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. 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 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. 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. 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 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.