Coast Guard: Most Training Providers Expect to Implement Revised International Maritime Standards by the Deadline Despite Challenges
Released: 2017-01-31T00:00:00

Letter

Background

Coast Guard is the federal agency responsible for oversight of U.S. merchant marine credentialing and licensing. As part of these responsibilities, Coast Guard develops credentialing regulations based on statutory requirements and international treaties developed under the auspices of the IMO, to which the United States is a party. Coast Guard also drafts policies to clarify implementation of its regulations for training providers and mariners. Coast Guard issues guidance for complying with its regulations, including STCW requirements, through the publication of NVICs. Coast Guard implements the requirements for the issuance of merchant mariner credentials. Finally, Coast Guard also is to coordinate with its maritime training stakeholders to monitor U.S. efforts to implement the STCW convention.

The United States, through Coast Guard, implements provisions of the STCW convention through regulations. A timeline of IMO’s major amendments to the STCW requirements since 1978 and Coast Guard’s actions to implement the changes are presented in figure 1.

Composition of STCW Training Provider Survey Respondents

As of March 2016, approximately 167 training providers were approved by Coast Guard to administer courses related to implementation of the revised STCW requirements. Out of the 81 percent of survey respondents (136 responses), 10 indicated they were not teaching STCW courses resulting in a survey sample of 126 STCW training providers. Not every survey respondent answered every question. As a result, response rate varied by question. Figure 2 shows the number of respondents and the types of organizations that participated in our survey.

Training and Certification Requirements for U.S. Mariners

Training requirements for U.S. mariners vary depending on circumstances—such as the mariner’s role on the vessel, the area of operation, and the size of the vessel—but mariners are primarily subject to three types of training requirements: training required for commercial operations in both oceangoing and domestic waterways (see figure 3 for a map of these waterways); military-specific training required of civilian mariners who sail aboard government-owned vessels or vessels on charter to the Department of Defense; and maritime company-specific training requirements.

Mariners may be certified for service in domestic waters only, but a STCW certification is required for international or oceangoing service. Under Coast Guard’s regulations, mariners can meet the training requirements for certification through a combination of experience, training with evaluation through professional examination, or a practical demonstration of skills. Figure 3 identifies the areas of operation for domestic and international certification.

The STCW certification process is intended to ensure that the training a mariner receives, and the assessment of a mariner’s skills after the training is completed, supports the goal of placing qualified mariners on- board merchant vessels.

Training Provider Course and Program Approval and Audit Requirements

The Coast Guard’s National Maritime Center (NMC) approves all training providers that offer mariner training courses and programs, including programs at the federal and state maritime academies. NMC is also responsible for oversight of Coast Guard approved maritime training programs to ensure that maritime training providers offering Coast Guard approved training are performing their duties in a manner that meets all regulatory and policy standards. Figure 4 provides an overview of Coast Guard’s maritime training course approval request process—application to issuance.

Coast Guard approves maritime training courses and is to audit training provider compliance with STCW requirements every 5 years. Coast Guard also requires providers to conduct an internal audit in the interim every 2 and a half years. According to Coast Guard officials, in 2013, the federal and state maritime academies received approval of their training programs for compliance with the 2010 STCW amendments. The officials added that Coast Guard is currently in the process of the first audit cycle subsequent to those approvals—the federal and five state maritime academies had been audited by Coast Guard as of November 2016.

STCW Training Providers We Surveyed Reported Satisfaction with Coast Guard Guidance, but Reported Delay in Quality Assurance Guidance May Affect STCW Implementation

Coast Guard Has Provided Guidance to Training Providers Through Outreach Activities and Guidance Documents

Coast Guard has provided guidance to training providers to implement the revised STCW requirements generally in two ways. First, Coast Guard conducted various outreach activities, including:

Publishing online resources such as webinars and a frequently asked questions page. For example, prior to issuing the STCW final rule, Coast Guard convened an STCW Policy Advisory Council to solicit questions from the maritime industry regarding the revised STCW requirements, and Coast Guard used this feedback to develop the frequently asked questions page.

Managing a call center that is available to training providers and mariners to answer questions about the revised STCW requirements, among other things.

