STCW question for Mr Cavo

[CaptAndrew]

I am in the middle of renewing and just got notice that my STCW will not be renewed unless I get a refresher course or more NC seatime. The issue seems to be that not enough of my seatime was NC or oceans. WTF. I have been working on various vessels that are inspected for Ocean and NC service as Captain or Mate and spend part of the time at least NC, actually about 1/4 to 1/3 of the time. We do the same drills etc wether we are inland or NC so what should it matter? STCW is needed for International work and this is the latest position I have applied for,and have previously done. But that could just as easily be going from USA to Canada via Inland passage or Great Lakes, which is Inland.

OK rant over, is this worth apealling or should I just take the course?

[jdcavo]

I am in the middle of renewing and just got notice that my STCW will not be renewed unless I get a refresher course or more NC seatime. The issue seems to be that not enough of my seatime was NC or oceans. WTF. I have been working on various vessels that are inspected for Ocean and NC service as Captain or Mate and spend part of the time at least NC, actually about 1/4 to 1/3 of the time. We do the same drills etc wether we are inland or NC so what should it matter? STCW is needed for International work and this is the latest position I have applied for,and have previously done. But that could just as easily be going from USA to Canada via Inland passage or Great Lakes, which is Inland.

OK rant over, is this worth apealling or should I just take the course?

It appears the "refresher" course you refer to is for basic safety training. If so, see
NMC Policy Letter 12-01. Note that as used in the policy letter, "seagoing" is considered operating beyond the boundary line (near coastal and oceans).

I can't advise you whether to appeal, but can say that if you request a reconsideration from NMC (the first step in the appeal process), NMC's review will likely focus on whether the policy was correctly applied. If you wish to appeal the policy itself, you would have to appeal the NMC's decision on reconsideration. I can't speak to how that appeal would be received (because I don't know, and because I'm not permitted to talk about pending or potential appeals). But it might be worth considering twhen you decide what to do that the average time for an appeal from the time we receive it until an decision is made is approximately 75 days.