	Background

Coast Guard is the federal agency responsible for oversight of U.S.  merchant marine credentialing and licensing. 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. STCW Training Providers We Surveyed Reported Satisfaction with Coast Guard Guidance, but Reported Delay in Quality Assurance Guidance May Affect STCW Implementation

		Coast Guard Has Provided Guidance to Training Providers Through Outreach Activities and Guidance Documents

Coast Guard has provided guidance to training providers to implement  the revised STCW requirements generally in two ways. 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. 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. As a result, the Coast Guard plans to  meet with MERPAC representatives in March 2017 to discuss whether  guidance on developing the required QSS is necessary. Training Providers We Surveyed Generally Reported They Will Meet the STCW Implementation Deadline Despite Implementation Challenges Most Survey Respondents Reported They Will Meet the STCW Implementation Deadline

Most of the training providers who responded to our survey reported that  as of June 2016, they expect to meet the overall January 1, 2017,  deadline for implementing the revised STCW requirements (81 percent). With regard to developing a QSS, Coast Guard officials noted  that since we concluded our survey in June 2016, when some training  providers reported developing a QSS as a challenge, many of the training  providers have succeeded in implementing QSS or expect to do so by the  January 1, 2017, deadline. For additional details  regarding the extent to which the respondents reported experiencing  challenges in implementing the revised STCW requirements, see  appendix IV. Interpreting the revised STCW requirements: The most frequently  reported challenge by survey respondents was interpreting Coast Guard’s  revision of the STCW requirements with 54 percent of survey  respondents reporting this as a challenge. State maritime academies also reported challenges interpreting the  revised STCW requirements. In addition, the Coast Guard  officials stated that they are unable to speak to the challenge of recruiting  qualified instructors for any specific training providers. Developing QSS: Almost half of the training providers–46 percent– reported that developing the organizations’ QSS was a challenge to  meeting the deadline. Coast Guard Assessed Costs and Benefits of STCW Implementation, and Training Providers We Surveyed Reported Varying Perspectives on STCW Costs and Benefits

		Coast Guard Assessed Costs and Benefits in Accordance with Key Practices for Federal Rulemaking

Coast Guard estimated the costs and benefits of implementing the  revised STCW requirements in its regulatory analysis of the STCW final  rule. About a third of respondents (28 to  39 percent) expect costs to be higher than Coast Guard estimated and 2  to 14 percent anticipated costs lower than Coast Guard’s estimates. For  example, the U.S. GAO staff who made key contributions to this report  are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

This report focuses on the maritime training providers’ perspectives on  the U.S. Coast Guard’s (Coast Guard) guidance available to implement  the revised Standards of Training, Certification and Watchkeeping for  Seafarers (STCW) requirements, their progress implementing the revised  requirements, and any costs and benefits associated with implementing  the new requirements. 1. 3. To what extent has Coast Guard evaluated the costs and benefits of  the revised STCW requirements, and what impact, if any, do training  providers report regarding the costs and benefits of implementing the  requirements? To determine the extent to which Coast Guard provided sufficient  guidance to training providers to implement the revised STCW  requirements, we analyzed data from our survey and included relevant  questions in our interviews with Coast Guard, stakeholders, and selected  training providers. We  reviewed Coast Guard’s updated Navigation and Vessel Inspection  Circulars (NVIC), which Coast Guard provided to training providers as  guidance to assist with implementing the revised STCW requirements.
Why GAO Did This Study

Merchant mariners operate U.S. commercial ships and support national defense in emergency and war. Coast Guard issues regulations and policies to ensure merchant mariners are credentialed and meet minimum international standards. To incorporate changes made to the international STCW Convention in 2010, Coast Guard issued regulations in December 2013 that training providers must implement by January 1, 2017, to ensure mariners meet the revised requirements. These changes are intended to help reduce the risk of accidents in U.S. and international waters.
GAO was asked to review Coast Guard and training providers' implementation of the revised STCW requirements. This report addresses (1) the extent to which Coast Guard provided sufficient guidance to training providers about the revised STCW requirements; (2) the progress training providers report in implementing the revised STCW requirements; and challenges reported in doing so; and, (3) the extent to which Coast Guard evaluated costs and benefits of the revised STCW requirements, and impacts training providers report about the costs and benefits of implementing the revised requirements. GAO conducted a web-based survey from March 2016 to June 2016 of all 167 Coast Guard-approved STCW training providers. Eighty-one percent responded, although response rates varied for individual questions. GAO also reviewed Coast Guard's guidance and reports and interviewed officials.
GAO is not making recommendations.

What GAO Found

Most training providers (80 percent) who responded to GAO's survey reported that they were satisfied with guidance the U.S. Coast Guard (Coast Guard) provided to assist them in implementing the revised International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) requirements. However, 58 percent of respondents, including state maritime academies, private for-profit colleges, and others, reported that the lack of timely Coast Guard guidance for developing a quality assurance process—Quality Standards System (QSS)—affected their ability to implement the revised STCW requirements. A QSS is intended to ensure that training providers have a documented quality system in place to monitor training activities. Coast Guard officials said the agency plans to meet with industry stakeholders in March 2017 to discuss whether additional QSS guidance is necessary.
Most of the training providers (81 percent) who responded to GAO's survey reported that they plan to meet the January 1, 2017, deadline to implement the revised STCW requirements, but also reported some challenges in doing so. For example, over half of the respondents (54 percent) reported that interpreting the revised STCW requirements was a challenge. To address this issue, Coast Guard has ongoing outreach efforts to obtain feedback from training providers, help them interpret Coast Guard's regulations, and determine what additional guidance is needed. Almost half of the respondents (46 percent) reported that recruiting qualified course instructors was a challenge. However, Coast Guard stated that the revised requirements related to instructor's qualifications have not changed substantially; therefore, the challenge experienced with recruiting instructors may be related to specific training providers, rather than to the revised STCW requirements. Training providers not expecting to meet the deadline for implementing the revised STCW requirements (19 percent) provided various reasons, such as a lack of funding to address the requirements, needing additional Coast Guard guidance, or lacking the time to complete the required documentation.
Coast Guard evaluated the costs and benefits of the revised STCW requirements, and training providers who responded to GAO's survey reported related impacts of implementing the revised requirements. For example, Coast Guard evaluated the average costs to training providers for developing a QSS and the costs for conducting STCW audits. About half of the surveyed training providers expected their costs would be similar to Coast Guard's estimates. About one third anticipated incurring costs higher than the Coast Guard's average estimate due to needing more time for administrative tasks than Coast Guard allowed or purchasing additional training equipment. Coast Guard officials said they estimated average costs, and therefore did not consider specific items that particular training providers may need. Over half of training providers agreed with Coast Guard's assessment of potential benefits from the revised STCW requirements, such as increased vessel safety, with most of the remaining providers expecting no effect from the STCW changes.