which are available ashore and aboard ship from the company; and · The written designation of the person who is responsible for the management, maintenance, and communication of safety management system requirements throughout the vessel's company; and

Guidance on company roles and responsibilities under the 1995 Amendments to the International Convention on STCW — If serving in a watchkeeping capacity, get acquainted with the watch schedule and

identify a personal work schedule which will comply with workhour limits and rest period requirements.

(b) When assigning a new mate or master to a ship with an Integrated Navigation System

(INS) or Integrated Bridge System (IBS), provide special instruction in the use of the system before assigning watchkeeping duties, particularly in regard to: 1. The function of each component (along with any dependent relationship of one component to another); 2. The visual and audible alarm displays (along with their meaning and location); 3. The source of critical input data (along with the need to verify the accuracy of inputs by other available means at periodic intervals); and 4. The procedures for switching between automated and manual operation (along with the response times involved).

(b) Conduct frequent drills to ensure all personnel with navigational watchkeeping responsibilities are fully competent in the ship’s characteristics and how to use the INS or IBS, as applicable, under normal circumstances and during emergencies.

(c) The supervisor must document the fact that new personnel are familiar with ship- specific arrangements. The seafarer and supervisor should also document any need for a period of special supervision to give the new crewmember additional opportunities to become familiar with the vessel's arrangements. Retain the signed documentation on the ship as long as the individual is engaged or employed on the vessel. This record must be available for review by those in management responsible for the safety of the vessel, including the vessel master and appropriate company officials. You may incorporate this record into the Training Record Book referred to in NVIC 5-97(reference (g)).

(5) Crew Coordination. Ensure that the master, officers and crew can effectively coordinate their activities in an emergency situation and perform the functions vital to safety or preventing or mitigating pollution. You can maintain and improve coordination through:

(a) Regular drills requiring the active participation of all crewmembers;

(b) Follow-up discussions of what went well and what needs to be improved and critiques to identify areas where improved procedures, or methods of communication, would allow smoother coordination of activities;

(c) Regular training sessions to allow crewmembers to become acquainted with each other's role on the vessel; and Encl. (2) to NVIC 4-97

(d) Incentives for crewmembers who identify or introduce improvements and for superior team performance during drills.

(6) Fitness for Duty and Watch Schedules. You should establish and enforce watch systems and work schedules to ensure that fatigue does not impair the efficiency of watchkeeping personnel. Take care to ensure compliance with the work hour-rules in 46 USC 8104 and the rest-hour provisions of section A-VIII/1 of the STCW Code (and the implementing regulations in 46 CFR 15.1111). These provisions are:

(a) Each person assigned duty as officer in charge of a navigational or engineering watch, or duty as a rating forming part of a navigational or engineering watch, on board any vessel that operates beyond the boundary line must receive a minimum of 10 hours of rest in any 24-hour period.

(b) The hours of rest may be divided into not more than two periods, one of which must be at least 6 hours in length.

(c) These rest hour provisions need not be maintained in the case of an emergency, drill, or other overriding operational condition (that is, circumstances in which essential shipboard work cannot be delayed for safety or environmental reasons, or could not reasonably have been anticipated at the commencement of the voyage).

(d) The minimum 10 hour rest period may be reduced to not less than 6 consecutive hours under the following conditions: 1. No reduction may extend beyond 2 days; and 2. Not less than 70 hours of rest are provided each 7-day period.

(e) The minimum period of rest required may not be devoted to watchkeeping or other duties. Watchstanders should normally sleep during their scheduled rest periods. This does not prohibit the person from engaging in “personal pursuits” during the rest period as long as the personal activity is not actually work associated with the vessel or ship specific on- board training. In defining and scheduling rest periods, you should not establish conditions where outside influences, such as overtime pay, performance evaluations, or other incentives and pressures undermine the purpose of the rest period which promotes rest and recuperation between periods of watchkeeping. Where the Oil Pollution Act of 1990 and STCW regulations conflict, the more restrictive requirement applies. Ensure that all watchkeeping personnel are aware of the requirements, principles, and guidance set out in Sections A-VIII/2 and B-VIII/2 of the STCW Code. Observe these requirements to ensure that a safe continuous watch, as appropriate to the prevailing circumstances and conditions, is maintained at all times. Placing a copy of the watchkeeping provisions in Sections A-VIII/2 and B-VIII/2 of the STCW Code on board each seagoing ship would assist this. The vessel master must post watch schedules where they are easily accessible to the crew and authorized officials. The schedules must include each affected crew member and take into account the appropriate rest requirements. 7 of 3

(7) Familiarization and Basic Safety Training. Ensure that all crewmembers have evidence of receiving approved familiarization and Coast Guard approved or accepted basic safety training or have maintained competence in basic safety as per STCW Regulation VI/1. Enclosures (1) and (2) are recommended qualification checklists for documenting vessel familiarization and basic safety training. Locally developed documentation is acceptable insofar as it adequately records the required information. Familiarization and basic safety training includes the following:

(a) Vessel Familiarization Training. Ensure that all crewmembers serving on your ships subject to the STCW Convention receive vessel familiarization training or instruction in accordance with 46 CFR 15.1105(a) before assigning them any shipboard duties. This training helps improve personal survival skills and effectiveness in responding to and mitigating emergency situations and is required one time for each individual employed on board. An individual assigned to serve aboard a different type or class of vessel for the first time would need familiarization training or orientation for that vessel. Enclosure (1) may be helpful for documenting this training.

