What are the criteria for the restoration of sea year on commercial ships?

In the January 6, 2017 all-hands meeting, Superintendent Helis assured the regiment of midshipmen and faculty that there was “a way ahead to restore training on commercial ships.”  That begs the question — what is the way ahead?  What are the criteria that a shipping company must meet in order to have midshipmen assigned to its ships?

In Secretary Fox’s letter to Helis (which was issued the same day as the all-hands meeting) Fox stated,

“you are authorized to resume Sea Year training on commercial vessels in a phased, company-by-company manner, provided that MARAD and the Academy have determined that a company has complied with the credentialing criteria established by the SCCT [Shipboard Climate Compliance Team], as recommended in the LMI report.”

(Emphasis added.)

The letter indicates that the SCCT has actually “established” [past tense] the credentialing criteria. The same day that Secretary Fox’s letter was issued, the Academy issued its “action plan” and stated that the creation of the credentialing criteria was a “completed” task:

“Shipboard Climate Compliance Team (SCCT) develop a Sea Year Credentialing Process in conjunction with the industry and maritime unions (Completed)

(Emphasis added.)

So where are the criteria?  Why have they not been widely published?  Is there some reason that the midshipmen, the parents, and the alumni should not see these criteria? Are they a state secret? Note that on the day of the all-hands meeting, DOT was quick to publish no fewer than six documents relating to the LMI report and the “restoration” of sea year on commercial ships.  Yet it couldn’t be bothered to post the actual criteria that are going to decide whether a shipping company can begin hosting midshipmen on sea year?

MARAD is quick to accuse people of believing in wild conspiracies; but, when MARAD hides information that should be public, it creates the basis for such beliefs. Some stakeholders are beginning to believe that MARAD has deliberately made the criteria so difficult that no company can possibly meet them. They argue that MARAD is hiding the criteria so that we won’t be able to raise a ruckus if the criteria are impossible to meet.  MARAD can quickly dispel such fears by publishing the criteria.  And this blog will be happy to publish them if MARAD (or anyone else) sends them to:

Andy Simpson 82 [at] Save Kings Point.com [no spaces]

FWIW, I don’t buy the theory that the standards have been made deliberately too difficult to meet. I have a different theory: 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.


  1. Perhaps we should find out how MARAD meets SCCT standards onboard their own ships that they are now requiring of others?

  2. Two things I just want to reiterate from some of my previous posts because I think they are relevant to this post.
    1. This all could have been done in July, while still allowing LMI to go forward with its study, and
    2. MARAD and the Academy leadership are their own worst enemy. Despite denying from the beginning that there was some sort of conspiracy to either partially or totally eliminate the traditional sea year, every move they have made plays directly into the hands of those who believe that such a conspiracy exists.

    This is why KPS and the Alumni Association, two groups that they really don’t want involved in this issue, have more credibility among various stakeholders than they do.

  3. BOY do I hope you are right, Sentry, because the alternative is too upsetting. I truly hope and pray that the standards are what was already proposed months ago!

  4. During the town hall call on Tuesday, I believe it was Rodriguez who stated the following as to what the criteria is: (summarized)

    1.Each vessel must have a designated mentor assigned to whom each cadet can go to

    2. Message from the ceo of the company stressing zero tolerance for SASH and evidence of implementation of the zero tolerance.

    3. Annual prevention training for crews—and evidence that crews are trained and acknowledge company policies. There was discussion of this being possibly a standard computer based program, which is still in the process of being developed.

    4. Zero tolerance policy with regards forbidding the consensual/non consensual relationships between cadets and crew, and confirmation that crew acknowledges such.

    5. Certification from the company that their policies meet federal requirements and policies, and such are provided to Marad (?).

    While The comments are paraphrased, this was taken from the response to a 2020 parent who specifically asked him to state the requirements.

    Standardized debrief that company will ask cadets upon disembark

  5. It is not clear under what authority of US Code law (USC) or Federal Regulation (CFR) MARAD can take this action? I have yet to see anything formally released in the Federal Register. The only thing I can see this as a tie to is the US Flag shipping subsidies, but not all ships receive these. Am I missing something?

    • Nope, if you do not take a subsidy, you cannot be compelled to meet MARAD demands. Many shipping companies may very well “opt out” of offering berths to KP. Why should they? They can simply service the state academy sea term needs, hire competent employees from that pool of candidates that they have “interviewed” during sea term, and stay out of the whole crazy USMMA fray. I have been constantly asking how many ships receive subsidies and how many do not. I would like to know what the long-term impact of ship availability will be after the shut-down (assuming sea year on commercial ships ever returns).

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