Coast Guard creates stir with proposal to eliminate paper licenses
The folks at gCaptain made a post concerning the recent final rule on the consolidation of Merchant mariner Qualification Credentials, often referred to the MMC or Merchant Mariner Credential. Essentially, the Coast Guard is moving to a single credential that documents all of a mariners qualifications and is in-line with international standards. The MMC is going to resemble a passport in size, and therein lies the problem. Merchant mariners have respected and admired with pride the significance of their license. Not only does it serve as a valid license to operate in its capacity, but it is a testament to hours of work, effort and knowledge possessed. One can argue that the medical requirements to serve as a licensed officer may be lacking, but there is no doubt that the licensing process itself is no easy task. I myself can still remember sitting in front of a practice flashing light exam at Kings Point 7 years ago, and wondering how I would ever be able to de-code it.
Draft version of Merchant Mariner Credential
The Master of Towing Vessels Association Forum posted a highly critical piece “Coast Guard Needs to Get Their Hearing Checked”on the final rule, and is well worth a read. There is clearly some very passionate disagreement to this rule. Interestingly, the Coast Guard has been attempting to double its efforts towards improving its relations with the maritime industry. I would imagine the MMC rule may set some of that back a bit. gCaptain’s Coast Guard contact Jeffrey Lantz stated the following concerning issuing a “sentimental” license in addition to the MMC.
The Coast Guard considered whether or not to continue issuing the current certificates; not for proof of qualifications but for sentimental and traditional reasons. The Coast Guard asked the Merchant Personnel Advisory Committee (MERPAC) to consider the alternatives for MMC format. MERPAC recommended that the MMC be a booklet similar in size and design to a U.S. passport. MERPAC also recognized that the current form of license has traditional and sentimental value to many mariners, and recommended that a “suitable for framing copy of the license” remain an option that a mariner can choose to obtain for a nominal fee.
MERPAC
The Coast Guard Merchant Personnel Advisory Committee (MERPAC) is a little known committee that the Coast Guard turns to for input and feedback on “matters relating to the training, qualification, licensing, certification and fitness of seamen in the merchant marine.” For more information on MERPAC:
USCG Homport website – Has the most detailed information, including contact info for all individuals on the committee.
After reading through the MERPAC working groups comments on the MMC rule, this comment stood out as an even more concerning topic than frameable licenses -
MERPAC seeks clarification on why the Coast Guard replaced the term “license” with “credential.” It is the understanding of mariners that term “license” conveys ownership, and cannot be taken away from the holder without due process. On the other hand, a “credential” may be revoked at will. MERPAC seeks assurances from the Coast Guard that the replacement of the term “license” with “credential” is not intended to remove the “due process” requirement before suspension or revocation of license under law. Furthermore, MERPAC is uncertain whether the Coast Guard has the legal authority to change the license structure that is based on statutes.
The bottom line is that the Coast Guard is saying that it knows the importance of this issue, and is continuing to look at the possibility of issuing a “suitable for framing copy of the license” at some point once administrative and legal issues are addressed. I think it is also important that the legal issues surrounding the change from a license to a credential are clearly explained to mariners.
More information on the MMC from the National Maritime Center (NMC):
MMC Final Rule Released, information on the Merchant Mariner Credential consolidation.
