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MERPAC: Mariner credentialing needs tweak, not TWIC (5/1)

The Merchant Marine Personnel Advisory Committee (MERPAC) recently finalized recommendations on mariner credentialing, in response to a supplemental notice of proposed rulemaking (SNPR-USCG-2006-24371) titled “Consolidation of Merchant Mariner Qualification Credentials.” The committee noted that in response to the original notice of proposed rulemaking, MERPAC recommended that the elements in the Transportation Worker Identification Credential (TWIC) be incorporated into the existing merchant mariner document (MMD, also known as a z-card) “as a far more efficient system than requiring mariners to obtain a TWIC…. MERPAC is still deeply concerned that the Coast Guard and TSA have grossly underestimated the resources necessary to set up a national identity document system for all maritime-related transportation workers. Coast Guard resources will be further taxed as they simultaneously move the National Maritime Center from Virginia to West Virginia, implement the new medical NVIC, and complete the final rule on STCW95. This combination has the potential for causing great harm and confusion to mariners and the maritime transportation system.” The committee specifically recommended to the Coast Guard “that the most efficient system would be to incorporate the elements of the TWIC into the MMD, and remove mariners from the TWIC rulemaking. Additionally, the existing licensing system should be left unchanged.” Among MERPAC’s other recommendations: Require individual self-disclosure in the application process only for incidents that have occurred since the last application. Make the new merchant mariner qualification credential (MMC) compliant with International Labor Organization Convention No. 185 so that it can serve as the Seafarers Identity Document. Have the Coast Guard and TSA develop an interim clearance process for mariners so they’re allowed to train and work while awaiting a final determination. In the event that MERPAC’s recommendation that the MMD and TWIC be incorporated into the same document is not implemented, mariners should be issued a TWIC and MMC within two weeks of application unless underlying information is missing, or security/suitability/safety issues arise. The application and appeals processes, respectively, must be clear, precise and allow mariners to track where they are in the progression. The hearing and vision tests under 46 CFR 10.215 should be harmonized with the comments issued by the MERPAC Medical Working Group. Established in 1992, MERPAC’s stated purpose “is to advise the Secretary of the Department of Homeland Security (DHS), via the Commandant, U.S. Coast Guard, on matters relating to the training, qualification, licensing, certification and fitness of seamen in the U.S. merchant marine. The Committee acts in an advisory capacity in accordance with 5 U.S.C. App. I (1976), the Federal Advisory Committee Act…. The Committee consists of up to 19 members who have particular areas of expertise, knowledge, and experience in the maritime industry.” MERPAC’s home page may be accessed HERE ###