NVIC 09-01: STCW quality standards systems for training

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 9 01 Subj: GUIDANCE ON STCW QUALITY STANDARDS SYSTEMS (QSS) FOR MERCHANT MARINER COURSES OR TRAINING PROGRAMS

Guidance on STCW Quality Standards Systems (QSS) for merchant mariner courses or training programs. — PURPOSE.

a. This NVIC provides information for organizations that wish to serve as a QSS on behalf of the U. S. Coast Guard. b. Training and assessment activities required by the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) must be monitored as part of a QSS. The U. S. Coast Guard's course-approval process described in Title 46, Code of Federal Regulations (46 CFR), section 10.302 and the oversight program described in Commandant Instruction 16721.1, Standards for Oversight of Licensing and Seaman's Certification Activities, comprise the U. S. Coast Guard's QSS for training courses or programs required by the STCW.

Guidance on STCW Quality Standards Systems (QSS) for merchant mariner courses or training programs. — ACTION. Officers in Charge, Marine Inspection should bring this NVIC to the attention of maritime interests within their areas of responsibility. Internally, it will be distributed electronically. It will also be available on the World Wide Web at http://www.uscg.mil/hq/g-m/nvic/index.htm.

ACTION. Officers in Charge, Marine Inspection should bring this NVIC to the attention of maritime interests within their areas of responsibility. Internally, it will be distributed electronically. It will also be available on the World Wide Web at http://www.uscg.mil/hq/g-m/nvic/index.htm.

Guidance on STCW Quality Standards Systems (QSS) for merchant mariner courses or training programs. — DIRECTIVES AFFECTED. NVIC 7-97, COMDTPUB 16700.4 is superseded and canceled.

DIRECTIVES AFFECTED. NVIC 7-97, COMDTPUB 16700.4 is superseded and canceled.

Guidance on STCW Quality Standards Systems (QSS) for merchant mariner courses or training programs. — BACKGROUND.

a. In 1993, the International Maritime Organization embarked on a comprehensive revision of the STCW to reduce human error as a major cause of marine casualties. On July 7, 1995, a conference of Parties to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended (STCW) adopted amendments which entered into force on February 1, 1997. b. The U. S. Coast Guard implemented the 1995 amendments by publishing an interim rule on June 26, 1997, that modified 46 CFR parts 10, 12, and 15 and incorporated the 1995 amendments into the domestic regulations. Title 46 CFR 10.309 and 46 CFR 12.03-1 now require entities offering training required by STCW to be monitored "in accordance with a U. S. Coast Guard-accepted quality standards system." c. The STCW details the training required for masters, officers and ratings and then broadens its scope to those activities that directly impact that training. It recognizes that training, both on-the job and formal, is an integral and vital part of career development. It acknowledges that on-the-job training has taken place between senior and junior personnel and has been a part of a long-standing maritime tradition. It formally captures training in a training record book or other record of training and establishes responsibilities for companies operating seagoing vessels. It recognizes the criticality of all training, and requires the establishment of criteria for those conducting training and assessing skills. It also requires organizations offering training required by the STCW to be monitored by a QSS, the subject of this NVIC. This function can be accomplished either by the U. S. Coast Guard or by a U. S. Coast Guard-accepted QSS.

Guidance on STCW Quality Standards Systems (QSS) for merchant mariner courses or training programs. — DISCUSSION.