(b) Basic Safety Training. Crewmembers assigned a position as part of a vessel’s required crew complement or assigned a responsibility on the muster list must receive appropriate approved or accepted basic safety training as set out in 46 CFR 15.1105(c) and the standards of competence under the STCW Code section A-VI/1. Competency must be established within the last five years as part of an approved program of training or instruction (see NVIC 5-95, reference (h)). On board drills and exercises qualify as training activity. Enclosure (2) may be helpful for documenting this training. Crewmembers who receive approved basic safety training need not also receive the vessel familiarization training described in 46 CFR 15.1105(a).

(c) Social Responsibilities/Human Relations Training. As part of the required basic safety training noted above, crewmembers must be trained or instructed in the area of social responsibility and effective human relationships. On-board training or instruction will adequately address this topic if crewmembers understand the following: 1. The dangers of drug and alcohol abuse to their own health and safety as well as the safety of the vessel and crew; 2. The importance of sanitation and personal hygiene when living on board a vessel; 3. The risk posed to the safety of the vessel and crew if good working relationships are not maintained at all times and disputes are not resolved promptly, respectfully, and amicably; 4. Any crewmember behaving in a manner perceived as harassing, abusive, discriminatory, or otherwise offensive to the personal dignity or professional standing of another person damages good working relationships; 5. The adverse effects of fatigue, the need for rest to prevent it, and the importance of notifying a supervisor when symptoms of fatigue are present; and 6. Procedures for calling attention to any unsafe or unhealthy shipboard conditions Encl. (2) to NVIC 4-97 or offensive behavior by another person on board the vessel.

(8) Roles of Companies in On-board Training and Assessment. If you conduct on board training and assessment, structure the activities to meet STCW certification requirements. Develop written programs that include the method of media delivery, procedures, and course materials necessary to achieve the prescribed standard of competence. Such training and assessment must be conducted, monitored, evaluated, and supported by persons qualified to perform these activities in accordance with section A-I/6 of the STCW Code. Instructors, supervisors, and assessors must be qualified for the particular types and levels of training or assessment of competence intended for use in qualifying for certification or endorsement under the STCW Convention. NVIC 6-97

(reference (i)) contains guidance on qualification of instructors and assessors. Additionally, take the following criteria into account when training or assessment takes place on-board:

(a) Anyone conducting in-service training of a seafarer must: 1. Have a working knowledge of the training program; 2. Have an understanding of the specific training objectives for the particular type of training conducted; and 3. Have the appropriate qualifications in the task they instruct.

(b) Anyone responsible for the supervision of in-service training of a seafarer must have a full understanding of the training program and the specific objectives for each type of training conducted.

(c) Anyone conducting in-service assessment of a mariner’s competence must: 1. Have an appropriate level of knowledge and understanding of the competence assessed; 2. Have the appropriate qualifications for the task assessed; 3. Receive appropriate guidance in assessment methods and practice; 4. Have practical assessment experience; 5. NVIC 5-97 on Training Record Books and NVIC 6-97 on designated examiners and assessors contain guidance on assessment. 6. If the use of simulators is involved, have practical assessment experience on the particular type of simulator under the supervision and to the satisfaction of an experienced simulator qualified assessor; and

(d) Persons conducting in-service training or assessment on board ship must only do so when such training or assessment will not adversely affect the normal operation of the ship and they can dedicate their time and attention to training or assessment. 9 of 3

(e) In accordance with section A-1/8 of the STCW Code, 46 CFR 10.309 and 12.03 and NVIC 7-97 (reference (j)), all activities conducted to meet an STCW requirement must be monitored through a quality standards system (QSS) to ensure defined objectives are achieved including those concerning the qualifications and experience of instructors and assessors.

(f) Training and assessment, conducted as part of an approved on-board training program, associated with certification as a watch officer must be documented in a Coast Guard accepted training and assessment record book in accordance with 46 CFR 10.304 and NVIC 5-97. For the purpose of updating the knowledge of masters, officers, and radio operators, you must ensure that the texts of recent changes in national and international regulations concerning the safety of life at sea and the protection of the marine environment are on board.