Holding advisory committee and maritime stakeholder meetings. For example, the Merchant Marine Personnel Advisory Committee (MERPAC) consists of about 19 members with expertise across the maritime industry and advises the Secretary of Homeland Security regarding merchant mariner credentialing issues, among other things. MERPAC is required to hold public meetings at least twice per year, and Coast Guard has used MERPAC meetings as a forum for discussing the revised STCW requirements. The Maritime Academy Council (MAC) consists of senior administrators from state maritime academies, and Coast Guard has used MAC meetings to discuss the revised STCW requirements, among other things. Coast Guard officials said that MERPAC and MAC are collaborative mechanisms used to provide stakeholders with an opportunity to provide recommendations to Coast Guard. The officials also reported that Coast Guard invited all of the STCW training providers to two public meetings in 2011 to provide details and answer questions on the revised STCW requirements.

Second, Coast Guard has issued guidance documents intended to aid training providers as they implement the revised STCW requirements. Guidance documents include material on how to prepare for Coast Guard audits, a bridging plan for maritime academies to update their curriculum based on the revised STCW requirements, and 24 NVICs that provide clarification on the compliance with and enforcement of regulations. Coast Guard also provided guidance on qualifying for specific training- related STCW endorsements. For example, one NVIC provides guidance for the approval of training courses and programs. According to Coast Guard officials, the NVICs were generally prepared in consultation with the maritime stakeholders through MERPAC.

Most Survey Respondents Were Satisfied With Coast Guard Guidance, but Over Half Reported that Delay in Quality Assurance Guidance May Affect STCW Implementation

Most training providers who responded to our survey reported that they were satisfied with Coast Guard’s coordination and guidance efforts overall (91 of 114 respondents or 80 percent). For example,

21 of the 26 survey respondents that reported participating in Coast Guard’s webinars were satisfied (81 percent).

57 of the 65 survey respondents that reported contacting Coast Guard’s call center to obtain information or clarification of the revised STCW requirements were satisfied (88 percent).

29 of the 32 survey respondents that reported attending MERPAC or other advisory committee meetings to obtain information on the revised STCW requirements were satisfied (91 percent).

In addition, most survey respondents reported that the Coast Guard’s 24 NVICs pertaining to the revised STCW requirements provided sufficient guidance and were issued in a timely manner. However, three of the six state maritime academy cadet programs (50 percent) reported being “not at all satisfied” with Coast Guard’s coordination on the implementation of the revised STCW requirements. Officials from the three state maritime academies generally attributed their dissatisfaction to the unique challenges they face as 4-year degree granting institutions, and reported that they would benefit from additional guidance regarding approval of their 4-year curriculum. Coast Guard officials stated that coordination with maritime academies has been extensive and that they have consulted with and sought input from both the maritime academies and industry, including during the negotiation of the 2010 amendments to the STCW Convention and through MERPAC meetings. In addition, Coast Guard officials said they met with the training institutions, including the maritime academies, to help implement the revised requirements and that they continue to provide assistance to all training institutions. Coast Guard officials also reported plans to issue additional guidance to state maritime academies.

For more details regarding survey respondents’ perspectives on the sufficiency of guidance and timeliness of the NVICs issued, see appendixes II and III.

Although most survey respondents reported that they were satisfied with Coast Guard’s coordination efforts overall, most training providers also reported that they would have benefited from a more timely update of guidance on developing the required Quality Standards System (QSS). For example, most of the training providers who responded to our survey (58 percent) reported that their ability to implement the revised STCW requirements was affected by a lack of timely guidance from Coast Guard on developing the QSS. The STCW final rule requires organizations offering training required by the STCW to be monitored by a QSS.

In 2014, Coast Guard reported plans to issue or update 26 NVICs pertaining to the revised STCW requirements. These plans included a QSS NVIC to clarify and guide training providers on how to appropriately develop a QSS. However, since Coast Guard has not developed its QSS guidance, the agency has directed training providers to the STCW final rule, which lists essential elements to be included in a comprehensive QSS. Because Coast Guard has not developed QSS guidance, training providers reported delays in updating their training programs to meet the revised STCW requirements. For example, training providers submitted comments to Coast Guard during the proposed rulemaking noting concerns that the QSS requirements were vague and duplicated other quality assurance practices that training providers currently had in place. One training provider who responded to our survey reported that additional guidance was needed to ensure compliance with significant changes to QSS record keeping requirements. Other training providers reported that they would have benefited from seeing an example of a completed QSS, as well as clarification of specific aspects of the QSS requirements.

