22 AUGUST 2018 • FOGHORN © 2017 Caterpillar. All Rights Reserved. CAT, CATERPILLAR, BUILT FOR IT, their respective logos, ”Caterpillar Yellow,” the ”Power Edge” trade dress as well as corporate and product identity used herein, are trademarks of Caterpillar and may not be used without permission. See our complete offer for ferries and cruise ships at marine.cat.com See the video at storiesfromsea.com PLEASE DO NOT REMAIN SEATED Do not switch of all electronics. Please move around freely. And above all, do not miss the spectacular beauty off the sea. With Cat® high performance engines, the total time of your journey could be the same as flying. Only with better views. And without the leg cramps. cat_ad_ferries.indd 1 08/01/18 22:30 REGULATORYREPORT By Peter Lauridsen, PV A Regulatory Affairs Consultant O n June 11, 2018 the Coast Guard published a Notice of Proposed Rulemaking (NPRM) on Radar Observer Refresher Training. The NPRM proposed eliminat- ing radar observer refresher training for mariners with at least a year of service on radar-equipped vessels when they routinely used the radar for navigation and collision avoidance. The qualifi- cation requirements for the mariner’s initial radar observer endorsement remain unchanged. The NPRM laid out the Coast Guard reasoning for this regulatory change and asked for public comments by July 11, 2018. PVA reviewed the proposal and did submit comments to the docket in support of the proposed changes. The NPRM covered several goals, both statutory and regulatory. Under the heading of statutory, the NPRM provides compliance with the Coast Guard Authorization Act of 2015 that required harmonization of the expira- tion dates of a mariner’s radar observer endorsement with the mariner ’s merchant mariner credential (MMC). The Act also specified that the mariner could not be made to renew the MMC before expiration. Since the radar en- dorsement was based on completion of the refresher course and the MMC had a certain date, the problem could not be solved absent addressing the radar endorsement. The Coast Guard sought input from the Merchant Marine Advisory Panel (MERPAC). Based on MERPAC comments and the analysis of radar prevalence and mariner use for navigation and collision avoidance, “the Coast Guard concluded that the Proposed Changes to Mariner Radar Operator Refresher Training current requirement for the completion of a radar refresher or re-certification course for mariners with relevant and recent service in a position using radar for navigation and collision avoidance purposes on board vessels equipped with radaring not necessary.” Further the Coast Guard determined, “comple- tion of radar refresher training is unnec- essarily burdensome.” To replace the refresher course and to ensure continued qualification for the radar observer endorsement, the Coast Guard has required the sea service letter submitted for MMC issuance to include a statement as to the mariners continued use of radar for navigation and collision avoidance. The statement requires attestation that the mariner served on radar-equipped vessels and, in the course of their em- ployment, used the radar for naviga- tion and collision avoidance. The NPRM also established that mariners that do not have the necessary year of experience must continue to take the refresher course. With the addition of the endorse- ment to the mariner’s MMC, there is no longer a requirement for carrying a separate proof of qualification. However, if for any reason qualifi- cation was achieved subsequent to the issuance of the mariner’s MMC, the certificate carriage requirement remains. This NPRM requires a subsequent adoption of a final rule so the foregoing is still just a proposal. The NPRM docket contains over 70 comments from mariners, training facilities and other interested parties. All comments must be addressed by the Coast Guard in its announcement of a final action.