review process. This much-needed update discusses several conditions and the information that the Coast Guard will most likely need to make a determination. While I applaud the Coast Guard's efforts to ensure a competent merchant mariner population, I believe the method in which they are doing so is flawed. Statistics will confirm that approximately 1% of the applications reviewed by the medical evaluation branch are denied. That, of course, means that 99% of the applications they review show that they are successfully treating their conditions and their medical practitioners provided sufficient information. The Coast Guard should place the burden back on the mariner, their medical practitioners, and the industry that hires them. As a manager of marine personnel, I feel it is my duty to ensure that the crews are physically competent. While medical privacy laws may prevent me from obtaining certain specific information, I can certainly request that any mariner provide general documentation that they are competent to perform their duties from their physician. However, many in the industry still rely solely on the Coast Guard's licensing system to ensure that mariners are physically competent and that burden is proving to be too much for a budget strapped government. So what is the solution? I believe the Coast Guard needs to establish a separate merchant marine medical review board, which is made up of occupational health specialists who fully understand the Coast Guard licensing scheme and the duties of those working in the merchant marine. This review board should work to establish clear and concise standards for certain medical conditions, which could then be evaluated and assessed by any licensed medical practitioner. Those standards should also be incorporated directly into the regulations by following proper regulatory procedures. While the new NVIC was sorely needed, it is not law and the process for publishing a NVIC is not held to the same scrutiny as a regulatory change. In addition, to prevent physician "shopping," mariners should be required to provide their medical history to any physician that is completing the Coast Guard form. If they don't have that information, it should be made known and the burden of testing the mariner for certain key medical conditions should fall on the mariner and/or physician. Simply checking 'yes' or 'no' on the form is not enough. At a minimum, there should be a requirement that the physician completing the form attests that they have actually reviewed the mariner's medical history. No medical review system is perfect and no system would have, in my opinion, prevented the Staten Island Ferry incident. However, we can all agree that the mariner population in this country is dealing with many of the same medical conditions that plague the general population and it is important for everyone involved to make sure that mariners remain physically competent. It is also imperative that managers become familiar with the Coast Guard's medical review process and understand how that can affect your ability to crew your vessels in the future. Hopefully changes can be made for the better with an eye toward improving a system that can improve the overall safety of our industry and incorporate a full understanding of the merchant marine.
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