MEPAC March 2017 Task 95 Inland Fire Fighting Requirement's for towing vessel watch officers MASTERS/PILOTS Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

PIROR TO 1999 A FF course meeting Basic and Advance STCW (1) Master’s license for service on vessels of 200 gross tons or less in ocean service. (2) All master or mate’s licenses for over 200 gross tons. (3) All operators of uninspected towing vessels, oceans (domestic trade). OUTV Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

In 1999 FR STCW Basic and Advance Required (1) Master’s license for service on vessels of 200 gross tons or less in ocean service. (2) All master or mate’s licenses for over 200 gross tons. (3) All licenses for master or mate (pilot) of towing vessels, except apprentice mate (steersman) of such vessels, on oceans. Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

FR 24DEC2013 “Implementation of the Amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, and Changes to National Endorsements” FR Notice for the NEW Dec. 24, 2013 stated “This new STCW regulatory requirement will not effect national Mariners National mariners standards are equivalent or exceeds STCW standards “ SO THE MAJORITY OF NATIONAL TOWING VESSELS MARINERS OR COMPANINES PAID NO ATTENTION TO THE NEW STCW REGULATORY REQUIRENMENT UNTIL NMC STARTED TO REQUIRE ALL RENEWALS/ORGINALS TO OBTAIN STCW FF Certificate Prior to issuing MMC. After 2014 Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

Effective Date MARCH 2014 NMC Enforced Mariner’s were caught off guard when they went to renew their license Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

Effective Date MARCH 2014 NMC Enforced License that Require a BASIC 16 Hour STCW COURSE 46CFRSubpart B –Merchant Mariners Officers and Seaman Basic STCW Fire Fighting Required Course for Part 11.201 (h) (3) (i) National Master of 500 tons or less Part 11.201(h) (3) (ii) All National Master and Pilots of Towing Vessel except Oceans Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

Listed below are excerpts from the NPRM, SNPRM, and Final Ruling of STCW regarding the applicability of 46 CFR 11.201(h)(3)(ii). “We do not propose to extend application of the STCW Convention to Inland waters, since the scope of the STCW Convention is limited to seagoing ships “The STCW Convention applies to mariners serving on seagoing ships ’’ The provisions in this final rule that implement amendments to the STCW Convention only apply to commercial vessels operating seaward of the boundary line, as specified in 46 CFR part 7.” “The provisions in this SNPRM which would implement amendments to the STCW Convention only apply to commercial vessels operating seaward of the boundary line, as specified in 46 CFR part 7. The Coast Guard does not intend to apply strict international standards upon our domestic mariners in this regard Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

In the FR under Summary of Changes Adds firefighting training requirements for certain endorsements.   Mandates basic firefighting training for some endorsements on non-ocean services. This is to ensure that mariners with those endorsements have basic firefighting skills and to improve overall maritime safety. Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

After much discussion between USCG/Industry Temporary Relief to Throttle Back NVIC 03-16 Dated June 23,2016 TODAY YOU CAN OBTAIN and or RENEW a National Towing Vessel MMC without any FireFighting training. Until 2019 USCG has exempted (grandfathered) all mariners who had a license prior to 2014 from ever taking a FF course USCG has asked two federal advisory committees for their input on what is the appropriate level of fire fighting training for the Inland National Towing Vessel Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

USCG STANDPOINT It was not in Error to require additional FF training for inland towing vessel watch officers, and not just allow drills and instruction to the crew to suffice It was not intended to require FF training that is not applicable Requesting from the Advisory Committees to assist the USCG in determination of what is the appropriate level of FF training that should be required for National Towing Vessel watch officer specifically Inland Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

TASK/DELIVERABLES 1. Review Regulation VI/1 of the STCW Convention, and Table A-VI/1-2 of the STCW Code, and consider whether the requirements are appropriate for towing vessels in inland service. 2. If the above is not appropriate, provide recommendations for firefighting training requirements for officer endorsements for master or mate (pilot) of towing vessels as required by 46 C.F.R. §11.201 (h)(3)(ii) for vessels in inland service 3. Provide any other recommendations to the Coast Guard that the Committee feels is appropriate for this subject matter. Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

Merchant Personal Advisory Committee (MERPAC) Summary of Report Reached out to Industry, Trade Association, Educator's, and TSAC to share opinions Basically stating the STCW required FF course is not the appropriate course for towing vessel Established minimum training elements for training of towing vessels officers and competences' Agrees that there should be some type of FF training for watch officers on towing vessels The course should be a USCG approved course, or a USCG accepted training or a company training program that meets the training requirement Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

Successfully completes a USCG accepted training program (ii) An applicant must submit to the USCG that he/she has either:   Successfully completed a Coast Guard-approved course covering the following topics: Successfully completes a USCG accepted training program Other accepted methods by the USCG (i.e. a statement attached to a service letter of the mariner) attesting that the mariner has successfully completed the training program in their company that satisfactory meets the training requirement’s above. Under Subchapter M requirements the USCG or an approved Third Party Organization verifies the training program content while reviewing the vessel training requirements for a COI. (see note) NOTE: We feel with Subchapter M compliance the USCG or an Approved Third Party Organization will have to know what these training requirements are, and the company will be required to keep training records that will have objective evidence that this training is completed and meets the elements above. Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

Towing Safety Advisory Committee (TSAC) Meet in April 11-12, 2017 in Memphis Maritime Services Group of Louisian, LLC www.msgola.com Merpac 95

Questions Tom McWhorter tom.mcwhorter@msgola.com Maritime Services Group of Louisian, LLC www.msgola.com Merpac March 23, 2017