Red Right Returning scoop! Monday’s Federal Register will include this document:
Consolidation of Merchant Mariner Qualification Credentials; Final Rule
OK, not much of a scoop: there isn’t really any surprises here. What this does is put into law the fact all your USCG Credentials will be bundled in to one document, and that the USCG is getting out of the Security Threat Assessment (STA) business; aka background checks and fingerprinting. We all knew this was in the works. I blogged about this here, and this quote from the opening paragraphs of the Final Rule pretty well sums it up:
This rule will minimize these redundant credentialing requirements,and ease the burden on merchant mariners. The Coast Guard is streamlining its mariner regulations and consolidating the four separate credentialing documents into one Merchant Mariner Credential (MMC). In addition to reducing the number of credentials a mariner will need to hold, this rule also eliminates redundant burdens and government processes.
One change I didn’t know about:
As an agency, we have decided not to continue to issue continuity licenses, but rather only documents of continuity. Should a mariner choose to obtain a TWIC, but seek to obtain an MMC for continuity purposes only, they will still receive a document of continuity. This decision is based on a desire to consolidate as many of our pre-existing credentials into the fewest number of mariner credentials as possible.
A continuity license is a renewal option that would preserve your status as having passed the original license test, so you don’t have to take the test again even if you don’t meet the requirements for renewal (like a lack of sea time, or a temporary physical disability). Beginning April 15, they won’t issue continuity licenses, but instead some kind of note from your mother that will accomplish the same thing. I doubt this applies to any of you, but I like to be thorough.
The USCG has reiterated their firm conviction that all licensed mariners will get a TWIC. A quote from the comments section of the final rule includes:
The TWIC final rule requires a mariner holding a credential issued by the Coast Guard to apply for and activate a TWIC prior to April 15, 2009. After this date, a mariner failing to hold a TWIC would be in violation of this requirement, and the Coast Guard may begin suspension and revocation (S&R) proceedings.
I have been poking around trying to get the USCG to commit to what “may begin” actually means. So far, the only answer I got was:
We will not provide comprehensive details of how, when, and where we will conduct enforcement of the TWIC requirement among merchant mariners.
Now, maybe they get to choose the “when, where, or IF” of enforcment proceedings, but I believe the “how” is actually part of the US Code. See 46USC7702 and 46USC7703, documents that are not exactly top secret. More on this to come.
