service it replaces..." (IMO, 1993). The STCW guidelines do not define the nature, form, or content of special training, an issue that is under review by the IMO.

The amount of time and structure of at-sea experience required to qualify for an original license varies widely, from the structured sea project required of U.S. Merchant Marine Academy cadets during their year of service aboard merchant vessels, to the three annual roughly 60-day training ship cruises of the state maritime academies, to the normally unstructured periods of at least 3 years at sea by unlicensed personnel qualifying for an initial license examination. Other than a requirement for documenting the duration of service, no national or international standards exist on the type of experience to be garnered during this period.

It is important to recognize that no baseline has been established as a frame of reference for determining adequacy of the current sea-time requirements for building the necessary mariner knowledge and skills. The minimum sea-time requirements have not been validated by either scientific research or documented by empirical evidence. Although analyzing the adequacy of the sea-time requirements is beyond the scope of this study, it is important to note that all discussions of sea-time equivalency are based on the assumption that existing requirements are adequate.

DEFINITION OF SEA-TIME EQUIVALENCY

The U.S. Coast Guard (USCG) and other certification authorities have begun to modify license requirements for onboard experience and have granted mariners sea-time equivalency—reductions in onboard service requirements—for completion of onshore training. The term sea-time equivalency, as used in marine licensing and this report, refers to a formal judgment concerning the relative value of simulator and other structured training as compared with actual hands-on experience gained aboard ship.

The concept behind sea-time equivalency is based on the perceived value of structured training, especially simulator-based training. During the past few years, the majority of mariners who have advanced to the level of master have done so through a combination of structured academic and onboard on-the-job training. The use of sea time equivalency represents a conclusion by the USCG that structured, simulator-based training is equivalent to certain on-the-job, shipboard experience.

The granting of credit for simulator training as a substitute for required sea time is referred to as remission of sea time. Recently, the USCG stated that it will encourage training and simulator use by expanding the practice of sea-time remission (USCG,1993).

The STCW guidelines do not specifically define, though they do imply, that seagoing service is service aboard an actual ship. Remission policies are permitted,



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