MM&P advocates on a number of regulatory fronts for the U.S. Merchant Marine. The union's official comments on a number of regulatory proposals are posted below. For more information on MM&P's work in Washington, D.C., click on the Legislative Issues button or the What's New button.

MM&P Comments on USCG NVIC on the Transportation Worker Identification Credential (TWIC)

MM&P’s comments on the U.S. Coast Guard’s draft NVIC, Guidance for the Implementation of the Transportation Worker Identification Credential Program in the Maritime Sector. click here to download pdf

MM&P Comments on DHS Chemical Facility Security Rules

DHS has also issued a proposed rule on the security of chemical facilities. In its formal comments on the rule, MM&P supported its systematic approach to assessing threats and developing security plans based on risk. This methodology is not present in the USCG regulations, which treat every vessel and every port facility as if they are all at the same risk of terrorism. MM&P's comments on chemical facility security. click here to download pdf

MM&P Comments on Original USCG Merchant Mariner Document Proposal

On Jan. 25, the U.S. Coast Guard amended its May 2006 notice of proposed rulemaking by publishing a supplemental notice of proposed rulemaking (SNPRM) entitled, Consolidation of Merchant Mariner Qualification Credentials. MM&P's comments on the original proposal, submitted in July 2006. click here to download pdf

MM&P Comments on USCG NVIC on Medical and Physical Evaluation Guidelines for Merchant Mariner Credentials

Articles in MM&P's Wheelhouse Weekly have covered the USCG's proposed navigation and vessel inspection circular (NVIC) on Medical and Physical Evaluation Guidelines for Merchant Mariner Credentials. The USCG developed the NVIC to offer guidance to those evaluating the physical and medical condition of applicants for merchant mariner's documents, STCW endorsements and licenses. MM&P and others in the maritime industry expressed serious concerns over the impact of the NVIC in comments submitted to the USCG in November. click here to download pdf

MM&P Comments on DHS Voyage Data Recorder Rules

Ferries should not be required to carry voyage data recorders (VDRs) because the information recorded is more likely to be used for finger-pointing than shedding light on what caused an accident, MM&P has warned in comments submitted in response to a Department of Homeland Security (DHS) study. Integrated navigation systems with playback functions should be carried instead because such systems improve safety and generate data investigators can use to analyze accidents. The union's comments are in the posted pdf. click here to download pdf