Entry & progression
Entry: you are collecting assessment signatures now. Progression: the rules on who may sign change on a fixed date. Read this before you collect another one.
WARNING — 1 JANUARY 2029 — all assessments must be signed by a Coast Guard-approved Qualified Assessor NVIC 17-14 (CH-8) and NVIC 15-14 (CH-6): "All assessments must be signed by a qualified assessor approved by the Coast Guard in accordance with 46 CFR 10.405."
"After December 31, 2028, QAs must be approved by the National Maritime Center."
For years the practical answer to "who can sign my assessments?" has been loose. A chief engineer who met the criteria at 46 CFR 10.405(a)(3) could sign. Plenty of people learned the trade being told that any suitably senior engineer aboard could do it. That advice now has a hard expiry date, and it is close enough to matter to anybody starting an OICEW or ETO package today.
The transition — NVIC 19-14 (CH-5)
| Date | What happens |
|---|---|
| Now → 31 December 2028 | A non-approved assessor who meets 46 CFR 10.405(a)(3) is still accepted. |
| 1 January 2029 | Every assessment must be signed by a QA approved by the Coast Guard (46 CFR 10.405). No exceptions. |
| Signed before 1 Jan 2029 → accepted until 30 June 2029 | Assessments already signed by a non-approved assessor remain acceptable only until 30 June 2029. After that they are dead paper. |
CAUTION — There is a cliff, and there is a shelf life Two separate dates, and people conflate them.
31 December 2028 is when a non-approved assessor may last put pen to paper.
30 June 2029 is when the paper he signed stops being worth anything — even if it was signed years earlier.
So an assessment signed by a non-approved assessor in 2026 has a shelf life of about three years. If your application is not filed and worked by 30 June 2029, that signature is gone and the task must be reassessed by an approved QA.
What a Qualified Assessor is
A QA is an individual approved by the National Maritime Center under 46 CFR 10.405 to conduct and sign competence assessments. The approval is a formal one — you apply, the NMC assesses you, and it grants approval. QA approvals run five years (10.405(d)), so an approved assessor is himself on a renewal clock.
Why this matters more on yachts than anywhere else
Because a shipping company with a cadet programme will have approved QAs on its books; it is a normal cost of doing business. A private yacht has whoever the chief happens to be. If that chief is not an approved QA on 1 January 2029, then from that date nobody aboard your vessel can sign anything, and the assessments have to be done ashore, or on another vessel, or not at all.
What to do about it now
- Find out whether the person signing your task sheets is an approved QA — not merely someone who meets 10.405(a)(3). Ask. It is a fair question.
- If they are not approved, understand your signatures have a shelf life ending 30 June 2029, and plan your filing date around it.
- If you are the senior engineer signing for others, look at NVIC 19-14 (CH-5) and get approved. Approvals take time and run five years.
- Do not batch your assessments into the last six months of a programme. The window narrows every year.
- Check the current NMC guidance before you rely on any of this — the transition dates are guidance-set, and guidance is amended.
None of this changes what competence means, or what a good assessment looks like. It changes whose signature the Coast Guard will accept, and that is enough to derail an application that was otherwise complete.