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(Editors Note: This article is from last year but we think it is still relevant in
Companies and Crews Facing New License
[Source: By Jeff L. Yates,
The Waterways Journal,
July 4, 2005]

Mariners taking exams for Coast Guard licenses today participate in a more equitable
process than those of a few decades ago, according to William Kline, president of The River
School, Memphis, Tenn.

Speaking at a Waterways Industries Association luncheon in Paducah June 22, Kline said
that although daunting and complicated by new requirements relating to service record,
safety, security, radar endorsements, firefighting, and first aid training, today's mariners
actually face a more fairly administered test than those given when he first became involved
in the process as Coast Guard examiner in 1971.

Until the current multiple-choice exams were implemented, mariners answered essay-type
questions administered by examiners who had complete freedom in deciding a mariner's
qualification, based upon his own interpretations of the applicant's essay response and/or
his evaluation of the person's attitude or general character.

"The Coast Guard personnel had wide discretion in how they graded the exam, as to the
kind of questions asked and how the exam was even made up," Kline said.

He said that when he first began as an examiner in Cleveland, Ohio, he was given a box with
index cards from which he was told to pick cards with questions from each section of the
exam and have the applicant respond to them with essay-type answers.

The process usually took a full week to complete, he said. "If you had a question regarding
a particular answer, you had the option to call the individual over to further explain his
answer. If he could explain it well enough, you could say, OK."

It did not take long before it became obvious which questions were the most difficult to
answer and when a mariner walked through the door, he was given a quick once-over.
Applicants judged to be pleasant, clean-cut individuals were given easier exam questions
and "we were more reasonable on how we graded them. On the other hand, if an applicant
was judged to be ‘hippy scum’ we had a whole different attitude," Kline remarked. "The
examiners had that discretion and they could literally vote someone off the island,
depending on their individual preference."

Kline said that was a system that could not last, and Guard eventually developed a multiple-
choice exam that used a system of overlays for grading by individuals who don't necessarily
have any knowledge about the subject. The net result is that the vast majority of Coast
Guard employees working in the licensing program do not have a license "and even of
those that do, we probably would be hard pressed to find even a handful that could operate
a towboat," he remarked.

"Now here we are, 12 years down the road with the operator license (Operator of
Uninspected Towing Vessels, or OUTV) in place since 1972 and an accident at Big Bayou
Canot in 1993, and we've had an effort undertaken by the industry in partnership with the
Coast Guard to develop a new licensing regime that took effect in May 2001."

However, the Coast Guard allowed a three-year "grace period" where currently licensed
mariners were "grandfathered" into the newer licenses.

"The Operator license went away in May 2001, although there are still people who hold that
license and they'll be with us until May 2006," he added. "That license has been replaced
with the 'Master of Towing Vessels' which now requires a display of skill"

Measurement of skills is being added to the licensing process, "but the Coast Guard doesn't
have the people who can do what you people do, and could not judge whether or not an
individual possesses the skill" Kline lamented. "So, we're still going to have to rely on the
industry to provide that evidence and that's the big change in the new licensing regime."

Although the exam still covers the same areas of knowledge in a multiple-choice format, the
prerequisites now also include more accurate and diligent background checks and
certification of service time with proper employer recommendations for first-time
applications. However, passing the same four exams that used to be used for the Operator's
license now only qualifies for a "learner's permit" (a Steersman's license), Kline explained.

A steersman has no authority to operate a vessel without being under the direct supervision
of somebody who holds a license, operator, master or the new pilot license (if he's on the
back watch). "It doesn't matter who he's steering for, he's operating under somebody else's

Kline said, "It's incredible to us (at the River School) that every week we have people
coming through the school who end up with a steersman's license, going, 'What's this?
What do you mean; I can't run the boat by myself?'"

''We're thinking, we're 10 years into a process (from 1993 to 2003) to put this all in place,
and we're into a grandfathering period and now we're even outside that and people still
don't know the procedure has changed!" He said that's probably because, ''We as an
industry are not communicating, or it could mean they (license applicants) don't want to
believe it.

