Dragos Butucea-Boscoianu

The proposed incorporation will obviously allow commercial fishing companies to be fully staffed thus averting any safety hazards. However, I am not fully convinced that this regulation would achieve the declared purpose. If the seamen must be “otherwise authorized for employment in the United States under the INA” then the pool of potential candidates is pretty narrow. It would only be comprised by those seamen who are already employed but whose employer is going out of business or no longer needs their services. Thus, the regulation only achieves intra-business portability. On the other side, the regulation would expedite and streamline the waiver process and allow commercial vessel operators to become fully staffed. (This comment is posted for the limited purposes of complying with a law school class assignment and for no other.)