Coast Guard audits also indicate a need for additional QSS guidance. As of November 2016, four of the five audit reports for federal and state maritime academies, conducted from March 2015 to April 2016, contained recommendations or deficiencies related to QSS implementation—further highlighting the need for guidance to help training providers develop and implement a QSS. Coast Guard also acknowledged in these audit reports that it needed to issue updated QSS guidance as soon as possible to ensure that training providers can implement their QSS by the deadline.

However, in November 2016, Coast Guard officials said that the situation may have changed since the time of our June 2016 survey, as the Coast Guard learned during the September MERPAC meeting that many training providers have successfully implemented QSS or expect to do so by the January 1, 2017 deadline. As a result, the Coast Guard plans to meet with MERPAC representatives in March 2017 to discuss whether guidance on developing the required QSS is necessary.

Training Providers We Surveyed Generally Reported They Will Meet the STCW Implementation Deadline Despite Implementation Challenges Most Survey Respondents Reported They Will Meet the STCW Implementation Deadline

Most of the training providers who responded to our survey reported that as of June 2016, they expect to meet the overall January 1, 2017, deadline for implementing the revised STCW requirements (81 percent). In general, the revised STCW implementation process consists of activities such as ensuring that instructors obtain additional training, providers update the training curriculum to reflect the revised STCW requirements, and providers develop a QSS, among other things. In all three categories, over half of the respondents reported that they will meet the implementation deadline for these activities. For example,

66 percent of respondents reported their instructors were fully trained as of June 2016, while 92 percent reported they will ensure that current instructors obtain the additional training required by the implementation deadline.

49 percent of respondents reported they have met the deadline for updating their curriculum to incorporate the revised STCW requirements as of June 2016, while 86 percent reported that they will have their curriculum revised by the implementation deadline.

41 percent of respondents reported they have implemented the QSS requirement as of June 2016, while 83 percent reported that they will meet this requirement by the implementation deadline.

Those training providers not expecting to meet the requirements reported various reasons, including a lack of time, lack of knowledge about the new requirements, a desire to retire, or cost. For instance, two training providers stated that they were unaware of the revised requirements while one respondent reported plans to retire because the requirements are getting burdensome for the small training school.

Among the federal and state maritime academies, six of the seven academies reported that as of June 2016, they expect to meet the overall January 1, 2017, STCW implementation deadline. More specifically, four of five academies who responded to our question regarding instructor training reported that as of June 2016, the current instructors at their institutions will obtain the additional training required to be STCW-compliant by the deadline; six of seven academies reported that as of June 2016, their curriculum will be updated by the deadline; and, six of seven academies reported that as of June 2016, their QSS will be implemented by the deadline.

The one state academy that did not anticipate meeting the overall STCW implementation deadline indicated that the grandfathering guidelines for graduating cadets who may need to take additional classes to comply with the latest changes to the STCW requirements were insufficient. Regarding the lack of grandfathering guidelines, Coast Guard officials said that they assisted the academies with a bridging strategy to ensure that current and future students meet the new requirements and continue to work closely with all maritime academies to ensure compliance.

Training Providers Cited Challenges in Addressing the Revised STCW Requirements

While training providers reported progress in implementing the revised STCW requirements, they also noted various challenges in implementing these requirements. Based on survey responses in which training providers were asked to note—from a list of 14 possible implementation challenges—which challenges they faced, the most frequently reported challenges were interpreting the revised STCW requirements, recruiting qualified instructors, developing the organization’s QSS, developing the program’s curriculum, and mariners’ willingness to remain in the industry. With regard to developing a QSS, Coast Guard officials noted that since we concluded our survey in June 2016, when some training providers reported developing a QSS as a challenge, many of the training providers have succeeded in implementing QSS or expect to do so by the January 1, 2017, deadline. See figure 5 for the list of 14 possible implementation challenges and the training provider’s views on the extent to which they considered each to be a challenge. For additional details regarding the extent to which the respondents reported experiencing challenges in implementing the revised STCW requirements, see appendix IV.

