NVIC 21-14: Sea service credit for STCW VSO endorsements

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 COMDTCHANGENOTE16721 NVIC 21-14 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 21-14, CH-1 Subj: CHANGE 1TO GUIDELINES FOR QUALIFICATION FOR STCW ENDORSEMENTS FOR VESSEL SECURITY OFFICERS, VESSEL PERSONNEL WITH DESIGNATED SECURITY DUTIES, AND SECURITY AWARENESS Ref: (a) Guidelines for Qualification for STCW Endorsements forVessel Security Officers, Vessel Personnel with Designated Security Duties,and Security Awareness, NVIC 21- 14, COMDTPUB 16721

CH-1 to Guidelines for Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — PURPOSE. This Commandant Change Notice publishes CH-1to NVIC 21-14.

PURPOSE. This Commandant Change Notice publishes CH-1to NVIC 21-14.

CH-1 to Guidelines for Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — ACTION. The Coast Guard will use this NVIC and Title 46 Code of Federal Regulations (CFR)

11.337, 12.625, and 12.627 to determine if mariners are qualified for STCW endorsements as Vessel Security Officer (VSO), Vessel Personnel with Designated Security Duties (VPDSD), and for Security Awareness (SA).

CH-1 to Guidelines for Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — DIRECTIVES AFFECTED. With the release of this Commandant Change Notice, NVIC 21-14

is updated.

CH-1 to Guidelines for Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — DISCUSSION.

a.

After publication of reference (a), the Coast Guard became aware of the need to address the question of whether sea service acquiredon military and government-owned or operated vessels should be allowed to be used to qualify fora STCW endorsement as VSO.This change notice revises NVIC 21-14toindicate that the Coast Guard has determined sea service accrued aboard certain military and government owned or operated vessels may be credited toward the sea service requirements in 33 CFR 104.215(d)(1)(v)(A)and 104.215(d)(1)(v)(B) to qualify for a STCW endorsement as VSO.

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 X C X X D X X E X X F G H NON-STANDARD DISTRIBUTION: COMDTCHANGENOTE 16721 NVIC 21-14 b.

The regulations at 46 CFR 10.232(d)(1) allow the use of military service towards credentials when the Coast Guard determines it is equivalent to sea service acquired on merchant vessels.

Additionally, many government owned and operated vessels are operated similarly to a merchant vessel.

The purpose of the sea service requirements for aSTCW endorsement as VSO is to ensure that the mariner is familiar with general merchant vessel operations.

The Coast Guard has determined that sea service onboard certain government owned or government operated vessels of at least 100 GRT counts toward the sea service requirements in 33 CFR 104.215(d)(1)(v)(A) and 104.215(d)(1)(v)(B) as it achieves familiarity with merchant vessel operations.

Additionally, the Coast Guard has determined that by combining (1) up to 5 months of military sea service, (2) 30 days minimum sea service on government owned or operated vessels of 100 GRT or on vessels subject to 33 CFR 104.105, and (3) the knowledge requirements in 33 CFR 104.215, the mariner can demonstrate the necessary operational experience to qualify for the VSO endorsement under 33 CFR 104.215(d)(1)(v)(B). c.

This policy supports the intent of 10 U.S.C. 2015 and Executive Order 13860 of March 4, 2019, Supporting the Transition of Active Duty Service Members and Military Veterans Into the Merchant Marine, by supporting practices that ensure that members of the United States Armed Forces receive appropriate credit for their military training and experience toward merchant mariner credentialing requirements.

CH-1 to Guidelines for Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — 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 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 Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — MAJOR CHANGES. This Commandant Change Notice revises Enclosure (1), to NVIC 21-14,to

allow the acceptance ofsea service aboard certain military and government–ownedor operated vessels to be credited toward meeting the qualification requirements for STCW VSO endorsements.

CH-1 to Guidelines for Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS.

a. The development of this Commandant Change Notice 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 Commandant Change Notice 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 Commandant Change Noticemust be individually evaluated CH-1 COMDTCHANGENOTE 16721 NVIC 21-14 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 Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — DISTRIBUTION. No paper distribution will be made of this Commandant Change Notice. An

electronic version will be located at https://www.dco.uscg.mil/Our-Organization/NVIC/.

CH-1 to Guidelines for Qualifications for STCW Endorsements for Vessel Security Officers, Vessel Personnel with Designated Security Duties, and Security Awareness — PROCEDURE. Remove and insert the following pages of NVIC 21-14:

Remove Insert Enclosure (1) Enclosure (1), CH-1 10.RECORDS MANAGEMENT CONSIDERATIONS.

This Commandant Change Noticehas 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, COMDTINST M5212.12 (series).

This policy does not create significant or substantial change to existing records management requirements. 11.FORMS/REPORTS.

None. 12.REQUEST FOR CHANGES.All requests for changes or questions regarding implementation of Reference (a) and this Commandant Change Notice should be directed to the Mariner Credentialing Program Policy Division (CG-MMC-2), at (202) 372-2357 or MMCPolicy@uscg.mil.To obtain approval for a SA or VPDSD course, please contact the National Maritime Center at (888) 427-5662 or IAskNMC@uscg.mil.

