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appeal a decision made by NMC. This change in process appears not to have come with the resources to handle the volume of appeals now being filed. Previously, a mariner had three levels of appeal before it reached the Headquarters level. The local Regional Exam Center Chief, the local Coast Guard Officer in Charge of Marine Inspection (OCMI), and the District Commander were all in the decision chain and more often than not, a ruling made at one of those levels determined the final outcome of the case. Today, you have two bites at the proverbial apple. The first step is to ask for ?reconsideration? by the OCMI (Commanding Officer at NMC), followed by an appeal directly to the Prevention Policy division for review and ?final agency action.? Due to the backlog of appeals at Headquarters, some cases have taken up to a year to rule on. Recognizing that they are unable to keep up with the workload, Headquarters has begun authorizing extensions of the validity of some mariner?s credentials, while they wait for a final decision. This amendment was part of the Coast Guard Authorization Act of 2010 and was a direct result of hurricane Katrina and the need to give the Coast Guard the flexibility of extending the 5-year credential period, due to acts beyond the control of the mariner. While appeal delays were not envisioned by this amend- ment authors, the effect can be just as devastating to a mariner?s livelihood. New and highly stringent medical standards coupled with various interpretations of current Coast Guard policies and regulations have proven to be a potent recipe for overloading the Coast Guard appeal sys- tem. One of the goals of restructuring and having one office handle all of the applications in the country was to standardize the process and bring consistency to a previ- ously ?inconsistent? program. However, consistency remains an elusive target as long as sweeping regulatory changes continue ? and they will ? and a system that isnot fully equipped to deal with the individual nature of mariners and the maritime industry itself, remains the norm. Even as the Coast Guard and its marine safety, inspection and credentialing missions try to get back on track, the industry?s perception that they can right the ship back at the National Maritime Center, remains guarded. Rapid regulatory change(s) continue to outpace reforms at the operational and policy making levels. The hangover from the now long forgotten consolidation of 17 REC?s into one centralized building therefore promises to be long and burdensome. Andy Hammond is the former Chief of the U.S. Coast Guard?s Regional Exam Center in Boston, MA. On the WEB: www.andyhammond.com. E-Mail: info@andyhammond.comMN#5 (18-31):MN 2011 Layouts 5/7/2012 1:27 PM Page 21
