Regional Exam Centers Living On Borrowed Time
(September 1999)
The USCG currently admits its
Regional Examination Centers (RECs) are broken and don't provide the service
needed to the maritime public. The USCG believes drastic measures are needed
to change the system enough so they can repair it and make it more workable.
Unfortunately, the drastic modifications proposed do not seem to address what
are perceived as problems by maritime users of the RECs.
While many in the USCG indicate
no final decisions have been made, it certainly appears the USCG fully intends
to privatize the license/Merchant Mariner's Document (MMD) examinations as a
first step toward closing all RECs and centralizing all administrative
processing at one location nationwide. The intent is to free up the resources
currently committed to the REC program to fund initiatives bringing the U.S.
into compliance with the STCW, 1995 amendments. The USCG points to the
supposed success of centralizing the vessel documentation system in the
National Vessel Documentation Center in West Virginia.
Many in the industry do not see
this as a glowing example demonstrating improved service to the public.
A Public Notice in the Federal Register in September 1998 and ultimate public
meeting in New Orleans in October 1998, coupled with all manner of rumors,
have unnerved many licensed and certified maritime personnel and operating
maritime companies utilizing maritime professionals.
The USCG
licensing/certification process has virtual life and death control on their
professional careers. No mariner can advance without obtaining MMDs and
upgrading their endorsements and licenses. There are four elements of the
licensing and certification system with which mariners are concerned. They
include development of individual license questions and examinations,
evaluation of applicants' experience to qualify to sit for an examination,
administration of the examinations and issuing the final documentation
following the examination.
Mariners generally believe the
license examinations are faulty - the evaluations of experience are unfair and
at best inconsistent from one evaluator to another; and the personnel mariners
deal with seem to have no understanding of their absolute power over the
individual mariner's future. Mariners generally believe the one portion of the
system not broken is the method of applying examinations.
It is most unfortunate the USCG
apparently wants to privatize the one working element in the licensing system:
the examination itself. It is the other three parts of the system most
individuals currently deal with the RECs want repaired.
Up through the early 1960s,
most USCG marine inspection duties (including licensing) were performed by
personnel originally from the maritime industry. They were either from the
USCG's predecessor organization, the Bureau of Marine Inspection and
Navigation (BMIN), or directly commissioned from the maritime under the 219
program (named after the public law requiring one half of marine inspection
personnel be from the maritime). It was one of the few ways a mariner could
get a job allowing him to remain active in the maritime trade and sleep at
home at night. Some of the other shore-side jobs included port captains, port
engineers, classification societies and various repair organizations.
In general, mariners worked
until they were no longer healthy enough to work, there being no retirement or
pension programs. Many died on the job. Only the best mariners got into
government service, classification societies and operating companies ashore.
Most personnel involved in marine inspection held maritime licenses. With
respect to inspection and licensing activities, the inspectors knew ships,
were very tough minded and wanted everything their way, remembering at one
time in their careers, they had been operators of commercial vessels. Many
held top licenses as either Master or Chief Engineer.
All examinations were written
in essay format, no multiple choice. Licensing officers were charged to give
fair license examinations. With all questions in essay format, a good deal of
professional knowledge was needed just to properly grade an exam.
In the late 1950s the USCG
started to convert to multiple choice examinations. The process was not
complete until the mid-1970s. There were many effects of converting the
examinations to multiple choice, not the least of which was that it tended to
eliminate the need for local expertise concerning license examination
questions and instead, centralized it at the Washington level (or wherever the
examinations were prepared - later Oklahoma City). The USCG no longer felt any
obligation to staff licensing examination billets with professional mariners.
From that time on there have been very few if any seasoned professional
mariners involved with the generation of license examinations and the
evaluation of a mariner's experience for a license.
In general terms, commissioning
mariners who are currently sailing is not workable. This source of personnel
has dried up with the implementation of pension programs for sea-going
maritime personnel. Bringing sufficient numbers of new graduates into the USCG
from the various maritime academies would take many years to impact the
system.
Today, the USCG apparently
feels slight obligation to licensed mariners. They see themselves as enforcers
of the STCW rather than guardians of the maritime professional qualifications.
The 1995 amendments to the International Maritime Organization's (IMO),
Standards of Training Certificating and Watchstanding (STCW) require the USCG
alter the way they do business by adding more oversight and enforcement to the
approved training programs called a Quality Standards System (QSS) and
increased Port State Control boardings. The U.S. delegation (USCG) at IMO
actively supported these amendments to STCW. The USCG are clearly the experts
on the contents of the STCW. They negotiated it at IMO and enforce it upon the
U.S. flag anywhere and all countries in the domestic U.S. The STCW is very
important to the USCG.
USCG management has apparently
determined it is more important to alter the licensing and certification
system in order to pay for changes required by the 1995 STCW amendments. They
apparently believe the current system needs drastic modification but are not
sure how best to modify it. They perceive they have a duty to protect the
general public from maritime operations and under-qualified mariners, with no
room for concern for the mariner's interests in any of this. The USCG seems to
be unable to meaningfully develop remedies for problems they acknowledge
exist. It is questionable that more than a very few insightful individuals
within their ranks understand the mariners' concerns.
The one thing that cannot be
done is turn back the clock and restore the system to what it was 50 years
ago. The USCG has the authority to change the system the way they believe is
right and mariners seem to have little or no say in the matter. One ongoing
positive development concerns specific USCG approved courses of instruction
which are designed and approved to generate a licensed individual without a
formal USCG examination. These USCG course approvals are for specific licenses
and circumstances and are held by specific operating companies and training
schools. USCG oversight can ensure that abuses don't occur. These approved
courses have already become a critical source of highly trained and qualified
personnel.
There is no question the USCG's
use of these approved courses as an alternative to examinations is a positive
and necessary step forward, but this program must be expanded only in a
careful and deliberate manner.
One must wonder, if the
military and civilian members of the USCG had to work through the current or
envisioned licensing system for promotion or maintenance of their right to
employment. What would it be like?
