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CAMM Views & Positions

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Page last updated on Mon, Sep 15, 2014

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CAMM is widely recognized as an organization whose members are highly regarded and extremely knowledgeable about the issues on which we take positions.

Current Positions

The following are CAMM’s current positions on maritime matters. Positions were agreed on by attendees at our 2014 AGM or revised by the Positions Committee as instructed by membership.


POSITION
2004-01

Criminalization of Shipmasters

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 committee for re-wording, amended 2014.;


POSITION
2004-02

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


POSITION
2004-07

One Man Bridge Watch

OPPOSE one-man bridge watch.

Adopted 2004; amended 2013


POSITION
2005-02

Contamination and Safety

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.

Adopted 2006; amended 2013, 2014


POSITION
2006-05

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


POSITION
2006-08

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.

Adopted 2006


POSITION
2006-09

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


POSITION
2007-03

Watch Stander’s Fatigue and Task-based Manning

SUPPORT flag state implementation of new IMO requirements under IMO resolution A. 1047, Principles of Minimum Safe Manning, and SOLAS Chapter V/14, Ships’ Manning. Also SUPPORT the enforcement thereof.

Adopted 2007; reworded in 2012 to condense two related positions to one; amended 2014.


POSITION
2007-06

Seaman’s Manslaughter Act

SUPPORT changing the Seaman’s Manslaughter Act (U.S. Code, Title 18, Section 1115) to require a higher standard of proof than simple negligence.

Proposed 2007; adopted 2008


POSITION
2008-04

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


POSITION
2009-01

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


POSITION
2009-04

International Piracy On the High Seas – Elimination of

SUPPORT the re-authorization of United Nations Security Council Resolution # 2125 (renewed 18 November, 2013 and recalling its previous resolutions) to authorize funding for international action to fight piracy, and to urge the governments of the world to work to defeat piracy wherever it occurs.

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, 2014


POSITION
2011-01

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


POSITION
2011-03

Requirements 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, require that any non-US citizen employed on a US Flagged vessel be required to meet the same standards of certification, endorsement and security check as a U.S. Seafarer.

Read the CAMM Statement submitted to the CFR docket for public comment.

Adopted 2011; amended 2013, 2014


POSITION
2011-04

Lifeboat Safety

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


POSITION
2012-01

Redundant Navigation Systems

SUPPORT international effort to require that redundant and independent electronic navigation system(s) be established to back up Global Navigation Satellite System (GNSS) technology.

Adopted 2012; amended 2014


POSITION
2012-02

Training in Celestial Navigation

SUPPORTS the inclusion of celestial navigation competency as a component of deck officer certification.

Adopted 2012


POSITION
2012-04

Jones Act
REAFFIRM our staunch SUPPORT for and retention of the Jones Act, Section 27 of the Merchant Marine Act of 1920 (Public Law 66-261)

Adopted 2012


POSITION
2013-01

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 U.N. Resolution urging world governments to defeat piracy.

Proposed 2012; adopted 2013


POSITION
2013-02

Regulatory Burden on Ship Masters

SUPPORT the International Maritime Organization efforts 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; amended 2014


POSITION
2013-03

Development of a Polar Code

SUPPORT the continued development and implementation of a Polar Code by IMO.

Adopted 2013; amended 2014


POSITION
2013-04

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.

Adopted 2013


POSITION
2013-05

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.

Adopted 2013


POSITION
2014-01

U.S. Coast Guard ownership of Merchant Mariner Credential (MMC) / License

Continue to OPPOSE Coast Guard position that the agency owns the new Merchant Mariner Credential (MMC)/License issued to a seaman and that USCG can revoke or recall the document 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.

CLARIFICATION: Positions Committee notes that the Original Position was discontinued because the USCG has taken actions indicating that it considers this a moot point. USCG no longer uses the word “license” when referring to the merchant mariner’s license. Revived because CAMM members wish to press the issue with Congress. CAMM does not challenge USCG right to revoke the Z card, as long as due process is followed.

Adopted 2008; discontinued 2013; reinstated 2014.


POSITION
2014-02

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; tabled 2013; reinstated 2014


POSITION
2014-03

Emergency Response Infrastructure for Arctic Shipping

RECOMMEND that the International Maritime Organization require that infrastructure for emergency response be established by nations bordering the Arctic Shipping routes and that vessels using Arctic passages provide funding for emergency response infrastructure.

COMMENT from Position Committee: Specifics regarding rescue in the Polar Region are under development. CAMM wants to assure that their Position is considered.

Proposed 2013, adopted 2014


POSITION
2014-04

Under-Qualified Officer Promotions(New Title)

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; tabled 2013 to combine two related positions; adopted 2014


2014-15 Current Views

The following are CAMM’s proposed current views on maritime matters. Views will be discussed and voted as official positions or dismissed at the 2015 AGM. Please email Committee Chair Ms. Lyn McClelland with additional comments.

VIEW
01-2013

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 proceedings conducted without the benefit and protection guaranteed by the Constitution of the United States.

Text of UNCLOS may be found online at the U.N. website.

Adopted 2004; tabled 2013, 2014 and returned to Committee for further analysis.