NVIC 09-14: Change 1 to advanced firefighting STCW guidelines

Commandant US Coast Guard Stop 7509 United States Coast Guard 2703 Martin Luther King Jr. Ave. SE Washington, DC 20593-7509 Staff Symbol: CG-MMC Phone: (202) 372-2357 Fax: (202) 372-1246 E-Mail: MMCPolicy@uscg.mil COMDTCHANGENOTE 16721 NVIC 9-14 18 Sep 2019 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 9-14, CH-1 Subj: CH-1 TO GUIDELINES FOR QUALIFICATION FOR STCW ENDORSEMENTS FOR ADVANCED FIREFIGHTING, NVIC 9-14, COMDTPUB 16721 Ref: (a) Guidelines for Qualification for STCW Endorsements for Advanced Firefighting, NVIC 9-14, COMDTPUB 16721

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — PURPOSE. This Commandant Change Notice publishes CH-1 to NVIC 9-14.

PURPOSE. This Commandant Change Notice publishes CH-1 to NVIC 9-14.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — ACTION. The Coast Guard will use NVIC 9-14, 46 CFR 11.201(h), and 46 CFR 11.303 to establish

whether mariners are qualified in Advanced Firefighting (AFF). Officers in Charge, Marine Inspection (OCMIs) should also bring this notice to the attention of the maritime industry within their zones of responsibility.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — DIRECTIVES AFFECTED. With the release of this Commandant Change Notice, NVIC 9-14 is

updated.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — DISCUSSION.

a. NVIC 9-14 included grandfathering provisions for mariners to demonstrate continuing competency in AFF that expired on January 1, 2017. This change notice removes the expired grandfathering provisions. b. The Coast Guard has become aware of confusion over whether mariners who serve on vessels that are in operation that do not get underway, including, but not limited to, vessels in reduced operating status (ROS), may use their service to demonstrate having maintained the standard of competence for some of the components of AFF. This change notice adds language to clarify that this service may be used for this purpose if the vessels hold regular fire and emergency drills.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — DISCLAIMER. This guidance is not a substitute for applicable legal requirements, nor is it itself a

regulation. It is not intended to, nor does it impose legally-binding requirements on any party. It DISTRIBUTION – SDL No. 170 a b c d e f g h i j k l m n o p q r s t u v w x y z A B X X X X C X X D E X X F G H X X NON-STANDARD DISTRIBUTION: COMDTCHANGENOTE 16721 represents the Coast Guard’s current thinking on this topic and is issued for guidance purposes to outline methods of best practice for compliance with applicable law. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — MAJOR CHANGES. This Commandant Change Notice revises the guidance found in Enclosure (1) of

reference (a) to: a. Remove grandfathering provisions that expired on January 1, 2017; b. Clarify whether mariners serving on vessels that do not get underway may use their service to establish having maintained the standard of competence for in AFF; and c. Clarify the type of renewal training required for mariners with at least one year of relevant service in the past five years, and for those without sufficient recent service.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS.

a. The development of this NVIC and the general policies contained within it have been thoroughly reviewed under Department of Homeland Security Directive 023-01 and Environmental Planning COMDTINST 5090.1 (series) by the originating office, and are categorically excluded (CE) from further environmental analysis under paragraph #A3 in Table 3-1 of U.S. Coast Guard Environmental Planning Implementing Procedures 5090.1. Because this NVIC implements, without substantive change, the applicable Commandant Instruction or other federal agency regulations, procedures, manuals, and other guidance documents, Coast Guard categorical exclusion #A3 is appropriate. b. This Commandant Change Notice will not have any of the following: significant cumulative impacts on the human environment; substantial controversy or substantial change to existing environmental conditions; or inconsistencies with any Federal, State, or local laws or administrative determinations relating to the environment. All future specific actions resulting from the general policies in this NVIC must be individually evaluated for compliance with the National Environmental Policy Act (NEPA), DHS and Coast Guard NEPA policy, and compliance with all other environmental mandates.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — DISTRIBUTION. No paper distribution will be made of this Commandant Change Notice. An

electronic version will be located at http://www.uscg.mil/hq/cg5/nvic.

