b'REGULATORY REPORTREGULATORY Verify the Validity ofMerchant Mariner Credentials PETER LAURIDSEN // PVA REGULATORY AFFAIRS CONSULTANTA s a maritime employer, do you knowgated to inform their employer within oneAn employer should not rely on the services of how to verify the validity of merchantweek of entering into a resultant settlementa mariner whose MMC is limited in the area of mariner credentials (MMCs) for cur- agreement. While the provisions of the set- employment or one whose MMC is deposited rent and prospective employees? tlement are in force, the mariner is requiredwith the Coast Guard. To assist the employer, toprovidecurrentemploymentinforma- the Coast Guard provides means to determine ThelatestU.S.CoastGuardMarineSafetytion, as well as any prospective employers toif the mariner holds a valid MMC.Bulletin (MSIB 01-22) opens with that ques- the Coast Guard for verification purposes. tion. In our industry comprising a significantFailure to make either notification will beAspecificmeanstovalidateMMCsis populationofsmallpassengervessels,mer- considered a breach of the settlement agree- through the USCG Merchant Mariner Verifi-chantmarinercredentials(MMC)primarilyment. Such a breach will trigger the pre-set- cation tool. An MMC and its endorsements focus on licenses for masters and mates. Ourtlement sanction.industry also has a large portion of seasonal businesses. Turnover of credentialed marinersThe burden of notifying an existing or pro- The burden of is probably not high. However, being a season- spectiveemployerofthesettlementagree-al business our mariners may choose to work inment is on the mariner. The MSIB states thatnotifying an existing other year-round activities and career blue wa- there have been situations where a mariner hasor prospective ter mariners may seek the benefits of locationnot disclosed their status to their employer or and work schedules of the domestic passengerevencontinuedtoworkundertheauthor- employer of the vessel business.ity of a credential where endorsements were suspended or reduced in scope. The MSIBsettlement agreement MSIB01-22isconcernedwithsituationsindicated that mariners with credentials on where a mariners MMC has been subject todeposithadobtainednewemploymentinis on the mariner. a Suspension and Revocation (S&R) action.safety-sensitive positions knowing that many When a mariners MMC has been limited byemployers did not check credential validity in an enforcement action the mariner is obli- the hiring process. may be invalidated, revoked, suspended, or fraudulently altered over the course of the standard 5-year issuance cycle. The verifica-tion tool provides the most current endorse-ment and medical certificate information on the mariners MMC. Incorporating the tool in the hiring process and periodic verification ensures the employer is being properly served by the mariner. The verification tool is browser sensitive and the Coast Guard recommends using Microsoft Edge or Internet Explorer to avoid erroneous reports of invalid MMCs. User vigilance concerning MMCs may give ev-idence of fraudulent documents. If credential fraud is discovered that information should be communicated to the Coast Guard Investiga-tive Service. Reports can be submitted via the CGIS Tips App.For more general questions or concerns relat-ed to specific MMCs and endorsements, the National Maritime Center or their Regional Exam Center are available. FOGHORN 22'