Policy changes at the National Maritime Center irk industry training schools and mariners. Will this undo more than 18 months of progress?
Just when you thought it was safe to assume that the Coast Guard had indeed backed up its promises to streamline and improve its mariner credentialing with real action, the maritime industry is once again pushing back with claims that the process is moving in the wrong direction. In a letter dated 6 May 2010, the Maritime Institute of Technology & Graduate Studies (MITAGS) challenged NMC to amend certain policy changes and additionally to address other failings that adversely affect mariner testing and credentialing. The new rift has the potential to undo more than a year of carefully orchestrated efforts at the Department of Homeland Security to regain the trust of industry, mariners and the training facilities that service them both. How DHS responds to the latest round of criticism will almost certainly define what happens next.
The Coast Guard’s ambitious centralization plan for mariner credentialing last year culminated in the creation of their gleaming, brand new National Maritime Center (NMC) in Martinsberg, West Virginia. When NMC effectively removed most of the authority from local Regional Exam Centers (REC), the move was not initially well received by a maritime community which felt that it had been badly served in the previous decade. But, with service to the mariners clearly deteriorating and anger building because of that metric, the Coast Guard knew it had to do something to change direction.
It was last September when the rocky transition finally appeared to be moving in the right direction. A quarterly MERPAC meeting provided the perfect backdrop for NMC to show off their new digs, boast of virtually no application backload and a larger, much-improved medical branch. The mammoth, three story building appeared to house a tightly run operation that was finally getting its arms around the task at hand. Less than 7 months later, however, some in industry remain unconvinced.
- New Issues: a Familiar Pattern
The Coast Guard’s NMC is led by Captain David C. Stalfort. Stalfort's vision to “bring the NMC into the 21st century by updating our technology ability to process credential in the most efficient and effective manner,” is today contradicted by new accusations that policies at NMC “have a significant negative impact on mariners and ship operators.” Specifically, the MITAGS letter sent to the NMC’s Mariner Training and Assessment Division – also copied to MERPAC, MESC and SOCP representation – complains of four primary failings:
1. NMC Policy Requiring the Removal of the Training and Assessment Information from the Course Completion Certificate;
2. Removal of the Approved ‘Course by School’ List from the NMC Website;
3. Requirement to Take 500 Tons Oceans and 1,600 Near Coastal Exams Modules; and
4. Errors in the NMC Question Database Pool.
There were other complaints, too. We spoke to a number of parties about the letter, including MITAGS and an industry licensing consultant who declined to be identified for the purposes of this article. In a balanced, but pragmatic response to our queries, the consultant told MarPro on Monday, “To be fair, the entire process at NMC has gotten a lot better. The e-filing procedures have streamlined many things, and in cases where we have had to appeal a particular ruling, we have had some success with NMC listening and reversing their decisions on more than one occasion. The problem, as I see it, is that these successful appeals are not translating into precedents that change policy.”
The issue of training certificates also came up. It turns out that the Coast Guard is accepting facsimile transmission copies of training and certifications, along with the e-process. And, while this is certainly convenient for all concerned, it also raises the possibility of fraudulent credentials being altered for submission via FAX. The Coast Guard is clearly moving towards their “trusted agent” goals as a method of further streamlining the credentialing process, but the idea is still in its infancy. Beyond this, an organization that brought all of the MMD and license production machinery to one secure building for the purpose of preventing another Puerto Rico-style forgery debacle is also probably not ready to assume that facsimile training certificates received from just anyone are, in fact, authentic.
Back at MITAGS, a spokesperson was careful to say that “NMC is trying to get it right.” At the same time, that individual also told MarPro, “We fear that the bureaucracy may be moving in the wrong direction. The right decisions are being made on the local level. But, making a mariner take 11 exam modules when 6 would suffice for the same material, cannot be characterized as progress.” It would not be much of a leap to say that this sort of thinking could very well give renewed weight to a skeptical group of stakeholders who say that the move away from the local service formerly provided at 17 Regional Exam Centers (REC) was flawed from the beginning. A source at MERPAC told MarPro this week that they were, for the time being, taking a “wait and see” attitude before launching any sort of action on their own.
Separately, Captain Stalfort addressed the growing litany of complaints being directed at NMC. Well aware of the consequences of failing to execute the mission using the considerable tools now at his disposal, Stalfort also hoped to dispel the impression that NMC was falling down on the job. Right off the bat, NMC’s commander contended that the additional information being added to Course completion certificates was confusing and the decision to order removal of some of this information was rooted in an ongoing effort to standardize the certificates across the full breadth of the licensing spectrum. With regard to the changes in the NMC Web site data, he conceded that some information had, as MITAGS claims, been taken off of the site, but that other enhancements had given mariners a number of ways to access information that they had not previously been able to use. And, he added, “There is more in the way of changes and improvements coming soon.” Indeed, a MarPro ‘prowl’ around their WEB site revealed 3 or 4 different ways to access course and location information.