a. The STCW seeks to ensure the highest standards for functions and processes relating to a mariner's competence. To do this, all training, assessments of competence, certification, endorsement, and revalidation activities regarding STCW certificates must be monitored by a QSS. The U. S. Coast Guard's QSS encompasses the above plus the processes of applying for, obtaining, issuing, upgrading, and renewing a U. S. Coast Guard-issued license or document. b. The U. S. Coast Guard's course approval system described in 46 CFR 10.302 and NVIC 5-95, Guidelines for Organization Offering Coast Guard Approved Course, satisfies the mandatory requirements of the STCW for a QSS in the area of training. However, due to the scope of the STCW's training requirements, the U. S. Coast Guard decided to expand its partnerships with industry. Enclosure (1) lays out the criteria for an entity that seeks acceptance as a QSS to review and monitor training on behalf of the U. S. Coast Guard. These entities will be called U. S. Coast Guard-accepted QSS organizations. c. The STCW's recommended guidance for a QSS, contained in the STCW Code B-1/8, describes a quality management system paralleling ISO 9000 guidelines. Elements of quality management are part of the guidelines for becoming a U. S. Coast Guard-accepted QSS organization. While these are not mandatory requirements for organizations offering training, the U. S. Coast Guard agrees with the concepts of quality management and has made these recommendations a voluntary option for training organizations. d. The implementation of the STCW ushered in a number of new concepts and terms. Additionally, the STCW works in concert with the International Safety Management (ISM) Code. These concepts, terms, and interactions are defined and discussed below:

(1) QUALITY STANDARDS SYSTEM (QSS) A system that provides for, and ensures through, the acceptance and monitoring of mariner training that such training provides the highest standards of merchant mariner competence. The existing U. S. Coast Guard course approval process is part of the U. S. Coast Guard's overall QSS; it ensures training is designed, offered, and monitored in accordance with the U. S. Coast Guard's standards.

(2) U.S. COAST GUARD-ACCEPTED QSS ORGANIZATION An organization meeting the standards contained in this NVIC and recognized by the U. S. Coast Guard as competent to act in lieu of the U. S. Coast Guard for the purposes of review, acceptance, and oversight of training courses and programs.

(3) ACCEPTED TRAINING Training that has been reviewed and accepted by a U. S. Coast Guard-accepted QSS organization will be termed "U. S. Coast Guard-accepted." This training will have the same weight and acceptance as U. S. Coast Guard-approved training within the licensing and documentation process.

(4) ON-BOARD TRAINING

(a) In some areas, the STCW requires on-board training as a requirement for an STCW certificate. An approved or accepted training program that includes on-board training must have the details of the on-board training included in the overall program approval issued by the U. S. Coast Guard or the acceptance by a U. S. Coast Guard-accepted QSS organization.

(b) ISM Code-certified, shipping companies should refer to paragraph 5.f to assess their options. Non-ISM Code-certified shipping companies wishing to offer their crews on-board training creditable toward an STCW certificate must ensure the training conforms to U. S. Coast Guard standards or have it reviewed and accepted by a recognized QSS.

(5) QUALIFIED INSTRUCTORS AND DESIGNATED EXAMINERS Training and assessments required by the STCW must be conducted by persons trained and qualified to perform these tasks. A qualified instructor is an individual who has been trained or instructed in instructional techniques of training. A designated examiner is an individual who has been trained or instructed in techniques of training and assessment and is qualified to evaluate whether a candidate has achieved the required level of competence. Information about the acceptance of ships' officers serving as assessors of practical skills that can only be completed aboard ship are available on the STCW web site, http://www.uscg.mil/STCW/s-home.htm. e. Enclosure (2) is a list of all training that a QSS may review and accept on behalf of the U. S. Coast Guard. Enclosure (3) is a list of all training reserved for review and approval only by the U. S. Coast Guard. Enclosure (4) lists training required by the STCW, but which does not require either approval or acceptance. New training required by statute, treaty, regulation or new technology will be reviewed by the U. S. Coast Guard to determine which agencies will be authorized to serve as the QSS for such training. f. The ISM Code also contains requirements for training; however, it does not prescribe specific requirements for the training program. Therefore, a training program simply by virtue of being under the ISM umbrella may not necessarily meet the STCW criteria. Specifically, the U. S. Coast Guard requires an enhanced level of detail before approving a course as well as periodic oversight by either the U. S. Coast Guard or an organization accepted as a QSS. For a shipping company certified under the ISM Code that wishes to have ISM-required training meet the STCW, it must be approved by the U. S. Coast Guard or accepted by a QSS.

(1) An organization that conducts ISM Code certification on behalf of the U. S. Coast Guard may also serve as a QSS for training if accepted as such in accordance with enclosure (1).

