b'HOW PVA BENEFITS YOUGuards position that a medical certifi - may differ from the medical certifi ca- Reporting Material Changes in cate can be held or cancelled withouttion determination because they areMedical Condition for Marinersinitiating suspension and revocationbased upon different standards. ThePVA sought further explana-procedures against a mariners cre- Merchant Mariner Medical Manualtion about reporting requirements dential. does not preclude marine employersand the role in which the National from establishing more rigorousMaritime Center (NMC) will play in Fitness-for-Certi cation Versusmedical or physical ability guidelines;investigating changes to a mariners Fitness-for-Duty however, there are additional laws andmedical condition by asking: As there However, PVA in its comments alsoregulations that apply. currently is no regulatory duty to report raised questions about several parts of the manual and asked the Coast Guard for clarifi cation. One such area was the determination of a mariners fitness for duty. Coast Guard responded, in the final Manual supplemental informa-tion, stating, The Medical Manuals purpose, is to provide guidance for evaluating the physical and medical condition of applicants for merchant mariner medical certifi cates. And goes on to say that making a determination of fi tness for certifi cation is distinctly different from making a determination of fi tness for duty.The Coast Guard describes fit-ness-for-certification as evaluating if the applicant meets the medical and physical standards, as outlined in the Code of Federal Regulations, based upon the information available to the Coast Guard at the time of the certification decision. This decision is necessar-ily a snapshot of the mariners medical and physical condition at a single point in time. 4416-CTC Tour BoatThe Coast Guard went on to discussCOI 49 passengers + 3 crewthe separate considerations of marine employers when evaluating fitness-for-duty, stating an individuals fit-ness-for-duty status is not static, thus it should be considered whenever an individual reports for duty. Fitness-for-duty status can change suddenly due to an acute illness, injury or incident. The Coast Guard added, Some maritime employers may choose to establish medical and/or physical ability requirements for their employees that are more stringent than the Coast Guard medical certifi -cation standards based on factors such as specifi c duty requirements, austere work environments, and operationalRaising the Standards for Passenger Vesselstempo. In these cases, the employ- sales@armstrongmarine.com | (360) 457-5752 | www.armstrongmarine.comers fitness-for-duty determinations OCTOBER 2019FOGHORN 37'