— The Council of American Master Mariners, Inc. —
CAMM Views & Positions
Views & Positions Home Page
Page last updated on Sat, Feb 16, 2008
Welcome to CAMM Views
Here will be important issues of the day for Masters and your opportunity as a member of CAMM to voice your feedback and provide additional support or testimony in relation to these (or other) subjects. Your input gives CAMM the opportunity to buttress, debunk, and scrutinize items while at the same time allowing time and changing world events to induce reflection by year’s end.
As the Annual General Meeting approaches, the issues of the CAMM VIEWS page will be culled down to issues that have proven to be most substantive. After discussion and debate at the AGM, Official Position Statements will be generated for proposal to The Council. Once approved, these CAMM VIEWS will become Official Positions and will be archived for reference and viewing. CAMM Views & Positions will be numbered using the format of YR-##, where YR is the year position is taken at the AGM, and ## is sequential.
It is our hope that this process will enliven debate, foster greater intellectual curiosity, and better prepare our membership for the forces of change that (it seems) are so often in conflict with our noble profession. We earnestly seek your input and look forward to seeing as many members as possible at the Annual Meeting in San Francisco in 2008.
To enter a formal request for a position topic, or to submit your formal view, please email Captain James Morgan, our Positions Committee Chariman, will review all submissions.
For general discussion, debate, and banter on these topics and many more, please register/login to our forum. It's easy. Click here for more information.
CAMM View 08-01: Oppose US Coast Guard ownership of Merchant Marine Certificates
CAMM stands in opposition of the Coast Guard’s position that they own the new Merchant Marine Certificates and can revoke or recall them at any time without cause as set forth in the Code of Federal Regulations.
The person who has been issued a USCG License to Merchant Marine Officer or Mariner’s document own that license or document. The license or mariner’s document is surrendered to the Coast Guard only on the Coast Guard’s legal request for such license or document.
This is another instance of the Coast Guard’s lack of knowledge and history of licensing and documentation and now coupled with the lack of legal advice by the Coast Guard’s Legal Counsel.
Licensing of Merchant Marine Officers and documentation of seamen must be removed from Coast Guard’s jurisdiction. As it now stands the Coast Guard stands as an issuer, revoker, judge and jury of the Licensed Officer and Seaman. This is contrary to our system of law.
CAMM View 07-08: Director of National Maritime Council Change of Billet
CAMM would like to state the following covering support for changing the Director of the National Maritime Council from a Coast Guard Billet to a Senior Executive Billet. This makes sense as with such a change, the NMC leadership will be one of continuity. As it is now, the Coast Guard Officer is rotated out every 3 to 4 years.
We support such a move as it will enhance the NMC, expand its role and provide for continuity and stability.
CAMM View 07-07: Transfer of Administrative Law Judges from the jurisdiction of the Coast Guard to the Justice Department
CAMM would like to state our support for moving the Coast Guard Administrative Law Judges and their staffs from the United States Coast Guard to the National Transportation Safety Board.
This move should provide the American Merchant Seamen both a fairer approach to his or her misconduct charges and hearing before an impartial Administrative Law Judge.
CAMM View 07-06: Seaman’s Manslughter Act
The Apostleship of the Sea presented a their statement on Criminalization of the Master and proposed changes to the Seamans Manslaughter Act. Please refer to the adjacent text and text published in Spring 2007 Sidelights.
CAMM AGM 2007 attendees vote to reword this statement to better fit our focus on the matter.
CAMM View 07-05: USCG Interim Rule Regards MMDs for Non-US Citizens
The US Coast Guard promulgated an interim rule allowing for issuance of merchant mariner documents (MMDs) to certain non-resident aliens for service in the stewards departments of US-flag large passenger vessels endorsed for the coastwise trade. The interim rule comes into effect immediately. Comments on the rule should be submitted by July 23. 72 Fed. Reg. 20278 (April 24, 2007).
CAMM AGM 2007 attendees voted to table this position until such time as we can gather more information.
CAMM View 07-04: USCG Authority over US Merchant Marine
It has been proposed that the Legal Enforcement Authority over the U.S. Merchant Marine now in the hands of the U. S. Coast Guard, be shifted to another enforcement agency. The stated reason for this change of authority is summed up in this email from Captain Dan Jordan, 2698-R, of Camas, Washington.
“A great position that CAMM could support would be to transfer all of the Coast Guard’s marine safety functions to MARAD. With the CG’s shift to Homeland Security their focus is primarily on Security and Search and Rescue with weakening professional experience in Merchant Marine issues such as Licensing, Marine Inspection, Marine Investigation and Aids to Navigation. MARAD’s pool of professional mariners could return the professionalism and common sense to Marine Safety issues. Best Regard, Dan Jordan”
This proposal was discussed at the February Executive Council of the Seattle/PNW Chapter, and later discussed at the regular meeting on 1 March 2007. The basic premise of the proposal was accepted the Seattle Chapter, but the following concerns and suggestions were added.
MARAD, a government agency, is peopled with both professional mariners and government careerists. Most of these individuals are more adept at handling Administrative Matters than Operational Ones. American Bureau of Shipping (ABS), an American Classification Society, is well versed in handling operational matters, and is currently working with the U.S. Coast Guard to incorporate joint repair and inspection responsibilities. Therefore, The Seattle/PNW Chapter, Council of American Master Mariners, proposes the following: The Legal Authority over the activities of the U.S. Merchant Marine that is now vested in the United States Coast Guard be transferred to a Joint Oversight Entity comprised of the United States Maritime Administration and The American Bureau of Shipping.
All Merchant Marine Personnel functions: e.g. ID Documentation, Licensing, Training, Discipline, etc to be handled by MARAD. All operational functions: e.g. Rules & Regulations, Life Saving Equipment, Repairs, and Inspections to be handled by ABS. CAMM AGM 2007 attendees voted to table this position until such time as we can gather more information.
CAMM View 07-03: IFSMA Advocates Goal-based Manning
Some ships demand more of their crew than others. Therefore, we request manning scales be designed for a specific ship.
CAMM Supports the idea that setting of minimum manning levels by Flag States be “Performance Based”. Consideration of ship type and trading pattern for example, must be addressed versus a “one size fits all” approach.
CAMM AGM 2007 attendees vote to support this position.
CAMM View 07-02: IFSMA’s position on Watch Stander’s Fatigue
CAMM supports IFSMA in their position that fatigue of mariners continues to be of the utmost concern. We further support the idea that establishing a minimum rest period will help to bring about this goal.
CAMM AGM 2007 attendees vote to support this position.
CAMM View 07-01: IFSMA E-Navigation Comments
Have newly installed E-NAV equipment designed and driven by watch standers instead of the technicians.
CAMM AGM 2007 attendees vote to support IFSMA working group discussion on this subject.
CAMM View 06-03: Changes to Physical Guidelines for Merchant Mariners, NVIC 2-98
Opposed CAMM AGM 2007 attendees vote to continue this position, with further text added. Summary text published in Sidelights Spring 2006 and full text on the web. Added text is as follows:
CAMM supports increased rigorous enforcement of existing qualifications for licensing.
The Council of American Master Mariners, having full and due regard for the importance of maintaining physically qualified and capable Masters as dictated by current licensing requirements, and in full appreciation of the overall impeccable safety record such requirements have faithfully yielded over the years, believe the rigorous enforcement of existing statutes is the most effective solution to ensure mariners are physically qualified.