Interpreting the revised STCW requirements: The most frequently reported challenge by survey respondents was interpreting Coast Guard’s revision of the STCW requirements with 54 percent of survey respondents reporting this as a challenge. Six survey respondents reported that Coast Guard’s STCW guidance intended to help training providers interpret the revised requirements is hard to understand and according to one provider, puts undue burden on providers to remain compliant. Another training provider stated that the lack of “plain- language” guidance creates a challenge, especially for small schools that might not have the resources or sophistication to understand the language in the IMO convention or the regulation. Furthermore, of the training providers who reported that they sought clarification on the requirements from resources such as the Coast Guard’s call center, five respondents reported receiving ambiguous or conflicting information, one stated that representatives would read the guidance documents rather than provide explanations, and another stated that the representatives are more proficient in credentialing requirements rather than STCW requirements. When we asked Coast Guard about these challenges, officials responded that in addition to revising the NVICs based on training provider feedback, they also prepared responses for individual questions and have outreach activities planned as Coast Guard seeks to provide clarification to the providers.

State maritime academies also reported challenges interpreting the revised STCW requirements. For example, officials from one state maritime academy stated that some of the revised STCW requirements became clear after they were subjected to a Coast Guard audit. Furthermore, other state maritime academy officials we interviewed stated that Coast Guard’s guidance does not offer much assistance to academies; as a result, the academies should be given separate STCW guidance that takes into consideration the academic system in which they operate. When asked about these challenges noted by the state maritime academies, Coast Guard officials stated that they are determining the type of guidance necessary to assist the state maritime academies and plan to develop guidance for the maritime academies in the future.

Recruiting qualified instructors: Recruiting qualified instructors to teach STCW-related courses was the next most frequently reported challenge with 46 percent of respondents reporting it as a challenge. According to Coast Guard guidance, requesting approval of new instructors as of March 2014 should include documentation of the proposed instructor’s experience, training, or evidence of the ability to use effective instructional techniques that could include train-the-trainer certification. In their survey responses, five training providers reported that these requirements have decreased the supply of qualified instructors to teach STCW courses and three reported that instructors will require higher compensation. In addition, several of the training providers reported that qualified instructors may be unaffordable to some providers or the increased costs may be passed on to the mariners seeking STCW-related training. Additionally, the supply of qualified instructors is declining, especially for engineering instructors, according to 11 training providers. Seven providers reported that the cost or time commitment required for potential instructors to acquire the additional qualifications is a challenge. In addition, one provider reported that some qualified mariners who could potentially serve as faculty may not be interested in meeting the rigorous STCW faculty requirements. Two other providers reported that some qualified mariners may opt to take more competitive salaries at sea rather than working as instructors. The Coast Guard acknowledged the effort required for instructors to be compliant, but stated that the revised guidance has not changed substantially regarding instructor qualification and that instructors have always been expected to hold appropriate credentials to teach maritime courses. In addition, the Coast Guard officials stated that they are unable to speak to the challenge of recruiting qualified instructors for any specific training providers.

Developing QSS: Almost half of the training providers–46 percent– reported that developing the organizations’ QSS was a challenge to meeting the deadline. One provider reported that due to the QSS development cost, it will not develop such a system and therefore may lose its STCW training status. Six providers reported that they believe the QSS requirement is an unnecessary administrative burden and expense to the providers, especially for small providers that may stop offering STCW courses because of the cost that may be associated with developing a QSS, according to a maritime professional. Two survey respondents also stated that they were reluctant to dedicate resources to developing a QSS because it was unclear at the time of our survey what would be required to be fully compliant. In addition, most state maritime academy officials we interviewed reported that a QSS is redundant since the academy’s accreditation status already ensures the quality of the maritime training programs. With regards to cost, Coast Guard officials stated that any cost incurred from developing a QSS is dependent on the provider since the process requires documenting what providers do to ensure program quality and compliance. According to Coast Guard officials, regarding the redundancy of a QSS, the maritime academies provided this comment during the development of the STCW final rule and in response text was added to the regulation to enable the Coast Guard to take accreditation body requirements into account when assessing compliance with applicable QSS requirements. As of November 2016, the Coast Guard is developing the policy to implement this regulatory flexibility for the maritime academies. In addition, Coast Guard officials stated that potential guidance may result after Coast Guard explores how the accreditation process could be used to fulfill the QSS requirements.

