In mid-September, the Department of Homeland Security Office of Inspector General issued a report evaluating the U.S. Coast Guard’s ability to effectively oversee merchant mariner credentialing in response to Congressional inquiry.   The report identified significant numbers of drug and alcohol allegations that received little or no follow-through, inaccurate records for mariners whose credentials were suspended or revoked, but not documented as such in the Coast Guard’s databases, and a policy gap in documenting reports on which the Coast Guard took no action.  Many of the shortcomings involved three (3) databases used by the Coast Guard to manage credentials—the Marine Information for Safety and Law Enforcement (MISLE 5.0) system, MISLE Adjudication, and the Merchant Mariner Licensing and Documentation (MMLD) database.  Current database architecture can hamper communication, and cause cases of Mariner misconduct to fall through cracks. This was further exasperated by the fact that these databases were not always up to date, or could provide ambiguous information, such as registering any abnormal entry as “void”, whether it was due to a credential revocation or a printing error.

The OIG recommended that the Coast Guard (1) establish a comprehensive case management system to track cases and (2) provide training for it, (3) create a policy to ensure that MMLD is up to date, (4) create a policy governing how Investigating Officers will decline to pursue a preliminary case, (5) ensure that Suspension and Revocation staff can search for impaired credentials, and (6) ensure that ALJ staff notify IO and Maritime Center staff on each decision. The report is DHS Report No. OIG-25-41.

Soon, mariners can expect to see a standardized policy used by the Coast Guard, including the use of a more modern and powerful system, the MISLE Enforcement and Adjudication Modernization (MEAM) system to enter and maintain data on mariner qualifications and discipline. Coast Guard created this system just after the initial investigations of the report were completed, and so it was not ready for the report. However, the Coast Guard intends that, by the end of the year, all data entry will be managed using this system.  Further, compliance with recommendations for greater documentation, the new system will require any investigation that does not result in a preliminary enforcement case to have a documented justification for no-action. The OIG was satisfied with the Coast Guard’s plans to redress their concerns, and MEAM will be the conclusive tool for this purpose.

Consistent with the report, the Coast Guard implemented a case tracking portal that will allow mariners facing potential cases to stay up to date on their case and be able to provide any representation with the same information quickly and easily. Mariners and counsel will also have the ability to file any documents needed for proceedings directly through the MISLE data systems, once registered, to help expedite all proceedings that may impact a mariner’s credentials. Links to these portals can be found in MSIB 04-25 and MSIB 05-25.