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — PROCEDURE. Remove and insert the following pages of Enclosure (1) to Reference (a):

Remove Insert Enclosure (1) Enclosure (1) CH-1

CH-1 to Guidelines for Qualification for STCW Endorsements for Advanced Firefighting — RECORDS MANAGEMENT CONSIDERATIONS. This Commandant Change Notice has been

thoroughly reviewed during the directives clearance process, and it has been determined there are no further records scheduling requirements, in accordance with the Federal Records Act (44 U.S.C. 3101 et seq.), NARA requirements, and the Information and Life Cycle Management Manual, Commandant 2703 Martin Luther King Jr.

Ave.

United States Coast Guard Washington, DC 20593-7501 Staff Symbol: CG-CVC-4 Phone: (202) 372-2357 E-Mail: MMCPolicy@uscg.mil COMDTPUB P16721 NVIC 09-14 25 JAN 2014 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 09-14 Subj: GUIDELINES FOR QUALIFICATION FOR STCW ENDORSEMENTS FOR ADVANCED FIREFIGHTING Ref: (a) International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended (STCW), Regulation VI/3 and Section A-VI/3 of STCW Code, incorporated into regulations at 46 Code of Federal Regulations (CFR) 11.102 1.

PURPOSE.

This Navigation and Vessel Inspection Circular (NVIC) provides guidance for qualification for and revalidation of STCW endorsements for Advanced Firefighting. 2.

ACTION.

The Coast Guard will use this NVIC, 46 CFR 11.201(h), and 46 CFR 11.303 to determine which officers and ratings are required to hold national and STCW endorsements for proficiency in Advanced Firefighting and whether such mariners are qualified to hold those endorsements.

Officers in Charge, Marine Inspection (OCMIs) should also bring this NVIC to the attention of the maritime industry within their zones of responsibility.

This NVIC is available on the World Wide Web at http://www.uscg.mil/hq/cg5/nvic.

The Coast Guard will distribute it by electronic means only. 3.

DIRECTIVES AFFECTED.

This NVIC cancels NVIC 01-02, Guidelines for Assessment of Seafarers' Proficiency in Advanced Fire-Fighting Through Demonstrations of Skills. 4.

BACKGROUND. a.

The STCW Convention and STCW Code set forth standards for training and certification for merchant mariners, including qualification requirements and standards of competence for proficiency in Advanced Firefighting.

DISTRIBUTION – SDL No. 162 a b c d e f g h i j k l m n o p q r s t u v w x y z A B X X X X X C X X D X X E X X F G H NON-STANDARD DISTRIBUTION NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 09-14 b.

In order to implement the 1995 amendments to STCW, the Coast Guard published NVIC 01-02 providing guidance on how mariners may demonstrate proficiency in Advanced Firefighting. c.

The International Maritime Organization (IMO) amended the STCW Convention and STCW Code on June 25, 2010.

These amendments entered into force for all ratifying countries on January 1, 2012. d.

The Convention is not self-implementing; therefore, the U.S., as a signatory to the STCW Convention, must initiate regulatory changes to ensure full implementation of the amendments to the STCW Convention and STCW Code.

The U.S. implements these provisions under the Convention and under the authority of United States domestic laws in United States Code, Titles 33 and 46. e.

The Coast Guard published a final rule on December 24, 2013 (78 FR 77796) that implements the STCW, including the 2010 amendments.

The Coast Guard is publishing this NVIC to provide guidance on complying with the new regulations and is cancelling previous policy.

Accordingly, this NVIC cancels NVIC 01-02. 5.

DISCUSSION. a.

As specified in 46 CFR 11.201(h), each applicant for an original STCW officer endorsement must present a certificate of completion from a Coast Guard approved or accepted Advanced Firefighting course.

The course must have been completed within the 5 years before the date the completed application was received by the Coast Guard. b.

Policy regarding proficiency in Advanced Firefighting is located in this NVIC.

Enclosure (1) gives specific requirements for qualifying for proficiency in Advanced Firefighting; Enclosure (2) contains the national assessment guidelines; and Enclosure (3) contains relevant excerpts from the STCW Convention and STCW Code. c.

Training providers may use the guidelines in Enclosure (2) to determine whether students have achieved competency in Advanced Firefighting, or they may develop and use alternatives.

