Capt. Ted Morley was raised aboard a schooner and has made a career working on board vessels ranging from superyachts to super tankers. During his tenure at sea, he worked his way up from seaman to master. He currently holds a USCG Master’s License, Unlimited Tonnage as well as several foreign certificates. Capt. Morley actively participates in maritime advisory committees in the U.S. as well as overseas and is involved in regulatory policy review in the U.S..
Every December, we take a look at some of the regulatory changes affecting our industry. The USCG’s policy letter, CG-MMC Policy Letter 03-21 (issued in August 2021), states that the USCG now issues endorsements for Master of Self-Propelled Vessels of less than 100 GRT to mariners that currently hold an endorsement for Mate of Self-Propelled Vessels of 200 GRT or greater. Mariners holding an MMC endorsement that authorizes service as mate on inspected self-propelled vessels of 200 GRT or more aren’t required to have the endorsement as master in their MMC to serve as master on an inspected vessel of less than 100 GRT. With this policy, the USCG may now issue a national MMC endorsement as master of self-propelled vessels of less than 100 GRT if they hold any of the following national endorsements:
- Chief Mate of Self-Propelled Vessels of Unlimited Tonnage
- Second Mate of Self-Propelled Vessels of Unlimited Tonnage
- Third Mate of Self-Propelled Vessels of Unlimited Tonnage
- Mate of Self-Propelled Vessels of Less Than 1,600 GRT
- Mate of Self-Propelled Vessels of Less Than 500 GRT
- Chief Mate (OSV)
- Mate (OSV)
- Mate (Pilot) of Towing Vessels
Also worth noting is Section 8316 of the NDA Act of 2021: operators of recreational vessels less than 26 feet in length must use an engine cut-off switch (ECOS) and associated ECOS link when the vessel is on plane. This federal law applies to all operators of all recreational vessels under 26 feet. Regardless of the number of people on board, the operator must use a kill cord in case they fall overboard or leave the helm area. All tenders, small boats, Jet Skis, etc., are affected by this ruling. Local enforcement throughout the U.S. is mounting along with increasing educational policies. This update is in direct response to a number of accidents and fatalities involving small power-driven vessels operating at speed.
Crew must comply with U.S. laws when operating in U.S. waters and territories, while captains are reminded to ensure their crew is aware of these laws and their vessels are equipped to comply. The MCA continues to work on the SV Engineering Program and is currently reviewing the SVE Workshop Skills Training Course, an updated MIN is expected shortly.
The STCW Code is a living document under almost constant review, as are the national-level laws for respective flag states. The goal is to make the industry safer while providing a clear pathway for those seeking employment. The ever-increasing yacht size, vessel complexity, and crew pressures are all factors regulatory agencies look at when they address issues within the industry.
This article originally ran in the December 2021 issue of Dockwalk.