Developing curriculum: Based on our survey, 44 percent of respondents reported that developing curriculum to meet the revised STCW requirements is an implementation challenge. For example, three providers reported that the curriculum development process related to STCW requirements is arduous, vague, or expensive. Two providers reported that having a sample curriculum related to STCW requirements would be helpful. In addition, one provider reported that academies needed more time to implement the STCW requirement changes within their academic systems to accommodate the needs of the cadet. When asked about this challenge, Coast Guard officials acknowledged there can be costs associated with curriculum development, but noted that the Coast Guard STCW regulation and policy guidance issued in January 2014 match the standards set by the IMO.

Willingness to stay in the industry: According to some survey respondents, the effort required by mariners to comply with the revised STCW requirements may result in some mariners leaving the industry. Forty-one percent of the survey respondents reported that the willingness of STCW-certified merchant mariners to remain employed in the industry following the revised STCW requirements poses a challenge. In the narrative responses, ten training providers reported that more mariners may leave the industry or are looking for other employment options because it is too difficult to maintain a merchant mariner credential under the revised requirements. Training providers we interviewed also stated that some mariners are opting to retire rather than meeting the new requirements. Three narrative responses also noted that maintaining the credential is expensive because of the cost of training, cost of travel to attend training including lodging expenses, as well as the corresponding loss of wages experienced when mariners are not at sea while they attend training. Two survey respondents indicated that sometimes mariners pay these costs out of pocket or some costs may be covered by unions. When we asked about the challenge of mariner’s willingness to stay in the industry, Coast Guard officials stated that the guidance provides the minimum standards required of mariners and they have the flexibility to choose the courses or programs they wish to take. Coast Guard also acknowledged that some mariners may gravitate towards professions that give greater flexibility to their schedule and work-life balance.

In addition to the challenges listed in the survey, survey respondents identified other challenges in their narrative responses, including the need for better harmonization of the Coast Guard’s training for domestic waterways and the STCW requirements. One provider reported that it has to use resources to cross-check both requirements to ensure that its program is accurate and in agreement. Academy officials we interviewed also reported that the overlapping of the domestic and STCW requirements is a strain on the time and resources of the academies. Coast Guard officials responded that in cases where a specific topic meets both a domestic and STCW requirement, it is only required to be done once and documented as meeting the STCW requirement.

Coast Guard Assessed Costs and Benefits of STCW Implementation, and Training Providers We Surveyed Reported Varying Perspectives on STCW Costs and Benefits

Coast Guard Assessed Costs and Benefits in Accordance with Key Practices for Federal Rulemaking

Coast Guard estimated the costs and benefits of implementing the revised STCW requirements in its regulatory analysis of the STCW final rule. Costs and benefits are two of the four elements that the Office of Management and Budget and GAO have identified as important to any regulatory assessment for federal rulemaking, and based on our analysis, Coast Guard’s rulemaking for implementing STCW regulatory revisions addressed all four elements. Coast Guard estimated the total present value cost of implementing the revised STCW requirements over 10 years to be $228.9 million, or about $32.6 million annually. Coast Guard estimates included implementation costs associated with four general areas—mariner training, medical examination, sea service, and training providers. As shown in figure 6, Coast Guard estimated the majority of costs were to meet mariner training requirements.

Coast Guard also identified qualitative benefits expected from implementing the revised STCW requirements that would result from increased and consistent training and enhanced medical evaluation. Expected benefits included, for example, an increase in vessel safety and a decrease in the risk of accidents. Coast Guard officials told us that they did not quantify the benefits of implementing the revised STCW requirements because of uncertainty about the relationship between training and human factors involved in accidents. Officials stated that to estimate benefits, Coast Guard reviewed studies on the effectiveness of training in other industrial settings, but because of the difference in contexts and the range of measures of effectiveness, they concluded that the benefits transfer was not robust enough to quantify benefits for STCW. Instead, Coast Guard conducted a “break-even” analysis of the expected benefits, noting that break-even analyses are used for situations where benefits from a regulatory action cannot be quantified. Such analyses are intended to answer the question: “How small could the non- quantified benefits be before the rule would yield zero net benefits?” We describe the Coast Guard’s benefits estimates in more detail below.