Under 46 CFR 10.402(e), if developing alternatives, a training institution must submit any deviations from these guidelines to the Coast Guard for approval before use.

A training institution submitting a course should state that the guidelines in Enclosure (2) will apply, or provide the alternative guidelines it proposes to use. d.

As specified in 46 CFR 11.303(b), mariners holding STCW officer endorsements are required to demonstrate continued proficiency for the revalidation of the Advanced Firefighting endorsement.

Mariners who have at least 1 year (360 days) of seagoing service within the previous 5 years will be considered to have met a portion of this requirement; the remainder must be demonstrated ashore in Coast Guard approved or accepted Advanced Firefighting Revalidation training that includes assessment in those Advanced Firefighting competencies that cannot be demonstrated through sea service.

Mariners who do not have 1 year of service in the previous 5 years must either take the original course, or an approved or accepted Advanced Firefighting Refresher course that assesses continued proficiency in all competencies related to Advanced Firefighting.

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 09-14 e.

To demonstrate original or continued proficiency in Advanced Firefighting, the mariner need only submit the course completion certificate(s) to the Coast Guard.

The Coast Guard recommends that the mariner retain a copy of the course completion certificate(s) for his or her records. f.

This NVIC primarily provides guidance for those officer endorsement candidates seeking to demonstrate the required proficiency in Advanced Fire Fighting.

There are no regulatory requirements for any ratings to hold an Advanced Firefighting Endorsement.

Nonetheless, it is possible for a rating to obtain an Advanced Firefighting Endorsement, either because of an employer requirement or the nature of the vessel upon which he or she serves requires competence in those skills associated with advanced fire fighting.

Ratings may qualify for and obtain an Advanced Firefighting Endorsement by using this NVIC and the associated enclosures 1-3 herein. 6.

DISCLAIMER.

This guidance is not a substitute for applicable legal requirements, nor is it itself a regulation.

It is not intended to nor does it impose legally-binding requirements on any party.

It represents the Coast Guard’s current thinking on this topic and is issued for guidance purposes to outline methods of best practice for compliance to the applicable law.

You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. 7.

ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS. a.

The development of this NVIC and the general policies contained within it have been thoroughly reviewed by the originating office, and are categorically excluded (CE) under current USCG CE # 33 from further environmental analysis, in accordance with Section 2.B.2. and Figure 2-1 of the National Environmental Policy Act Implementing Procedures and Policy for Considering Environmental Impacts, COMDTINST M16475.1

(series). Because this NVIC implements, without substantive change, the applicable Commandant Instruction or other federal agency regulations, procedures, manuals, and other guidance documents, Coast Guard categorical exclusion #33 is appropriate. b. This NVIC will not have any of the following: significant cumulative impacts on the human environment; substantial controversy or substantial change to existing environmental conditions; or inconsistencies with any Federal, State, or local laws or administrative determinations relating to the environment. All future specific actions resulting from the general policies in this NVIC must be individually evaluated for compliance with the National Environmental Policy Act (NEPA), DHS and Coast Guard NEPA policy, and compliance with all other environmental mandates. 8. RECORDS MANAGEMENT CONSIDERATIONS. This NVIC has been thoroughly reviewed during the directives clearance process, and it has been determined there are no further records scheduling requirements, in accordance with Federal Records Act, 44 U.S.C. 3101 et seq., NARA requirements, and Information and Life Cycle Management Manual, COMDTINST M5212.12 (series). This policy does not create significant or substantial change to existing records management requirements. NAVIGATION AND VESSELINSPECTION CIRCULARNO. 09-14 9. FORMS/REPORTS. None. 10. QUESTIONS. All questions regardingimplementationofthis Circularshouldbedirectedto theMarinerCredentialingProgramPolicyDivision(CG-CVC-4), at(202) 372-2357or MMCPolicy@uscg.mil. To obtainapproval for an alternativeto the assessments describedin Enclosure(2), contacttheNational Maritime Centerat(888) 427-5662 orIAskNMC@uscg.mil. J.ASER 10 Re Admiral, U. S. CoastGuard AssistantCommandantfor PreventionPolicy Encl: (1) DiscussionofQualificationRequirements forAdvancedFirefighting

(2) AssessmentGuidelines for AdvancedFirefighting

(3) Excerpts from STCW Conventionand STCW Code