J.

W.

MAUGER Rear Admiral, U.

S.

Coast Guard Assistant Commandant for Prevention Policy CH-1 Commandant 2703 Martin Luther King Jr.

Ave.

SE United States Coast Guard Washington, DC 20593-7501 Staff Symbol: CG-CVC-4 Phone: (202) 372-2357 E-Mail: MMCPolicy@uscg.mil COMDTPUB P16700.4 NVIC 21-14 August 25, 2014 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 21-14 Subj: GUIDELINES FOR QUALIFICATION FOR STCW ENDORSEMENTS FOR VESSEL SECURITY OFFICERS, VESSEL PERSONNEL WITH DESIGNATED SECURITY DUTIES, AND SECURITY AWARENESS Ref: (a) International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended (STCW) 1.

PURPOSE.

This Navigation and Vessel Inspection Circular (NVIC) provides guidance on qualification for STCW endorsements for Vessel Security Officer (VSO), Vessel Personnel with Designated Security Duties (VPDSD), and Security Awareness (SA). 2.

ACTION.

The Coast Guard will use this NVIC and 46 Code of Federal Regulations (CFR) 11.337, 12.625, and 12.627 to determine if mariners are qualified for STCW endorsements for VSO, VPDSD, and SA.

Officers in Charge, Marine Inspection (OCMIs) should 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/g-m/nvic/.

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

DIRECTIVES AFFECTED.

CG-CVC Policy Letter 12-06, International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as Amended, Endorsement(s) as Vessel Personnel with Designated Security Duties and for Security - Awareness, is cancelled. 4.

BACKGROUND. a.

Regulation VI/6 of reference (a) sets forth minimum requirements for security-related training and instruction for seafarers.

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 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 21-14 b.

In 2009, the Coast Guard added a regulation in 46 CFR 15.1113(a) that requires a person serving as VSO on a seagoing vessel to hold a VSO endorsement. 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.

Specifically, the 2010 amendments to the STCW Convention and Code added security-related endorsements for VPDSD, and for SA. d.

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

That rule includes provisions for the STCW security endorsements.

This rule became effective on March 24, 2014.

The Coast Guard is publishing this NVIC to provide guidance on complying with the new regulations. 5.

DISCUSSION. a.

The STCW requires that certain seafarers hold endorsements as VSO, VPDSD, or SA depending on the scope of their shipboard security duties.

The IMO published Circular STCW.7/Circ.17 in June 2011, advising administrations and port state control authorities that mariners may comply with section 13 of the International Ship and Port Facility Security Code (ISPS Code) instead of Regulation VI/6 of the STCW Convention until January 1, 2014.

Recognizing the challenges of ensuring that mariners will hold the endorsements by this date, the IMO has promulgated a circular STCW.7/Circ.21, advising port state control officers, recognized organizations and recognized security organizations that until July 1, 2015, even if a seafarer does not hold an endorsement for security awareness training or for seafarers with designated security duties, it would be sufficient to accept compliance with Section 13 of the International Ship and Port Facility Security (ISPS) Code, Part A.

With a free public account, Circular STCW.7/Circ.21 can be accessed online at http://www.imo.org/OurWork/Circulars/Pages/IMODOCS.aspx > Circulars > STCW > STCW.7.

After that date, pursuant to Circular STCW.7/Circ.17, mariners on vessels of 500 gross tons or more sailing beyond the boundary line established by 46 CFR Part 7 must hold the STCW endorsement appropriate for their shipboard security duties, except mariners serving on vessels that have been determined to be otherwise exempt from, or not subject to, further requirements of STCW under 46 CFR 15.105(f) and (g). b.

In addition to the endorsement requirements for vessel personnel, all contractors, whether part-time, full-time, temporary, or permanent, must have knowledge of the requirements in 33 CFR 104.225, through training or equivalent job experience.

Vessel owners and operators must maintain records documenting this requirement and produce those records to the Coast Guard upon request (46 CFR 15.1113(f)). c.

The security training requirements in the STCW were developed as a progression where “security-awareness” is the lowest level of training and “vessel security officer” (VSO) demands the highest level of training.

Under this progression, VSO training meets the requirements for VPDSD, and the VPDSD meets the requirements for security NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 21-14 awareness.

Therefore, for example, mariners who completed VSO training would be eligible for any position with a training requirement at the VSO level or lower.

A mariner who meets the requirements for a “superior” security endorsement will have their merchant mariner credential (MMC) endorsed for the superior endorsement as well as all subordinate endorsements. d.

This NVIC establishes the policy regarding VSO, VPDSD, and SA.

Enclosure (1) discusses specific requirements for security endorsements, Enclosure (2) provides guidance on approval of courses leading to security endorsements.

Enclosure (3) contains relevant excerpts from the STCW Convention and STCW Code, these are provided for information only. 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 D.

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. 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 the Federal Records Act, Title 44 United States Code (U.S.C.) 3101 et seq., National Archives and Record Administration requirements, and the Information and Life Cycle Management Manual, COMDTINST M5212.12 (series).

This policy does not create a significant or substantial change to existing records management requirements.