Executive Order 13563 directs agencies to periodically review significant regulations to identify those that may be outmoded, ineffective, insufficient or excessively burdensome, and to modify the regulations according to what has been learned. Coast Guard officials said they would consider conducting a retrospective analysis of its estimated costs and benefits of implementing the revised STCW requirements after sufficient time has passed for the costs and benefits to be realized, and if funds are available.

Survey Respondents Reported Varying Perspectives on STCW Costs and Benefits

Perspectives on Costs to Training Providers

Most training providers who responded to our survey (68 percent) reported that they anticipated that implementing the revised STCW requirements would increase their organization’s costs. About half of all survey respondents (49 percent) expected to increase their organization’s training prices in 2017 while 37 percent expected no change in prices.

Training providers generally reported that they expected their costs of implementing STCW requirements to be equal to or higher than the Coast Guard’s estimates in its regulatory analysis of the STCW final rule. Specifically, in estimating the costs of implementing the revised STCW requirements, Coast Guard estimated average dollar costs for small and non-small training providers across five cost categories. For example, using Coast Guard estimates, the average cost for initial auditor training—one of the five cost categories—for small providers was $3,499 and for non-small providers was $16,023. Across these five cost categories, about half of responding training providers (46 to 50 percent) indicated that their costs would be similar to Coast Guard’s cost estimates, as shown in figure 7 below. About a third of respondents (28 to 39 percent) expect costs to be higher than Coast Guard estimated and 2 to 14 percent anticipated costs lower than Coast Guard’s estimates. In addition, a small number of providers (between 10 and 13) responded “other” to these questions. For example, one provider who indicated “other” when comparing anticipated costs to Coast Guard estimates said “our training system is much more complex than any other commercial provider” while another stated “my training school consists of a single all- in-one manager/owner/instructor.”

Some survey respondents identified costs that they did not believe were included in Coast Guard’s average estimates for training providers. For example, while Coast Guard included estimates for developing QSS procedures, several training providers indicated that new QSS requirements could involve more administrative time than estimated by Coast Guard. Officials at one maritime academy indicated that they allocated 9 hours per week to maintain the STCW system and believed that the Coast Guard’s average estimates “did not come close to the true costs” incurred by a large training provider. Officials at another maritime academy indicated that implementing the requirements would require “more courses, more assessments, more record keeping, more simulation.” Coast Guard officials told us that they plan to consult with state academies about the perceived impacts related to implementing the requirements. A recently purchased simulator used for STCW training at a maritime academy is displayed in figure 8.

In addition to administrative costs, academy officials stated that the extra days of sea time required under the revised STCW requirements cost an additional $7,000 a week to operate and staff the ship. Coast Guard stated that it developed its cost estimates for a typical or average entity, and therefore the costs used for estimating national effects did not include costs that a specific entity might incur. When asked for their perspectives on the training providers’ view of the cost of the revised STCW requirements, Coast Guard officials stated that providers had the opportunity to comment on the Coast Guard cost estimates during the supplemental notice period and those comments were adjudicated and applicable text amended before the final rule was issued.

Perspectives on Benefits of the Revised STCW Requirements

In estimating the benefits of implementing the revised STCW requirements, Coast Guard identified nine categories of potential benefits. Across these nine categories, survey respondents were mixed in their expectation of whether there would be either a positive effect (i.e., benefits would be realized) or no effect (i.e., no benefits) from implementing the revised STCW requirements. For example, as shown in figure 9 below, 70 percent of training providers indicated that increased mariner situational awareness was a benefit of the STCW regulatory revisions. Also, between zero and nine providers across categories reported the effects might be negative, rather than provide benefits, with one state maritime academy noting that the documentation required to demonstrate compliance with STCW—much of which has to be completed at sea—is cumbersome.

Training providers varied by type of organization in their perspectives of the benefits of implementing the revised STCW requirements. For example, the U.S. Merchant Maritime Academy and most of state maritime academies’ cadet programs (4 of 6) and union training providers (3 of 5) expected that implementing the revised STCW requirements would have no effect on the potential benefit of decreasing the risk of property loss, whereas with other types of providers, such as colleges and universities, most (10 of 15) expected a positive effect from the benefit.

Agency Comments and Our Evaluation

We provided a draft of this report to DHS and the Department of Transportation (DOT) for review and comment. DHS provided technical comments, which we incorporated as appropriate. DOT had no comments on the report.

