— The Council of American Master Mariners, Inc. —
CAMM Views & Positions
Views & Positions Home Page
Page last updated on Mon, Jun 02, 2014
CAMM is widely recognized as an organization whose members are highly regarded and extremely knowledgeable about the issues on which we take positions.
The following are CAMM’s current positions on maritime matters. Positions were agreed on by attendees at our 2013 AGM or revised by the Positions Committee as instructed by membership. Changes recommended by the Positions Committee are shown in red type.
All Positions and VIEWS will be considered, voted on and possibly amended at the 2014 Annual General Meeting on June 13, 2014. Because of time constraints, members of CAMM wishing to enter comment into the record must submit written comment to firstname.lastname@example.org not later than Friday, June 6, 2014, for inclusion in the discussion.
Criminalization of Shipmasters REVISED May 2014
Positions Committee Recommends the following wording be used for this Position:
OPPOSE the immediate arrest of shipmasters after civil maritime incidents until appropriate criminal investigations are completed and all rights of the master are protected. OPPOSE the detention of shipmasters by any arresting Port State not respecting the warrant and status of the shipmaster.
SUPPORT IFSMA Resolution 1/2004 (AGA 30) calling on IMO, ILO and other regulatory interests to develop guidelines for Port States with regard to the arrest and detention of Masters without trial following maritime casualties. (See IFSMA AGA 30 - Resolution 1/2004 for full statement.)
Adopted 2004; 2013: Sent to committtee for re-wording
Ports of Refuge
SUPPORT the ancient doctrine of Port of Refuge and support the clarification of international law of said doctrine.
Adopted 2004; Amended 2013
One Man Bridge Watch
OPPOSE one-man bridge watch.
Adopted 2004, Amended 2013
Contamination and Safety REVISED May 2014
SUPPORT the reduction of substandard vessels.
SUPPORT strengthening U.S. law to assure that all U.S. regulatory agencies take decisive action to prevent: 1) contamination of U.S. waters by vessels of all registries, through discharge of oil, contaminated water, sludge, sewage, etc.; and 2) entry into U.S. waters of vessels infested with vermin, having insufficient potable water for the crew, and/or lacking basic safety and sanitation features.
Clarification: CAMM expects all U.S. regulatory agencies to detect and hold accountable substandard vessels of all flags and registries which contaminate U.S. waters through discharge of oil, contaminated water, sludge, sewage, etc. Additionally ships that: 1) are infested with roaches, rats and other vermin; 2) have insufficient potable water for the crew; 3) lack basic safety and sanitation conditions should not be permitted to operate in U.S. waters.
Adopted 2006; 2013: Sent to committtee for re-wording
Witness Treatment by U.S. Officials
OPPOSE detention of crew of violating ships for the purpose of serving as material witness(es), for an unreasonable period of time, resulting in loss of liberty, wages, and proper due process. “Unreasonable period of time” is defined in this instance as exceeding the 29-day period after which a D-1 visa would expire, leaving the crew member(s) unable to move about freely in this country.
Adopted 2006; Amended 2008, 2013
ILO/IMO Guidelines for the Fair Treatment of Seafarers 2006-08
SUPPORT the recommendations of an ILO/IMO Working Group on the Fair Treatment of Seafarers, to develop internationally accepted guidelines for addressing actions against and criminalization of seafarers.
ILO Maritime Labor Convention 2006
SUPPORT U.S. ratification of the ILO Maritime Labor Convention (MLC) 2006 to eliminate sub-standard shipping with respect to maritime labor.
NB: The MLC 2006 has NOT been ratified by the U.S. MLC 2006 went into effect on 20 August 2013 after the Philippines became the 30 country to ratify MLC 2006 on 19 October 2012.
Note of Clarification: MLC 2006 lays down stringent rules regarding working conditions and requests proof of compliance from ships. Port State control officers have the power to fine and detain ships which do not abide by the “Seafarers’ Bill of Rights”.
Adopted 2006; Amended 2008, 2013
Watch Stander’s Fatigue and Task-based Manning
SUPPORT IFSMA position that minimum manning levels established by Flag States be “task-based”, taking into consideration ship type and trading pattern.
Adopted 2007; Reworded in 2012 to condense two related positions to one; Amended 2013.
Seaman’s Manslaughter Act
SUPPORT changing the Seaman’s Manslaughter Act (U.S. Code, Title 18, Section 115) to require a higher standard of proof than simple negligence.
