USCG resumes MMC requirements for Non-Operating Individuals

The United States Coast Guard has announced that effective January 1, 2025, it has resumed enforcement of the requirement for Non-Operating Individuals (NOIs) to hold Merchant Mariner Credentials (MMCs). This change marks the end of a four-year period during which the Coast Guard was prohibited by law from enforcing these requirements. The enforcement suspension was in effect from January 1, 2021, through December 31, 2024, under legislation enacted by Congress.

Background on the Suspension of MMC Requirements

During the period of non-enforcement, the Coast Guard was legally restricted from requiring MMCs for specific categories of individuals engaged in maritime activities. These included marine firefighters, spill response personnel, salvage operators, and commercial divers or those providing diving support. These personnel were exempted from needing an MMC if they were aboard vessels solely to carry out activities related to spill response, salvage, marine firefighting, or commercial diving.

Furthermore, on certain vessels, such as Offshore Supply Vessels (OSVs) or industrial vessels, additional personnel were exempt from MMC requirements if they were engaged in specific tasks that were outside the traditional scope of vessel crew duties. These tasks included:

Supporting or performing industrial operations of the vessel.
Conducting short-term surveys or investigations.
Assessing the competence of the crew.
Conducting vessel trials.
Providing enhanced security services.
Performing warranty maintenance or maintaining equipment not owned by the vessel owner or beyond the capabilities of the regular crew.

Resumption of Enforcement

As of January 1, 2025, the Coast Guard’s authority to enforce MMC requirements for NOIs has been reinstated. Individuals who fall into the previously exempt categories must now comply with the credentialing requirements set forth by federal law. This change aligns with the statutory mandate outlined in Public Law 116-283 and its subsequent amendments.

Guidance and Additional Information

For those seeking clarity on obtaining an MMC as a Non-Operating Individual, inquiries should be directed to the U.S. Coast Guard’s National Maritime Center (NMC). The NMC can be reached by email at IASKNMC@uscg.mil or by phone at 1-888-427-5662. For questions related to the enforcement of MMC possession requirements, stakeholders are advised to contact their local USCG Officer in Charge, Marine Inspection (OCMI).