We are sending copies of this report to the appropriate congressional committees, the Secretary of Homeland Security, and the Office of the Assistant Secretary for Administration, DOT. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-7141 or groverj@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

This report focuses on the maritime training providers’ perspectives on the U.S. Coast Guard’s (Coast Guard) guidance available to implement the revised Standards of Training, Certification and Watchkeeping for Seafarers (STCW) requirements, their progress implementing the revised requirements, and any costs and benefits associated with implementing the new requirements. Specifically, we addressed the following questions. 1. To what extent has Coast Guard provided sufficient guidance to training providers about addressing the revised STCW requirements? 2. What progress do training providers report in implementing the revised STCW requirements, and what challenges, if any, have they reported in doing so? 3. To what extent has Coast Guard evaluated the costs and benefits of the revised STCW requirements, and what impact, if any, do training providers report regarding the costs and benefits of implementing the requirements?

To address all three objectives, we conducted a web-based survey of the universe of 167 training providers approved by the Coast Guard to teach STCW courses to obtain their perspective on each of our objectives. Coast Guard provided GAO with a list of all training providers approved to teach STCW courses, including contact information. We worked with Coast Guard and independently verified contact information, particularly e-mails (as the survey was web-based) to confirm the universe of 167 STCW training providers. We determined that this information was reliable for our purposes.

To develop our survey questions, we reviewed the STCW final rule (including comments and STCW implementation cost estimates), relevant congressional testimony, Coast Guard’s guidance related to STCW implementation, and other STCW-related documents. We also discussed the survey topics with representatives from the Coast Guard, Maritime Administration (MARAD), and a maritime union. We pretested our survey with selected STCW training providers who were purposefully selected to represent a broad range of providers, including the Coast Guard Academy, a state maritime academy, a private training provider, a union training provider, and with Coast Guard officials, and made changes for clarity as needed.

The survey was available for completion from March 21, 2016, through June 10, 2016, and we followed up by e-mailing or calling all participants who had not yet responded after 8 days and again every few weeks to encourage participation. Out of the universe of 167 STCW training providers, 136 responded for a response rate of 81 percent. Of those responding, 10 indicated they were not currently teaching STCW courses. As such, we removed these respondents from our sample resulting in a total population of 126 training providers teaching at least one STCW course, and subject to STCW regulatory requirements. Not all respondents answered every question so the response rate varied by question. We analyzed the numeric data with statistical software and the testimonial data with qualitative analysis software.

Also, for all three objectives, we interviewed officials from the Coast Guard, selected training providers (including the federal and state maritime academies) and other stakeholders, including MARAD— primarily for their perspectives as we developed our survey. We also conducted interviews with Coast Guard officials responsible for maritime training to obtain their views on each of our objectives. In addition, to supplement training provider information gathered by the survey, we interviewed officials at the federal maritime academy and the state maritime academies to understand their unique perspective on implementing the revised STCW requirements. Four of the six state maritime academies and the federal maritime academy were interviewed by phone, and we conducted site visits at two state academies—Texas A&M at Galveston Maritime Academy and the Great Lakes Maritime Academy. These academies were selected because both academies had been recently audited by the Coast Guard for STCW compliance and could share what was learned from the audits. We also interviewed two private providers that were selected based on geographic proximity to the academy site visits. While our survey represents the perspectives of the of STCW training providers who responded, our interviews with training providers are not generalizable and are used to provide illustrative examples and context about the survey responses.

To determine the extent to which Coast Guard provided sufficient guidance to training providers to implement the revised STCW requirements, we analyzed data from our survey and included relevant questions in our interviews with Coast Guard, stakeholders, and selected training providers. We reviewed and analyzed Coast Guard and MARAD documents including applicable Coast Guard training and audit guidance and reports, correspondence with training providers, STCW training workshop materials, the STCW final rule, and prior GAO reports. We reviewed Coast Guard’s updated Navigation and Vessel Inspection Circulars (NVIC), which Coast Guard provided to training providers as guidance to assist with implementing the revised STCW requirements. In our meetings with selected STCW training providers and stakeholders we discussed their experiences implementing the revised STCW requirements and coordinating with Coast Guard and MARAD to do so. With Coast Guard, we confirmed our understanding of their audit recommendations to the respective federal and state maritime academies.