Proposed 2007, Adopted 2008
Vessel Documentation, Inspection and Mariner Credentialing
SUPPORT the transfer of vessel documentation, vessel inspection and mariner credentialing from Department of Homeland Security to the Maritime Administration, U.S. Department of Transportation.
Proposed 2007, Adopted 2008, Amended 2013
IFSMA E-Navigation Comments
SUPPORT IFSMA Working Group Recommendation that watch standers participate in the design and development of E-NAV equipment and that watch standers, rather than technicians, operate said equipment on the bridge. This Position applies to all electronic navigation systems including but not limited to ECDIS.
Adopted 2007, Amended 2009, 2011, 2013
International Piracy On the High Seas – Elimination of
SUPPORT the UN continuation of resolution adopted Dec. 17, 2008 and urge the governments of the world to work to defeat piracy wherever it occurs. CAMM asserts that it is the responsibility of the U.S. Government to provide the force protection necessary to ensure the safety of life and property aboard U.S.-Flag vessels. (currently UN resolution # 2077)
NB: Position 2013-01 deals with an IMO recommendation making the Flag State responsible for a much broader range of Flag State mariner care.
Adopted 2009, Amended 2013
Physical Guidelines for Merchant Mariners
SUPPORT the International Labor Organization, Maritime Labour Convention 2006 (ILO-MLC 2006), Regulation 1.2 – Medical Certificate.
Note of Clarification: Adoption of ILO-MLC 2006, Regulation 1.2 - Medical Certificate would oblige the USCG to remove the medical fitness requirements from the certificate of professional competency currently required in the Merchant Marine Credential (MMC). An independent two (2) year Medical Certificate would be added to the MMC. Said Medical Certificate would be in compliance with MLC 2006, Regulation 1.2.
Adopted 2011, amended 2013
Recognition of Foreign licenses, STCW certificates, and endorsements on U.S. VesselsRequirements for Foreign Crew Aboard U.S. Flag Vessels
OPPOSE any expansion of the language of CFR 46 USC 8103 (b)(3) to include any vessel other than those specifically cited therein. Furthermore, that any foreign seafarer holding a foreign license, certificate or document who is to be employed on a U.S. flagged vessel, be required to meet the same standards of certification and security check as would be required of a U.S. seafarer.
OPPOSE any expansion of the language of CFR 46 USC 8103 (b)(3) to include any vessel other than those specifically cited therein. Furthermore, require that any non-US citizen employed on a U.S. Flagged vessel be required to meet the same standards of certification, endorsement and security check as a U.S. seafarer.
Adopted 2011, Amended 2013
SUPPORT IFSMA’s position on developing industry standards for design study, stability, and fall-preventer devices for on-load release hooks for lifeboats. CAMM Further supports the development of international standards for lifeboat controls and operations, including procedures for launching and retrieving the lifeboats.
Adopted 2011, Amended 2013
Redundant Navigation Systems
SUPPORTS proposals made at the IMO that a redundant electronic system, including but not limited to LORAN E, be established to back-up GPS technology.
SUPPORT proposals made at the IMO that a redundant electronic system, including but not limited to e-LORAN, be established to back up GNSS technology.
Training in Celestial Navigation
SUPPORTS the inclusion of celestial navigation competency as a component of deck officer certification.
REAFFIRM our staunch SUPPORT for and retention of the Jones Act, Section 27 of the Merchant Marine Act of 1920 (Public Law 66-261)
Flag State Responsibilities in Incidents of Piracy
RECCOMEND that the International Maritime Organization create a regulation holding the flag state of any merchant vessel held captive by pirates politically and financially responsible for patrolling the pirate zone, freeing the crew, releasing the vessel from the control of the pirates and compensating the crew and their families for lost wages and hardship.
NB: 2009-04 Recommends U.S. support for UN Resolution urging world governments to defeat piracy.
Proposed 2012, Adopted 2013
Regulatory Burden on Ship Masters
SUPPORT appeals to the International Maritime Organization to review and reduce the regulatory burden imposed on vessel masters.
Note: Please visit IMO's website for information on their work on Reducing Administrative Burdens. The public comment period ends October 31, 2013.
Proposed 2012, Adopted 2013
Development of a Polar Code
SUPPORT the development and implementation of a Polar Code by IMO.
Food for Peace Program ‒ Public Law (P.L.) 480
SUPPORT the efforts of USA Maritime to prevent changes in the Food for Peace Program, proposed in the Administration’s FY 2014 Budget.