"People still don't understand that the Steersman's license is a limited license….limited in
the fact that you must steer under the supervision of another licensed individual," Kline
explained. "That steersman, having spent the required 540 days as a deckhand and having
met the academic requirements, now has to acquire and demonstrate the skills necessary to
run the boat." He said acquiring the skill means steering for somebody, but it's the Coast
Guard's intention that this not be a passive operation.

"It's the Coast Guard's intent that you all have some sort of training program in place that
addresses all the skill necessary to safely operate a towboat," he explained.

The Coast Guard has provided guidance for what should be included in the training
program, he said, adding that there are basically about a dozen areas of importance. In the
process of the onboard training program, individuals must demonstrate their ability to
perform skills in seven different categories and 35 different functions, he added.

This requirement has brought about the creation of another new term, the "Designated
Examiner." This is a licensed individual who has recent experience, has been trained in
conducting assessments and who is accepted by the Coast Guard.

"So, if individuals apply to the Coast Guard and become designated examiners, they then
can attest to and certify the skills of the people who are training to become pilots," Kline
explained. Company training programs must have somebody who is a designated examiner.
"Otherwise, who's going to do the required signoffs?" he asked.

It all depends on how companies have approached the situation to this point, he said,
whether they have these programs in place.

The Coast Guard maintains a master list of designated examiners, and as steersmen
complete their route-specific Towing Officer Assessment Record (TOAR), the signatures of
the person signing off on the requirements are compared against the master list for
authenticity, he said.

"So, we've added another bureaucratic layer to the process. Once the steersman has met
all the required skill training and has all the sign-offs, he can become a pilot of towing
vessels, Kline said, adding, "Now, here's where it gets confusing."

Kline said that because Coast Guard terminology is blue-water-oriented, they call that
license a "Mate" license. Early on in the process, he said industry officials and training
school representatives told them, (Coast Guard) "Please don't do that to us. We have other
people on towboats called mates. Please don't confuse us."

However, the Coast Guard's response only exasperated the situation, he said. "You can call
that "mate" a "pilot" but it will be up to the mariner to tell the Coast Guard what he/she wants
on their license."

Sometimes if the applicant does not indicate their preference to the Coast Guard the
certificate comes back as mate/pilot, he said.

Further complicating matters, Kline said, is the fact that "Steersman is a Western Rivers
term, but in the blue-water world, it's called an "Apprentice Mate."

"So it's easy to get confused when you attempt to sort your way through this maze of Coast
Guard regulations surrounding the new licenses," he said.

In brown-water terminology, Kline said the license progression is steersman, pilot and
master, "the captain on the boat." He said as of May 2006, every towboat must be operated
by someone holding a "Master of Towing Vessel" license.

"There are all sorts of exceptions to that, involving people with tonnage licenses, such as
1,600-ton or unlimited-tonnage licenses," he added. "There are many possibilities here but
90 percent of the time, people operating towboats are going to have to hold a Master's

Noting that "every towboat has to have a captain," Kline said, "I wonder what they're up to
here." He said a small change in terminology could result in a big difference in legal
responsibility. They took people who were operators and have now made them merchant
mariner officers through the stroke of a pen. "An operator's license was a little bit of an odd
duck in the big scheme of things, he said, explaining that the license was actually a
compromise that served the industry "pretty well" for a long time.

However, a master's license carries with it some notion in the admiralty court that the license
holder is primarily responsible for the safety of the vessel and crew.

"That notion or blue-water terminology may have an unintended consequence," he said,
because the Coast Guard and the courts may look at the license holder and say, "now you
have that 100 percent, 24-hour-a-day responsibility while you are the captain." He said
although that scenario has not occurred yet, "we'll find out when it hits the fan one of these

Kline wondered if there wouldn’t become a shortage of captains after all the new regulations
have become effective for a while. Although there is a structured system for advancement
from steersman to pilot, to captain, obtainable through documented service time and
qualification sign-offs. Kline said he has heard from many mariners who don't necessarily
want the aggravation and extra responsibility of being the captain.

"Maybe they're just going to be happy, just being the pilot."

"Is there anything that's going to make them go from being a pilot to being the master?" he
asked. Responding to his own question, Kline said, "The Coast Guard assumes that
everybody wants to, but we don't know if that's true. Maybe folks will be just as happy
running on the back watch and not having to be the captain."

