Document renewals: Stay alert to changes or pay the priceFeb 20, 2013 04:02 PM
For decades, unlicensed mariners such as ordinary seamen, able seamen and oilers never had to worry about renewing their merchant mariner document (MMD), since it was issued for life. Officers had to renew their license every five years, and could do so one year before it expired and up to one year after it expired — although they couldn’t work at sea after it had expired. In the mid 1990s, things began to change. For the first time in U.S. maritime history, both licensed and unlicensed mariners’ documents expired every five years. The renewal procedures that previously applied only to officers were now applicable to all.
Considering the involved process necessary to renew a document or license, the restriction posed by the one-year-in-advance rule could be problematic. Pete, a second mate I sailed with just after Standards of Training, Certification and Watchkeeping (STCW) ’95 came into effect, was at work for a total of nine months the year before his license expired. During the remaining three months, he took his physical and drug screen, with the ensuing weeklong wait for the results, and finished his radar recertification class. Then, due to the lack of available courses near where he lived, he had to travel across the country to take a two-week GMDSS (Global Maritime Distress and Safety System) class he also needed before he renewed. With the time it took to get all of that done, plus filling out his application and getting his paperwork in order, Pete submitted his renewal package to the U.S. Coast Guard 10 days before his license expired. His new license and MMD arrived a month later, but by then he had already missed out on two job opportunities due to his expired documents.
I was talking recently with Norleen Schumer, a longtime colleague and maritime licensing expert who is retiring this month. After we discussed her upcoming travel plans and some home projects she and her husband want to do, the conversation came around to when I was going to renew my Merchant Mariner Credential (MMC). I told her, “I’m good until 2015, so I can’t even think about turning in my renewal until 2014 at the earliest.”
She replied, “Not any more, Kelly. When the Coast Guard began issuing MMCs in 2009, they changed the provision that you could only renew a year in advance. Now you can renew anytime during the five years your MMC is good.”
The day after I heard about being able to renew anytime, I called a couple of friends of mine, a designated duty engineer and an able seaman. Because both were planning to renew their credentials in the next year or two, I wanted to pass on the news. When I told them that we could renew our MMC at any time, they were just as surprised as I had been. Although I had felt that I’d been keeping up on the latest developments, the announcement of the new renewal policy on page 11,196 of the Federal Register, Vol. 74, No. 49, on March 16, 2009, had slipped by me. These changes were made into law, and 46 CFR 10.227(b) was amended to state, “A credential may be renewed at any time during its validity and for one year after expiration.”
To their credit, when the Coast Guard changed the MMC renewal policy, they obviously had mariners’ needs in mind. Now we can choose the best time to start the process, without being pigeonholed by the old one-year in advance rule. As a result there is less need to juggle personal/family obligations, financial considerations and work schedules when renewing an MMC.
Recently, I was talking with Dale, a 1,600-ton master who is taking a hiatus from sailing to care for an ailing parent and who will likely not have enough sea-time to keep his STCW ’95 certification valid when his current MMC expires in 2016. At that time, he would be forced to take a basic safety training (BST) refresher class, complete a lengthy open book renewal exercise, and then wait the weeks or months for his new MMC to be issued. By renewing two years into his current credential instead, Dale could keep his STCW endorsement current by using sea-service going back five years from the date of his application, avoiding the need for the open book test and the BST refresher. Since his new MMC would be good for five years starting from the date it was issued, he’d essentially extend his credential two years beyond what it would have been otherwise.
To help keep professional mariners abreast of the many changes affecting our credentials, the National Maritime Center (NMC) website has an “Announcements” section. As a way for the NMC to keep us informed, this is an excellent idea. I have, however, found that the public notices posted there are written in a formal, official style that is not always easy for me to follow and comprehend. I believe the Coast Guard should collaborate with merchant mariners to make the “Announcements” section even more user-friendly, incorporating ideas from MERPAC (the Merchant Marine Personnel Advisory Committee), maritime unions, and even individuals. In addition, I think that the NMC website should include an archived list of mariners’ frequently asked questions and their answers — for as long as they are applicable. These changes would be easy to implement, and helpful to mariners.
With the many changes to STCW ’95 and other laws coming up in the next few years, it is essential that we mariners remain proactive in staying up-to-date. It’s clear that the Coast Guard is interested in making the credentialing process go smoothly. So if you have questions regarding your MMC renewal, call 1-800-IASKNMC, or e-mail IASKNMC@uscg.mil to seek out the answer.
Till next time I wish you all smooth sailin’.
Kelly Sweeney holds the licenses of master (oceans, any gross tons) and master of towing vessels (oceans), and regularly sails on a wide variety of commercial vessels. He lives on an island near Seattle. You can contact him at email@example.com.