PUBLIC SUBMISSION | As of: February 14, 2009 Tracking No. 805a4df2 Comments Due: September 17, 2007 Late comments are accepted |
Docket: USCG-2006-26202
Training and Service Requirement for Merchant Marine Officers
Comment On: USCG-2006-26202-0006
Notice of Proposed Rulemaking
Document: USCG-2006-26202-0025
Brian M. Shea
300 West Ocean Boulevard
Long Beach,
CA,
90802
Please allow me to weigh in on uscg-2006-26202
Regarding the proposal to remove radar observer endorsements from the uscg
license. My concern is where they go, as they currently appear on no other uscg
issued document. Does an unverifiable school issued document now become
another paper I must carry with me and pray never to lose or have stolen?
Perhaps a better solution is to list all certificates and endorsements on one uscg
issued paper (a license) and synchronize the expiration dates. Instead of a one
time opportunity to synchronize the expiration dates, simply always synchronize
the expiration dates. My master’s license, radar observer and stcw all expire at
different times even though I am in the industry for fifteen years.
Regarding an alternate path for mates of tow to enter the industry. I am
wholesalely opposed to this on broad terms. Off-watch masters should not be
asked to bear the liability of licensed mates legally standing a watch yet operating
under the master’s license. This is a mater’s catch 22 of the most onerous sort.
If the coast guard is willing to license a mate to stand a wheelhouse watch and a
company can therefore hire him as such; a master should not be held liable for
the actions of the mate as though they were his own. This entire issue should be
revisited with an eye toward protecting the license and reputation of existing
masters. A fast tracked mate should not be responsible for a tow 12 hours a day
and in essence operate as a limited liability master.
Thank you for hearing my comments.