(2) The ISM Code requires newly assigned crewmembers to be familiarized with the vessel to which they are reporting. This ISM Code requirement is identical to STCW regulation I/14. Satisfying the ISM Code for shipboard familiarization also satisfies STCW regulation I/14-1.4. This training does not have to be U. S. Coast Guard-accepted or -approved.

(3) The ISM Code requirement for shipboard familiarization is not sufficiently detailed to meet the requirements for training required by STCW regulation V/1-1.2 (Tanker familiarization). This training must be approved or accepted by a QSS.

(4) STCW regulations V/2-5 and V/3-5 require familiarization training for personnel serving on passenger vessels. This training is not required to be approved or accepted by a QSS, and providing familiarization training is a responsibility of the vessel's operator. ISM Code familiarization training may also meet the STCW's requirements for familiarization training if it covers the areas set forth in the respective sections of part A of the STCW Code.

Guidance on STCW Quality Standards Systems (QSS) for merchant mariner courses or training programs. — IMPLEMENTATION.

a.

All training creditable towards STCW certification must meet standards established by the U.

S.

Coast Guard, or it must be accepted by a U.

S.

Coast Guard-accepted QSS organization.

The QSS will also monitor that training.

In accepting training, the QSS will, at a minimum, ensure that the training covers the subject areas in the model courses developed by the International Maritime Organization (IMO) and listed in enclosure (2). b.

Organizations wishing to serve as a QSS, and accept and monitor training on behalf of the U.

S.

Coast Guard, should apply to the U.

S.

Coast Guard's National Maritime Center (NMC) in accordance with enclosure (1).

An organization submitting an application may not act as a U.

S.

Coast Guard-accepted QSS until it has received its letter of acceptance.

Review of an application to serve as a QSS normally requires 60 to 90 days. c.

Except for the courses listed in enclosure (3), training organizations may elect to have the U.

S.

Coast Guard or a U.

S.

Coast Guard-accepted QSS serve as its QSS.

Training currently approved by the U.

S.

Coast Guard retains that approval until its expiration date.

At that time, a training organization may either have the training re-approved by the U.

S.

Coast Guard or accepted by a U.

S.

Coast Guard-accepted QSS organization. d.

A training organization wishing to switch its QSS must ensure that it receives approval from the organization to which they are switching before the expiration of the current approval or acceptance.

The NMC must be notified in writing of the change and include the name of the new QSS organization, the effective date of the change, and the courses accepted by the new QSS. e.

NVIC 5-95 provides information about the submittal of courses to the U.

S.

Coast Guard for approval.

Courses submitted to a U.

S.

Coast Guard-accepted QSS organization should conform to the standards established by the U.

S.

Coast Guard-accepted QSS organization and should encompass the same content as submissions to the U.

S.

Coast Guard as described in NVIC 5-95. f.

A list of U.

S.

Coast Guard-accepted QSS organizations is available on the World Wide Web at http://www.uscg.mil/STCW/m-achome.htm. g.

U.

S.

Coast Guard-accepted QSS organizations must be completely independent and may not exercise direct or indirect managerial or financial control through contract or understanding over any training organization for which they serve as the QSS.

Likewise, a training organization may not exercise direct or indirect managerial or financial control through contract or understanding over any U.

S.

Coast Guard-accepted QSS organization that serves as its QSS. h.

A training organization choosing to be monitored by U.

S.

Coast Guard-accepted QSS organization must grant the QSS the same access granted to the U.

S.

Coast Guard.

A U.

S.

Coast Guard-accepted QSS organization must have convenient access to all appropriate documents and facilities, and opportunities both to observe all appropriate activities and to conduct confidential interviews when necessary.

Arrangements must be such that persons representing the U.

S.

Coast Guard-accepted QSS organization are not rewarded, directly or indirectly, by the training organization for making any particular observations or for reaching any particular conclusions.

Encl : (1) Guidance for becoming a U.

S.

Coast Guard-accepted QSS organization

(2) Training that may be accepted by a U. S. Coast Guard-accepted QSS

(3) Training that may be approved only by the U. S. Coast Guard

(4) Training that is not required to be approved or accepted