Glen M. Paine

The security course approval system implemented by MARAD did not come into force until over two years after the start of vessel security training. This means that many mariners will have to retake the security course simply becaused they took the course before any course approval system. This situation can be fixed by amending the course approval date back to the date of when the course was first taught instead of the date of the implementation of the course approval system. This should be allowed for all vessel security officer training courses that meet the following criteria: #1 The course met the MARAD/DNV requirements for certification. #2 The course was taught under a quality standards system. #3 The school's QSS auditor concurs that the courses taught before the certification date are substantially the same as the courses taught after the certification date.