Centralized Licensing - Friend or Foe?
(August 1999)
As discussed in a recent
article, the USCG is now talking openly about centralizing the nationwide
administration of the licensing and certification of seamen and officers into
one location (the actual examinations will be "privatized"). They speak of the
success they have had performing this feat for the vessel documentation
offices and now want to repeat if for the licensing system.
Obviously, they have forgotten
the problems that occurred with the centralization of vessel documentation and
for reasons of their own are reluctant to admit they will probably have
serious problems with this new venture because of the different clientele.
In 1995, the USCG centralized
the vessel documentation process into one office located in Falling Waters,
W.V. The original plan had called for reducing the number of documentation
centers from 15 or so offices around the country to four and then after 10
years to consolidate into one office.
It is not clear why the USCG
did not stick to the original plan.
Speculation is it was probably
some budgetary need, i.e. the greater the reduction in employees used in
vessel documentation, the more money could be spent elsewhere, presumably
where the USCG wanted to spend it. Shipbuilders and vessel owners along the
Gulf Coast insisted the USCG keep the New Orleans documentation office open
with a token staff to be capable of responding to various quick turnaround
issues in order to prevent delaying the sailing (foreign) of a vessel. After
all, the USCG documentation offices act as the county courthouses for vessels
and record important monetary transactions.
At the time of consolidation,
terrific and almost unmanageable backlogs occurred. This was in part due to
large backlogs that had been present in many ports. Relocation of the records
from the various individual ports caused confusion. Computerization did not
work as well in all aspects of the consolidation as had been promised.
Professional personnel also became a problem, as many documentation officers
would not relocate to West Virginia. Training then became an obvious problem.
Most customers of the new
documentation center speak of serious problems, delays, and horror stories
they have encountered over the first years of operation. As an example, the
vessel documentation center answers the phone with a voice mail system. I
personally (two years ago) left more than 10 telephone messages pleading for a
real person to speak with to help me. Out of all the messages I left at the
time, only one was affirmatively responded to and that was 12 days after the
message was left. The archiving activities the USCG is required to maintain
have become extremely difficult, if not impossible, to access in many cases.
To its credit, the USCG has
been able to overcome many of the problems that occurred and today seem to
provide timely, reasonable service, at least to most customers. Many of the
problems that occurred in the first year or two of operation have been
overcome.
It would seem the USCG believes
they can overcome the problems they would encounter with centralizing the
licensing offices in the same manner they dealt with the vessel documentation.
I believe they are wrong. In
case they haven't noticed, seamen are different than vessel owners. Vessel
owners are generally more focused on self-interest than are seamen and
licensed individuals. Vessel owners could survive a serious disruption of
vessel documentation services for a period of years without causing them to
"quit the trade". I'm not sure the same is true for seamen and licensed
officers.
Remember a seaman and a
licensed officer cannot ply their trade if they cannot renew their z-card
(Merchant Mariners Document) or license. The same is not true for a vessel
owner.
Today, all seamen and licensed
officers must renew their documents and licenses every five years in order to
continue to sail. The USCG, in general terms, does not treat seamen or
licensed officers with respect, as USCG management is not made up of personnel
that have sailed in the maritime. Any disruption in the ability to conduct the
mandatory renewals will mean these potential crewmen are not available to go
to sea. As a consequence, vessel operators will have even more trouble finding
licensed and unlicensed personnel to man their vessels.
They will no doubt apply
pressure to our government to solve their problem. This can be done using
often-overlooked provisions of the Kuwaiti Tanker legislation (1988). This act
provides the U.S. citizenship requirements for U.S. flag vessels may be waived
by the Secretary of Transportation or the President if, after an
investigation, it is determined qualified seamen who are U.S. citizens are not
available. Seamen and licensed officers whose authority to go to sea cannot be
effectively renewed, are not technically qualified to go to sea.
The decision to waive the
citizenship requirements is political and not a part of USCG responsibility.
No action by the USCG is necessary, or for that matter, possible. It would
clearly be an issue beyond their control. It does not take a change in law to
"solve" the problem. This could happen under current U.S. law. We could easily
find foreign seamen and licensed officers manning our vessels engaged in
domestic, inland and international trade.
Once we allow foreign seamen
and licensed individuals to sail on U.S. flag vessels in domestic waters, I do
not believe we will ever get them off our vessels. Is there an agenda here?
Does someone want the USCG to make licensing and documentation more difficult?
While the USCG freely
acknowledges the licensing system is broken, they also freely acknowledge they
do not know how to fix it. They seem to believe they can change it radically
to suit their needs because it doesn't work properly today. To change from one
system that doesn't work to another system that doesn't work is not a serious
problem for them.
We have been told, after
centralization, the USCG will concentrate on finding out how to repair the
system. It seems to me, by then, it could be too late.