BACKGROUND - The following question came from a 1990's SUNY Maritime graduate (a naval architect) about his first experience in renewing his license:
"What is the proper definition of "working in the maritime industry? Just recently I renewed my Third Mate’s license. Regarding the fact I have absolutely no sea time, I was questioned of my employment as a naval architect. It is stated, and is also what we were told to believe at Schuyler, that if you could not sail on merchant ships, that working in a maritime related industry, and proof of that would be sufficient in renewing your license. At the USCG ... Examination Center I was told that being a naval architect had no maritime relation to renewing my license and that I had to be working in a shipyard building ships."
"What gives? I could be a merchant chaplain working for [XYZ] Shipping Company. What exactly is the definition the Coast Guard is looking for regarding working in a maritime related industry? This is something that needs to be addressed for those whom are not sailing on their license and would like to renew every five years. Four years of training at Fort Schuyler is motivating enough to not let your license terminate itself."
NFFS sent the original memo to several graduates who are connected with the Coast Guard to get their reading of "Maritime related industry" issue and license renewal. Here are some of their responses, which came promptly and seemed to the editor consistent and responsive to the query.
RESPONSE # 1: "..in regards to service that is creditable towards renewal - the regulations are not specific; however, they offer general guides in that they look for service that is directly involved with the operation or construction of vessels. This is a grey area. If you feel that your service meets the intent of the regulations, you may appeal the decision of the evaluator. The first appeal should be made to the local office. If the appeal is not resolved there, there are two other levels of appeal open to you."
"The only difference in the renewal process for someone who has closely related service is that a person with closely related service is only required to take an open-book exercise on the rules of the road for a deck officer (nothing for an engineer.) An applicant who has worked in a position that is not closed related service must complete a 70-question exercise on general professional knowledge."
RESPONSE #2 - "The term ‘closely related service’ is not well defined. The closest guidance is in the regulations where it talks about equivalents for licensing purposes. In 46 CFR 10.211 it speaks of service as a port engineer, shipyard superintendent, and instructor service at a school of navigation or marine engineering. Other service may be considered."
"Being a naval architect myself, I can see why Mr/Ms? thinks he/she has been slighted. I can also see why the Regional Examination Center hesitated to consider such service at first blush. Some naval architecture work is closed related to and similar to that of a Port Engineer - out in the shipyard, down in the vessel, etc. For other naval architects, the closest they come to a vessel is the 3-dimensional model on the company computer-aided-design system. I doubt that many working in Regional Examination Centers know much about naval architecture. Each case is different and must be evaluated on its merits."
"If an applicant feels aggrieved by the decision, there are appeal provisions. The only difference in the method of qualifying for a renewed license is that someone who does not have closely related service must complete a 70-question open book exercise to demonstrate continuing, basic, professional knowledge."
RESPONSE #3 - "I don't deal with licensing issues at all but found out some info for you regarding the problems mentioned in your e-mail." "46 CFR 10.211 talks about creditable service and equivalencies for licensing purposes." "When I went to [city deleted] a few years ago to renew my Master's license I encountered the same treatment; and I work for the...CG.. ! It was a major pain and I voiced my displeasure to the Regional Exam Center (REC) Program Manager from the National Maritime Center (NMC). I'm sorry to hear things don't seem to have gotten any better in [city deleted]" "As a member of the public, I would recommend that, if anyone has a problem with the treatment they receive at an REC, they should first contact the NMC. Their number is (703) 235-0018. When connected ask for the Regional Exam Center's Program Manager. If they want to write a letter their address is: National Maritime Center (NMC) - 4200 Wilson Blvd., Suite 510 - Arlington, VA 22203-1804."
EDITOR’S NOTE: Due to the specialized subject of this issue it was only distributed to alumni and faculty subscribers.