To describe the progress of training providers in implementing the revised STCW requirement and any challenges in doing so, we analyzed data from our survey and included relevant questions in our interviews with Coast Guard, stakeholders, and selected training providers. We reviewed the STCW final rule, applicable deadlines, and Coast Guard’s plan for training providers to transition between the existing and revised STCW requirements. For familiarity with the process at state maritime academies, we reviewed the maritime academy handbook. To describe Coast Guard’s assessment of progress made by the providers in implementing STCW revisions, we reviewed Coast Guard’s internal audit guidance, the audit reports conducted to date for the federal and state maritime academies.

For our third objective regarding Coast Guard’s assessment of STCW costs and benefits, we analyzed data from our survey and included relevant questions in our interviews with Coast Guard and selected training providers. We reviewed congressional testimony, comments submitted for the Supplemental Notice of Proposed Rulemaking, and the STCW final rule to identify cost and benefit issues. We reviewed the STCW final rule and Final Rule Regulatory Analysis and Final Regulatory Flexibility Analysis prepared by the Coast Guard to document the agency’s estimated costs and benefits of revising STCW regulations. We compared the STCW final rule to Office of Management and Budget (OMB) criteria identifying key elements for effective rulemaking, and prior GAO work. We reviewed OMB regulatory requirements, including Circulars A-4 and A-94, and prior GAO work to identify key elements in conducting a regulatory cost-benefit analysis.

We conducted this performance audit from September 2015 to January 2017 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Survey Responses on Coast Guard Guidance

Survey Respondents’ Perspectives on the Sufficiency of Coast Guard’s Guidance to Implement the Standards of Training, Certification and Watchkeeping for Seafarers (STCW) Requirements

The U.S. Coast Guard (Coast Guard) issues guidance for complying with its regulations, including STCW requirements, through the publication of Navigation and Vessel Inspection Circulars (NVIC). In 2014, Coast Guard reported plans to issue 26 NVICs pertaining to the revised STCW requirements. As of March 2016, Coast Guard had published 24 NVICs and reported plans to publish the additional NVICs pertaining to the revised STCW requirements. According to Coast Guard officials, the decision to publish a NVIC is based on a need to clarify a regulation and provide implementation guidance. Table 1 provides details regarding the survey respondents’ perspectives on the sufficiency of Coast Guard’s guidance (24 NVICs), as of June 2016 to implement the STCW requirements.

Appendix III: Survey Respondents’ Perspectives on Timeliness of Coast Guard Guidance

Survey Respondents’ Perspectives on Coast Guard’s Timeliness in Issuing Guidance to Implement the Standards of Training, Certification and Watchkeeping for Seafarers (STCW) Requirements

The Coast Guard issues guidance for complying with its regulations, including STCW requirements, through the publication of Navigation and Vessel Inspection Circulars (NVIC). In 2014, Coast Guard reported plans to issue 26 NVICs pertaining to the revised STCW requirements. As of March 2016, Coast Guard had published 24 NVICs and reported plans to publish the additional NVICs pertaining to the revised STCW requirements. According to Coast Guard officials, the decision to publish a NVIC is based on a need to clarify a regulation and provide implementation guidance. Table 2 provides details regarding the survey respondents’ perspectives on Coast Guard’s timeliness in issuing guidance (24 NVICs), as of June 2016 to implement the STCW requirements.

Appendix IV: Standards of Training, Certification and Watchkeeping for Seafarers (STCW) Implementation Challenges

Standards of Training, Certification and Watchkeeping for Seafarers (STCW) Implementation Challenges as Reported by Training Providers, June 2016

Based on GAO’s interviews with officials from Coast Guard, Maritime Administration, and other selected maritime training providers and stakeholders (including unions and associations), we identified the 14 most frequently cited possible challenges that providers may face when implementing the revised STCW requirements. Table 3 presents a summary of the extent to which GAO’s survey respondents reported experiencing challenges in implementing the revised STCW requirements in each of the 14 challenge categories.

Appendix V: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact above, Ellen Wolfe (Assistant Director); Frederick Lyles, Jr. (Analyst-in-Charge); David Bieler; Chuck Bausell; Eric Hauswirth; Susan Hsu; Monica Kelly; Tracey King; Dainia Lawes; Carl Ramirez; Cynthia Saunders; and Christine San all made key contributions to this report.