"This becomes an unintended consequence and implication for you folks trying to crew a
boat. You're going to have folks who hold a pilot's license who cannot be the captain but
that boat's got to have a captain before it goes anywhere.

"Nobody ever sorted that one out to see how it was going to work," Kline said.

Harbor pilots are in a league of their own, according to Kline. He said the Coast Guard
considers harbor work to be a different kind of service, compared to linehaul operations, so
those operators need a different kind of license.

"To go from being a deckhand on a harbor boat to holding a license that allows you to run
the boat, you have to have 540 days as a deckhand, 540 days as a steersman and pass
the four knowledge exams. Then you still have to do the training program and get signed off
by the Designated Examiner."

The unintended consequence of this is that previously a mariner was authorized to operate
a harbor boat on a 100-ton master's license which only required 360 days service. Because
there is generally no half-day's credit for time requirements on a harbor boat, "We've
typically tripled the amount of time it takes to get a license to operate a harbor boat," he
said. The practical impact raises the question of who's going to run the harbor boats.

"We're going to be a while until we figure out how to get enough people into that system to
get enough time to get the training, get the sign-offs to qualify for that license," he predicted.

The problems of the harbor boat license change are probably unintended, Kline said, but
the implications are significant. "The harbor boats are the ones on the short end of the stick
in this whole process."

The River School president said the twists and turns of the new license requirements and
procedures are very confusing and "it's no wonder people don't have a sense of where
they're going with this." He said even at the school and instructor level, "It's hard for us to
keep track, let alone your folks."

From his perspective, Kline said "it's become obvious that the industry is not very good at
giving mariners "a sense of career." It is difficult now for a river employee to predict where
he or she will be in their career in five or 10 years," he remarked.

Currently licensed pilothouse personnel will face another major change next year also. Any
person renewing a license will be required to show evidence of training and participation in
drills, although there is still no format developed for documentation.

Starting some time next year all renewals will be subject to enhanced background
screening, he said. It appears now that each person renewing a license will have to travel to
the Coast Guard fore a digital electronic fingerprint and digital photo. This requirement has
been in place for a few years for tankerman licenses, and it began last month for original
license applications.

This extra security check is going to cause serious repercussions within the industry, Kline
warned. "You’re going to have a number of people who have been running boats for you for
20 years who are now suddenly not able to because a minor infraction or run-in with the
authorities from the mariner’s youthful days has popped up.

"The Coast Guard can say, ‘45 years ago when this guy was 13 years old, he got into
trouble with the juvenile authorities so we’re going to put his application in to the
investigation shop.’ The guy doesn’t get his license renewed and he can’t run the boat for a
period of time," Kline warned. He said he has already seen this happen.

"The unintended consequences of this stuff keep building more and more complexities for
how you guys (towing companies) are going to have to deal with the system."

"It’s not just the people we’re licensing up now. All those who renew the licenses in the
future are also going to have to deal with it," he warned.

"Our folks are not well equipped to understand how to get from point A to point B," Kline
said, because they don’t understand the process now. The old way of training vessel
crewmembers and helping them obtain licenses will no longer work, and individuals can no
longer handle the process by themselves, he said.

"You’re going to have to have somebody who’s champion for that person, to the information,
work the system, make the advancement happen and fight the battles with the Coast Guard."

Kline said the industry needs to push the Coast Guard to create an ombudsman position
within its licensing structure, "whose job is to watch out for the little guy and figure out how
to make it (license approval) happen, not to throw barriers in the way."

Kline said he has heard some industry executives predict that a shortage of pilothouse
personnel resulting from the new licensing program will cause the Coast Guard to retrace
their actions and reduce some of the procedural problems or requirements.

"That’s not going to happen," he warned. "The Coast Guard’s not going to back up on it.
They’ve already moved on. This licensing problem is something they solved three years ago.

"I wish I could give you a rosy outlook here, but I don’t see it that way," Kline concluded. "I
see that were in for hard times."    [ End of W.J. Article]

-by Jeff L. Yates, The Waterways Journal, July 4,