MARAD’s “new” criteria for restoring sea year were proposed by industry 7 months ago

In our continuing effort to assist MARAD with its “new era of transparency,”  I put out a request the other day for MARAD or anyone else to provide me with a copy of the criteria MARAD had created for restoring sea year to commercial ships.  True to form, MARAD did not rise to the occasion. Fortunately, however, others did, and we were provided copies of the criteria from several different sources.

When I put out the request, I also stated my theory as to why MARAD did not want to make the criteria public:

“MARAD doesn’t want them made public because it knows it will be widely criticized when they are finally made public — because they will virtually mirror what industry proposed to MARAD on June 26, 2016 — only ten days after the stand down cancellation was announced.”

Nailed it!  (Except I got the date wrong — industry actually proposed the criteria on June 24, 2016, only eight days after the stand down cancellation was announced.)

In the table below, I compare the June 24, 2016 industry proposal with the MARAD criteria as of January 12, 2017.  The MARAD criteria mirror the industry proposals.  What is most incredible about this is that industry actually proposed that more stringent criteria be applied. — MARAD took 7 months to water down the industry-proposed criteria.

Industry proposal – June 24, 2016  MARAD criteria – January 12, 2017
“Develop and implement a process providing cadets [with] [a]n advocate with identified responsibilities onboard the vessel” “Company-assigned ‘Mentors’ with defined duties to look after cadets aboard each ship”
“Formal policies and related materials prohibiting SA/SH” “CEO-level company-wide message stressing zero tolerance of SASH.”
“Training programs involving company and union personnel implementing anti-SA/SH policies” “Annual SASH Prevention Training required for crew”
“Evidence of mandatory review of policies by all shipboard personnel” “Companies must verify that the crew will complete Annual SASH Prevention Training, and review and acknowledge the Company’s SASH policies”
“Formal policies and related materials prohibiting fraternization (dating / consensual relations) involving cadets” “Zero-Tolerance policy regarding romantic or sexual relationships (including voluntary and consensual) between cadet and crew members”
“Provide written materials to the Academy that include the following:
•Formal policies and related materials prohibiting SA/SH
•Formal policies and related materials prohibiting fraternization (dating / consensual relations) involving cadets
•Evidence of mandatory review of policies by all shipboard personnel
•Training programs involving company and union personnel implementing anti-SA/SH policies
•Appropriate protocols governing reporting and investigation of SA/SH incidents”
“Company submits all relevant policies to SCCT; certifies that they meet Federal requirements”
“Documented post-voyage debrief of each cadet by the company (forwarded to the Academy)” “Standardized company debriefs of every cadet and mentor at completion of Sea Year time onboard;”
“Develop and implement a process providing cadets . . . [with a] [c]ompany representative ashore serving as advocate with 24/7 access” No similar requirement imposed by MARAD
“Develop and implement a process providing cadets . . . [with a] [p]olicy related to shore leave by cadets” No similar requirement imposed on the companies by MARAD (although it does create a shore leave policy imposed on the cadets) (In the proposal by industry, Maersk Lines had additional comments, which included recommending that  the Academy develop a standard shore leave policy for cadets)

For months, MARAD vilified an entire industry when it was the maritime industry that immediately stepped up to the plate and made concrete suggestions for a protocol for ensuring that midshipmen would be protected during sea year — a protocol that MARAD tweaked (and weakened) but otherwise adopted in toto.

The companies that made this proposal are:

Alaska Tanker Company, LLC Matson, Inc.
APL Maritime, Ltd. National Shipping Corp.
Argent Marine Overseas Shipholding, Inc.
Crowley Maritime Corp. Patriot Shipping Co.
Keystone Shipping Co. Saltchuk
Liberty Shipping Tote Services, Inc.
Maersk Line, Limited

They deserve our thanks.  And an apology from MARAD.



  1. These are all large companies that already had appropriate policies in place for a host of legal reasons. That’s what makes this stand down so unnecessary–these companies don’t ever want to get stuck legally and like every other large corporation, had already taken action to protect themselves. That’s why it only took a few days in June to present their proposal. They already had a system in place and did not have to start from scratch.
    Assuming the KPS comparison above is accurate (and there is no reason to think it isn’t), it’s just further evidence that this was a huge diversionary tactic to distract everyone’s attention away from the management failures pointed out in the middle states report.

    I hate to sound like a broken record (do kids even know what a broken record is these days) but I don’t want my comments seen as being so naïve to think that SASH is not a problem. SASH is a problem, but not to the extent of shutting down a core part of your curriculum. Their solution (the stand down) did nothing to address the problem and may have in fact created the “us v. them” mentality between female and male mids that the LMI report refers to. It’s the law of unintended consequences.

    Poor management exacerbated by political correctness and an inability to admit a mistake. Janecin is off to greener pastures. Rodriguez is off to greener pastures. Helis is left holding the bag but still gets a paycheck. The mids, who were told that “the world is their campus” are sitting on ships that don’t move.

    Again-Great job MARAD.

  2. The pre-planning for the cancellation of the Sea Year by the Maritime Administrator and his supporters, and the determination, with which they have successfully pursued their objective, has been impressive. What was their motivation?
    In my view, their motivation was to create a diversion, a smoke-screen, using the SA/SH issue to divert attention away from the persistent failure of Academy leadership. The stated MSCHE accreditation warning was based on the following five identified management shortcomings:

    1) Planning, Resource Allocation and Institutional Renewal, 2) Institutional Review, 3) Leadership and Governance, 4) Administration, and 5) Student Support Services.

    The shortcomings cited are clearly management responsibilities and are a reflection of the lack of proactive leadership at the Academy that has persisted for some time. In my experience, over some forty years consulting to management in government and industry, I have found that it is not uncommon to find that the cause of poor performance is invariably the result of complacent top management. Moreover, the cause is generally well known within an organization but it most always takes an outsider to point out the obvious.

    As one of the callers pointed out in the January 17, 2017 Town Hall Meeting audio, it is usually, if not always, necessary to replace the self-congratulatory managers in-place in senior positions within the organization with a new enlightened management team. Short of replacement, nothing will change, and the ‘battle of the consultants’ will continue, like opposing expert witnesses at a trial, thereby prolonging the agony at the expense of the institution.

    I hope that the new Secretary of Transportation receives the unvarnished facts that lead to the suspension of the Sea Year, and takes the actions necessary to resolve the root cause of the problem, replace the poor performers and put in place personnel policies that preclude recurrence.

    We are now at the ‘paralysis through analysis’ stage of this debacle and desperately need a leader to stand up and take charge.

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