R.I.P. MERPAC: 1992 – 2010?
First established in 1992 at the request of the Coast Guard Commandant, the Merchant Marine Personnel Advisory Committee (MERPAC) advises 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 merchant marine. The Committee acts in an advisory capacity in accordance with federal guidelines – or at least it did until the Coast Guard announced that the regularly scheduled September 2010 meeting had been cancelled.
In an August 6 E-mail message, the U.S. Coast Guard’s Mayte Medina told all 19 MERPAC committee members, “I am writing this email to inform you that the Fall MERPAC meeting scheduled for September 8th and 9th in San Diego has been cancelled due to not having a signed committee charter…We will keep you informed of any future developments. If you have any questions, please feel free to contact me directly.” In a nutshell, each advisory committee, formed under the Federal Advisory Committee Act (FACA) has a charter that forms the committee and spells out their duties. Renewed every few years, the charters all go to the Secretary of the Department (in the case, DHS) for signature. The same is true with the nominations of committee members. And according to one MERPAC member, “Right now, the MERPAC charter is waiting for a signature, and the committees cannot meet because the money for the meeting cannot be spent, without a charter in place.” And there, you have it. The only unanswered question is why?
Does MERPAC Matter?
To be fair, the absence of MERPAC input won’t prevent the U.S. Coast Guard from considering feedback from the general public in advance of their internal STCW deliberations. And despite a tight-lipped approach to the process that fairly rivals the MARAD theory of “no information is good information,” they have also signaled their intention to publish a Supplemental NPRM as a next step. The SNPRM would describe any proposed changes from the NPRM, and seek comments from the public on those proposed changes. Arguably, input from MERPAC would have been better structured, far better informed and of greater value.
The new additions to the STCW code could have a far reaching effect here in the States. As such, the Coast Guard will have a host of issues on their plate, because the sweeping overhaul of the rules include, among other things:
· Improved measures to prevent fraudulent practices associated with certificates of competency and strengthen the evaluation process (monitoring of Parties' compliance with the Convention);
· Revised requirements on hours of work and rest and new requirements for the prevention of drug and alcohol abuse, as well as updated standards relating to medical fitness standards for seafarers;
· New certification requirements for able seafarers;
· New requirements relating to training in modern technology such as electronic charts and information systems (ECDIS);
· New requirements for marine environment awareness training and training in leadership and teamwork;
· New training and certification requirements for electro-technical officers;
· Updating of competence requirements for personnel serving on board all types of tankers, including new requirements for personnel serving on liquefied gas tankers;
· New requirements for security training, as well as provisions to ensure that seafarers are properly trained to cope if their ship comes under attack by pirates;
· Introduction of modern training methodology including distance learning and web-based learning;
· New training guidance for personnel serving on board ships operating in polar waters; and
· New training guidance for personnel operating Dynamic Positioning Systems.
Medina told MarPro on Tuesday, “For the Coast Guard, cancelling any advisory committee meeting is always a significant event since this is one of the most direct ways for the public to provide their input to the Coast Guard. In this case it is significant because MERPAC had some tasks in support of the implementation of the 2010 amendments to the STCW Convention that will come into force on January 1st, 2012.” Indeed. Also up for discussion in January – something no doubt the MERPAC members would have liked to weigh in on formally – is the potential for increased sea time for American state maritime academy cadets. Without a doubt, the timing of the meeting’s cancellation is both curious and potentially crippling to the interests of U.S. commercial mariners. Another MERPAC committee member, who also declined to be identified, characterized the ill-timed bureaucratic snafu as “simply awful.”
The Maritime Industry Responds
Stepping in to fill the considerable void left by the temporary (?) drydocking of the MERPAC folks is the industry-led Shipping Operations Cooperative Program (SOCP). According to Glen Paine, Director of the Maritime Institute of Graduate Studies (MITAGS) in Linthicum, MD, SOCP will meet at MITAGS (also on September 8-9) to discuss the full range of subject matter related to the so-called “Manila” STCW amendments. SOCP already addresses and promotes commercial operations through the identification, development, and application of new methods, procedures, and technologies. With SOCP’s overall objective to improve the competitiveness, productivity, efficiency, safety, and environmental responsiveness of U.S. vessel operations, the effort makes perfect sense. All U.S. based vessel operators and organizations that support vessel operations are eligible to participate in the program.
How the SOCP rescue effort will be received by the regulatory part of the equation – the U.S. Coast Guard & its parent, DHS, in this case – has yet to be determined. Paine thinks that SOCP can contribute in much the same way as MERPAC and furthermore told MarPro on Tuesday that the Coast Guard could use the input. In the still muddy wake of the less-than-steady inception of the new National Maritime Center in West Virginia, he is probably right.
Marpro also learned this week that the “charter” for MERPAC – and in fact, more than one maritime committee – has already been written and submitted to the Secretary of DHS. In the end, this probably has less to do with the Coast Guard than it does with high-level, White House politics. And, if DOT can take 19 months to vet, choose and swear in a Maritime Administrator, then what’s to say that DHS can’t spend a similar amount of time playing a game of chicken with the livelihoods of America’s professional mariners?
Apparently, and with the stroke of a pen, the DHS Secretary can put MERPAC back in the game, allowing nineteen industry subject matter experts to do what they do best – counsel the Coast Guard as it moves closer to critical STCW and regulatory decisions. You have to wonder what she is waiting for. The Coast Guard can’t say, MERPAC members don’t know, and the shape of the regulatory climate for marine personnel in this country for the next couple of decades, literally hangs in the balance. None of that seems quite right to me. – MarPro
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Joseph Keefe is the lead commentator of MaritimeProfessional.com, a licensed mariner and a 1980 graduate of the Massachusetts Maritime Academy. His ongoing efforts to achieve STCW compliance for his marine credentials continue; online and in the brick-and-mortar environment. You can read about these efforts here or in print in MarineNews and in The Maritime Reporter magazines. He can be reached at email@example.com
or at Keefe@marinelink.com
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