USCG: Mariner credentialing grace period extension

The United States Coast Guard issued CG-MMC Policy Letter 01-24 on a temporary extension of the administrative grace period for credentialing transactions.

This letter was published on 15 April 2024.

The primary purpose of this policy letter is to announce and explain the temporary extension of the administrative grace period provided for in reference (a), which is 46 Code of Federal Regulations (CFR) 10.227(h). This grace period allows mariners whose MMCs have expired to renew them without having to undergo further examinations or training, provided that all other renewal requirements are met.

The background section of the letter provides context for the decision to extend the grace period. It references the National Defense Authorization Act for Fiscal Year 2017, which mandated a study by the Maritime Workforce Working Group (MWWG) to assess the size of the citizen mariner pool necessary to support the United States Flag Fleet in times of national emergency. The study estimated the number of qualified mariners needed for various scenarios and highlighted the importance of maintaining a sufficient workforce.

Subsequent disruptions, particularly those caused by the COVID-19 pandemic, have affected the maritime industry's labor pool and mariner retention. To address these challenges and facilitate the entry of new mariners into the industry, section 3534(j) of the National Defense Authorization Act (NDAA) of 2024 temporarily reduced sea service requirements for certain deck rating endorsements. Additionally, there is a need to encourage mariners whose credentials have lapsed to reenter the maritime industry.

Reference (a) originally provided a one-year administrative grace period for mariners with expired MMCs. However, the Coast Guard is temporarily extending this period from one year to six years. This extension allows mariners to renew their MMCs up to six years after expiration without having to take the complete original examination. The extension is effective immediately and will remain in effect indefinitely, with the Coast Guard providing additional guidance as necessary.

The policy letter emphasizes that the extension does not extend the validity of an MMC, and mariners cannot sail under the authority of an expired credential. It also specifies that the extension may be further extended by a term of active service in the Uniformed Services, and no other extensions are authorized by this policy letter.

Mariners who had previously applied for renewal of their MMC after the one-year grace period expired may re-apply for renewal if they are within the new, extended grace period. However, a new application will be necessary, including payment of required fees.

This guidance is not a substitute for applicable legal requirements, nor is it itself a regulation. It is not intended to, nor does it impose legally binding requirements on any party. This guidance represents the Coast Guard’s current thinking on this topic and may assist industry, mariners, the general public, and the Coast Guard, as well as other Federal and State regulators, in applying statutory and regulatory requirements. Alternative approaches for fulfilling this policy may be acceptable if the approach satisfies the requirements of the applicable statutes and regulations.

For more information, please see the document below (available only to subscribers):