Note of Clarification: The current requirement requires that food purchased under the program be grown in the United States of America and transported in Congressionally prescribed percentages on U.S. Flag ships. The FY 2014 Budget changes P.L. 480 to a cash donation program through which recipient countries may purchase food from anywhere in the world, with no cargo preference provision.
Increase in USF Requirement under Food for Peace Program
SUPPORT USA Maritime’s position that the percentage of PL 480 cargoes which must be carried on U.S. Flag ships be restored to 75 percent. Further SUPPORT efforts to legislate a meaningful penalty for failure to ship on U.S. Flag vessels, at the required percentage.
The following are CAMM’s proposed current views on maritime matters. Views will be discussed and voted as official positions or dismissed at the 2014 AGM. Please email Committee Chair Ms. Lyn McClelland with additional comments.
UN Convention of the Law of the Seas Treaty
OPPOSE U.S. ratification of the Law of the Sea Treaty, which would give important domestic powers to an international authority based in Brussels. Specifically oppose provisions which would result in American ship masters accused of offenses at sea being tried by an international court in Europe, and conducted without the benefit and protection guaranteed by the Constitution of the United States.
Adopted 2004; 2013: Tabled. Sent to committtee for further discussion.
Note from Committee: We don't have any information about whether the U.S. Senate has taken action to ratify UNCLOS. Hoping for that update before the AGM.
U.S. Coast Guard ownership of Merchant Mariner Credential (MMC) / License 02-2013
OPPOSE Coast Guard position that the agency owns the new Merchant Mariner Credential (MMC)/License issued to a seaman and can revoke or recall at any time without cause as set forth in the Code of Federal Regulations. CAMM contends that the credential is the property of the user, and that it is to be surrendered to the Coast Guard only after due process. CAMM supports changing the CFRs to that affect.
POSITIONS Committee notes that the USCG no longer uses the word “license” when referring to the merchant mariner’s license.
NB: CAMM does not challenge USCG right to revoke Z card.
Adopted 2008; 2013: Discontinued. Sent to committtee to submit new view that is more current.
Design Requirement for New Ship Construction
SUPPORT a design requirement whereby all new ship construction shall include an elevator/lift when the navigation bridge is more than 4 decks or 12 meters, whichever is greater, from the main deck or pilot embarkation point.
Adopted 2012; 2013: Tabled. Sent to committtee for further discussion.
Positions Committee recommends the following wording:
SUPPORT the IMO Protocol for handling of pilot ladder rigging and SUPPORT a design requirement whereby all new ship construction shall include an elevator/lift when the navigation bridge is more than 4 decks or 12 meters, whichever is greater, from the main deck or pilot embarkation point.
Emergency Response Infrastructure for Arctic Shipping
RECOMMEND that the International Maritime Organization require that infrastructure for emergency response be established by nations boarding the Arctic Shipping routes. Financing of recourses to be offset by toll and/or tax for ships using the Arctic Passages. and that vessels using Arctic passages provide funding for emergency response infrastructure.
Discussion: With the continued increase of Arctic shipping it will be necessary to insure there are emergency response equipment and support readily available in the region. Due to the extreme weather and remote location, such infrastructure must be staged as close as practical to the Arctic Ocean. This will necessitate the adjoining nations to provide Arctic Ocean access and land area to house said support teams and attending equipment. It cannot be expected that the boarding nations be solely financially responsible for provide land, equipment and personnel.
Under-Qualified Officer Promotions(New Title)
The following two views were combined by positions committee, as instructed by membership, and are offered as a new 2014 view as follows:
OPPOSE Coast Guard’s proposed regulations which would allow a third or second mate to progress to an unlimited master’s license with only 36 months’ service as a third or second mate, removing the requirement of six-months service as chief mate on unlimited tonnage vessels. (Formerly View 03-2013, offered as Officer Promotion Requirements.)
OPPOSE Coast Guard proposal to allow a third mate with only 12 months’ service as an Officer in Charge of Navigational Watch (OICNW) to progress directly to chief mate unlimited tonnage. (Formerly View 04-2013, offered as USCG Advancement to Chief Mate Requirements.)
To view full text on the USCG proposed changes, view/download the Federal Register.
Adopted 2010 as Positions 02-2013 and 04-2013; 2013: Tabled. Sent to committtee to merge with new title "Under-Qualified Officer Promotions".