Medical and Physical Evaluation Guidelines For Merchant Mariner Credentials

The United States Coast Guard has issued a Navigation and Vessel Inspection Circular (NAVIC) entitled “Medical and Physical Evaluation Guidelines for Merchant Mariner’s Credentials.” Driven, in part by the Staten Island ferry disaster of recent memory, the general intent of this document is to provide for stricter medical standards for merchant mariners who intended to actively sail on their licenses and / or credentials. Mariners should be aware that these new standards are in the proposal stage only, but also that much of what the Coast Guard has proposed will eventually come into effect. The downstream changes could affect many mariners.

According to the Coast Guard, this NAVIC is intended to ensure U.S. compliance with STCW requirements that specify each party to the convention must establish standards of medical fitness for seafarers. Because neither STCW nor the regulations contained in 46 CFR contain few standards for determining whether a candidate is physically qualified, the Coast Guard says that “this NAVIC provides guidance to assist medical personnel in conducting these (physical) examinations. The NAVIC also recognizes the arduous nature of sea service which can impose unique physical and medical demands on all crew members. All crew members need to be medically and physically fit to perform their duties ??" routine and emergencies. The NAVIC further stipulates that these new guidelines apply to ALL merchant marine physical examinations.

In the future, the Coast Guard intends to require medical personnel who conduct medical exams of merchant mariners, most of whom they say do not knowledge of shipboard duty requirements, to use the information contained in this NAVIC to determine if applicants are physically and medically qualified to perform their duties. More importantly, USCG personnel who review these applications and medical examination results will use the same standards.

The proposed medical standards contained in the NAVIC cover a wide spectrum of medical issues, including but not limited to color vision, visual acuity, hearing, speech, cardiac, pulmonary, gastrointestinal, genitourinary, orthopedic, endocrine/metabolic diabetes mellitus, hematologic/oncologic, neurologic, psychiatric, allergies, infectious diseases, medications, HIV-AIDS and other miscellaneous conditions. All of these proposed requirements, as a combined effect, could present one of the most comprehensive and stringent medical standards in effect today, for any job classification.

By one count, there are over 200 potentially disqualifying conditions which might prevent a mariner from making a living, but this in itself does not constitute a cause for panic; at least not just yet. In situations where an applicant does not meet the guidelines specified in the NAVIC, but is still able to function effectively and perform all requirements and emergency duties, the Officer in Charge of Marine Inspection (OCMI) may recommend that a waiver be granted. But waivers ??" except in certain cases ??" must be approved by the National Maritime Center (NMC).

The new proposed standards are complex, specifying different levels of physical examinations for different licenses and credentials. For example, medical certification standards which would apply to licensed applicants will not be required of entry level ratings such as ordinary seamen, wipers and / or a steward’s department food handler. More than one industry observer has cited the inequities inherent in such a standard and the questionable wisdom of applying a lesser standard to someone who will likely have to perform far more physical work than his licensed superiors.

In a similar light, the proposed rules will require licensed pilots to undergo annual medical reviews, but personnel acting as “pilots” ??" of which there are many credentialed mariners ??" but lacking formal licensing will not be subject to annual medical review. Accordingly, all of these issues and more are being addressed with the Coast Guard in a formal manner through the Merchant Marine Personnel Advisory Committee (MERPAC). MITAGS and the IOMMP are actively involved with this process.

The new proposed rules are not a done deal. Many issues are still on the table and MERPAC is addressing each and every one of them. These concerns include:

• Privacy of Mariners with regard to their own medical history / data. Who will have access to this new data and why?

• Obtaining a Waiver: documentation / costs and sheer the numbers of these requests might overwhelm the Coast Guard. For example, will there be a mandated maximum turnaround time for medical waiver decisions?

• Personnel Shortages ??" new proposed requirements have the potential to exacerbate the present shortage of senior officers in the deep sea sector of the industry.

• Uniformity of Medical Standards: Why do the standards not apply to all rating equally across the board?

These and other issues are left to be resolved with the Coast Guard. Currently, there is no word on when the final draft will be released or what changes to the draft NAVIC might be contemplated. What is for certain is that the new standards, in whatever form that they may take, will complicate document renewals and change the way that original documents are issued.

Mariners who want to stay ahead of the curve should maintain good fitness and stay on top of your medical conditions. Secondly, get out of the habit of waiting until the last possible moment to put together the necessary requirements for your license or document renewal. The Coast Guard recommends that you start the process at least six months in advance. That’s good advice.