Complaints that alleged little coordination between different testing protocols and unnecessary overlapping of testing modules for different licenses prompted Stalfort to state simply, “There is logic to the structure now in place.” The issue of errors in the Exam Question Database was also addressed. He explained that a “protest process” was in place at NMC; one that played “a big part in our correction procedures.” More than that, he insisted that an internal QC process screened all questions before they were published and that NMC “regularly asks for input from outside industry sources such as MERPAC and TSAC.” That said, he also conceded, “Do we makes mistakes? Yes, we are human.”
Finally, Stalfort defended the appeals process in place at NMC. He reminded MarPro that any decision can be appealed and claimed that fully one-third of all appeals resulted in a reversal of the original decision and that typically this involved a medical NAVC issue. Beyond this, he also indicated that all appeal decisions automatically triggered a review at headquarters with the final word coming from ADM Cook, the Director of Coast Guard Policy Prevention. To those who would say that the appeal process had little effect on changing policy when the Coast Guard got it wrong, he said, “We have a good system in place. Can we get better? Yes. But regulations and policies sometimes can’t get changed overnight. There is a process in place for that, as well.”
- Time and People: Marching On Quickly
Tuesday marked the Coast Guard’s time honored change-of-command ceremony, with ADM Thad Allen being relieved by ADM Robert Papp. In a similar ceremony to take place on June 23rd, Captain Anthony Lloyd will officially take command of NMC from Captain Stalfort, who will step down and retire after more than 29 years in the Coast Guard. Fully 16 months after the last U.S. mariner credential was delivered from a local REC, most of us can barely remember the ugly, July 2009 hearings on the Hill, where scores of maritime industry advocates excoriated DHS for poor performance and service in the credentialing mission. A lot of water has passed under the bridge since then. Captain Lloyd will inherit from Stalfort a credentialing system that is arguably in much better shape than what Stalfort was called upon to step into the breach during the centralization of NMC.
According to information obtained from the Coast Guard’s NMC WEB site, NMC today handles approximately 300,000 plus actively employed merchant mariners and maintains records on more than 2 million mariners around the world. The broad scope of resources being thrown at this mission by DHS should, in a perfect world, be more than adequate for the Coast Guard to efficiently administer to more than 200,000 domestic mariners, who collectively demand as many as 6,000 credentials every month. Nevertheless, industry this month said there is still a long way to go.
- Looking Ahead, Looking Back – and Learning from the Past
One letter does not necessarily mean that the Coast Guard’s mariner credentialing mission and its shiny new NMC are in trouble again. And, to be fair, MITAGS doesn’t speak for everyone. On the other hand, the MITAGS/PMI connection is one of the nation’s largest, well-respected providers of maritime training. As such, they just might be the 600 pound gorilla in the room. And when it comes to the Coast Guard’s credentialing mission, it has been my experience that “where there is smoke, there’s usually fire.”
Almost ten years ago, a seemingly disconnected event (9/11) ended up draining mission capabilities from virtually the entire portfolio of other Coast Guard missions in order to properly address the looming fears of vulnerable port security. Arguably, it was the right thing to do. Also a byproduct of that action was the abject neglect of the credentialing mission for an extended period of time. Today, there’s a similar sized problem brewing in the U.S. Gulf, where an oil spill has already tested, stretched and arguably broken the capabilities of the system in place to respond. Will that ongoing event also drain resources from the NMC’s missions? Dave Stalfort says emphatically, “No.”
Stalfort doesn’t buy into my 9/11 theories; at least not entirely. He points out that the lack of adequate resources for the credentialing mission were already a critical issue, well before September of 2001. “The advent of STCW had more to do with it than anything else,” he insists. He added for emphasis, “We were, once again, doing more with fewer resources.” He dismissed the idea that the BP Gulf Oil Spill could have a similar impact on NMC today, explaining, “Today, the majority of human resources at NMC are civilians and not military. Civilians are much less apt to redeployed or surged to other missions. That’s not to say we haven’t been helping out down there – we have.”
It is unlikely that the Coast Guard will make the same mistake twice when it comes to administering to a needy group of American merchant mariners. The drama playing out today – in the field, at NMC and on board the nation’s commercial fleets – is ample proof that the quest to improve marine credentialing is still very much a work in progress. (Captain) Anthony Lloyd will therefore have his hands full when he takes the helm on June 23rd. Industry will be watching to see that he doesn’t veer very far off course. – MarPro.
Joseph Keefe is the lead commentator of MaritimeProfessional.com. He can be reached at jkeefe@maritimeprofessional.com. MaritimeProfessional is the largest business networking site devoted to the marine industry. Each day thousands of industry professionals around the world log on to network, connect, and communicate.