Limitations within the STCW are considered in one of three places. Understanding the difference between when to use each is vitally important.
In the STCW, there are three places where limitations are considered.
- 1. Against the functions for an officer. These are set by the issuing country and cannot be changed by the recognising country. When an application is made the applicant needs to put these in exactly as they are on the COC. If the applicant forgets or puts the wrong one, the approving officer at the flag state can make the correction, but in the end only the function limitations that are on the seafarer’s COC can appear against functions.
- 2. Against the capacity. Any limitations that appear against functions need to repeat against capacity. So for example, if the issuing country has put “Not valid on steam ships” against the function “Marine engineering” then that needs to repeat on the endorsement against that function and also repeat against the capacity. Seafarer HQ does this automatically. So if this limitation is recorded against the “marine engineering” function, it will automatically appear in capacity so the endorsement will show “Chief Engineer - not valid on steam ships”. The person approving the application does not need to do anything further. If there is no limitation against any function but the issuing state has placed a general limitation against capacity, this should be inserted by the applicant as it is on the COC. Again the approving person needs to do nothing, just check that it is there. If it is there it will appear correctly on the endorsement.
- 3. There is a final option for limitations. This is now extremely rare. It was more common in the early days of the endorsement system but is now very rarely used. That is the right of the recognising state to issue an endorsement for a lower capacity or with further limitations that it wants. It can’t limit functions as that is reserved for the issuing state, but it can limit capacity. In the early days it was common for example, for an applicant with a Master COC to get an endorsement as Chief Mate until such time as the company reported his performance as suitable, at which point he was granted the full master endorsement. This is a residual right that is now rarely used. To go with it the recognising state can add its own limitations.
It was to deal with this last scenario that Seafarer HQ had a set of standard limitations that the flag has configured as a drop down and can be edited via settings. When approving an endorsement application, it is possible to “add a different capacity/limitation” allowing the recognising country to select a different capacity and a set of standard imitations. It was done this way to reflect the 3rd scenario above and to avoid a steadily growing list of different ways to state the same limitation. However, our experience has shown that flag states rarely used this facility, and the option to report on type of limitation is not a valuable use case.
The option to be able to set a recognising state limitation different from that on the COC is still required, and several clients do use this. Some flag states limit endorsements to a set company “valid only on vessels operated by XYZ Company” whereas others are less specific. Ensuring flag states have the ability to use their right to issue endorsements for lower capacities is a core feature that all clients have access to as standard.