(9) Bridge Resource Management. As recommended in Section B-VIII/2 of the STCW Code, you should issue guidance to masters and navigation watch officers concerning the need for continuously reassessing the allocation and use of bridge resources based on the following bridge resource management principles:

(a) Ensure a sufficient number of qualified individuals are on watch to effectively perform all duties;

(b) Ensure all members of the navigational watch are appropriately qualified and fit to perform their duties efficiently and effectively or the officer in charge of the navigational watch should take into account any limitation in qualifications or fitness of the individuals available when making navigational and operational decisions;

(c) Clearly and unambiguously assign duties to specific individuals, who should confirm that they understand their responsibilities;

(d) Perform tasks according to a clear order of priority;

(e) Do not assign members of the navigational watch more duties or more difficult tasks than they can effectively perform;

(f) Assign individuals to locations where they can most efficiently and effectively perform their duties and reassign individuals to other locations as circumstances may require;

(g) Do not assign members of the navigational watch to different duties, tasks or locations until the officer in charge of the navigational watch is certain that the adjustment can be accomplished efficiently and effectively;

(h) Ensure that instruments and equipment considered necessary for effective performance of duties are readily available to appropriate members of the navigational watch;

(i) Ensure communications among members of the navigational watch are clear, immediate, reliable, and relevant to the business at hand;

(j) Non-essential activity and distractions should be avoided, suppressed or removed; Encl. (2) to NVIC 4-97

(k) Ensure all bridge equipment is operating properly and if not, the officer in charge of the navigational watch should take into account any malfunction which may exist in making operational decisions;

(l) All essential information should be collected, processed and interpreted, and made conveniently available to those who require it for the performance of their duties;

(m) D o not place non-essential materials on the bridge or any work surface; and

(n) Ensure members of the navigational watch are at all times be prepared to respond efficiently and effectively to changes in circumstances.

(10) Bridge Teamwork Procedures. The Standard of competence for officers of the navigational watch under STCW includes a requirement that candidates have “thorough knowledge of bridge teamwork procedures” as per 46 CFR 10.205 and 10.209. An on- board assessment of a working mate’s competence in bridge teamwork principles should include confirmation that the individual concerned has this knowledge and an ability to apply bridge management principles based on direct observation of exercises or circumstances in which the individual demonstrates these skills. The areas assessed should cover:

(a) Voyage planning and evaluation of alternative routes, schedules, and arrangements;

(b) Bridge procedures, checklists, and logs;

(c) Watch conditions, watch augmentation, watch change, and management of workhours and rest periods for watchkeeping personnel;

(d) Effective communication, confirmation and application of information among bridge-team members, and between the bridge and the master and between the bridge and the engine/control room;

(e) Situational awareness and error trapping, based on a continuous reassessment of priorities, resource allocation, and effective use of bridge systems and equipment;

(f) Leadership in maintaining bridge discipline and vigilance in promoting teamwork and information exchange taking into account the skills and experience available and in positioning and re-positioning of watchkeeping personnel taking into account the status of automated systems;

(g) Response in bridge emergencies, such as failure of a critical component in an integrated navigational system, sudden incapacity of a bridge-team member or loss of propulsion, steering or other critical automated systems; and

(h) Pilot/bridge team integration. 11 of 3 c. What if my company operates under a safety management system? If you operate your vessel under a safety management system (SMS) in compliance with the International Safety Management (ISM) Code and hold a valid Safety Management Certificate (SMC) and Document of Compliance issued by the Coast Guard under 46 USC 3205 (reference (k)), you are presumed to be in compliance with STCW Regulation I/14. NVIC 2-94 (reference (l)) contains guidance on how to comply with the ISM Code. 5. IMPLEMENTATION. a. These guidelines apply to seagoing commercial vessels (except commercial fishing vessels and fish tender vessels) operating beyond the boundary line. If you conform to these guidelines, an equivalent Coast Guard accepted industry standard, or ISM Code, you will be in compliance with the provisions of STCW Regulation I/14 and 46 CFR Part 15 with respect to company responsibilities outlined in paragraph 4.a. of this NVIC. b. The Officer in Charge, Marine Inspection (OCMI) may use this NVIC during periodic vessel inspections. Post marine casualty investigations will also take these regulations and policies into account to determine if any non-compliance with these standards is evident. The OCMI will take appropriate enforcement action where necessary to encourage compliance. R. C. NORTH Rear Admiral, U.S. Coast Guard Assistant Commandant for Marine Safety and Environmental Protection Encl: (1) Recommended Qualification Checklist for Vessel Familiarization Training

(2) Recommended Qualification Checklist for Basic Safety Training Non-Standard Distribution: B:a G-MSO(4); G-MOC(4); G-MOA(2); G-MSE(1); G-MSR(1); G-M(1); G-MS(1) C:e New Orleans (90); Hampton Roads (50); Baltimore (45); San Francisco (40); Philadelphia, Port Arthur, Honolulu, Puget Sound (35); Miami, Houston, Mobile, Morgan City, Los Angeles/Long Beach (25); Jacksonville, Portland OR, Boston, Portland ME, Charleston, Galveston, Anchorage, Cleveland, Louisville, Memphis, Paducah, Pittsburgh, St. Louis, San Juan, Savannah, Tampa, Chicago, Buffalo, Detroit, Duluth, Milwaukee, San Diego, Juneau, Valdez, Providence, Huntington, Wilmington, Corpus Christi, Toledo, Guam (20). C:m New York (70); Sturgeon Bay (4). D:l CG Liaison Officer MILSEALIFTCOMD (Code N-7CG) (1). RSPA (DHM-22), CG Liaison Officer MARAD (MAR-720.2) (1).