Entry & progression
Entry: you have the task sheets in front of you. Progression: understanding what they are — and are not — tells you when you may depart from them, and when you may not.
The NVICs' own disclaimer
NOTE — In the NVICs' own words "…nor is it itself a regulation. It is not intended to, nor does it impose legally-binding requirements on any party."
The binding text is 46 CFR Parts 10, 11, 12 and 15. The NVIC tells you how the Coast Guard intends to apply the regulation. It cannot add a requirement the regulation does not contain, and it cannot take one away.
This matters in both directions, and getting it backwards is how people either over-comply with a suggestion or under-comply with a rule.
The task sheets are a model, not a mandate
NVIC 15-14 and NVIC 17-14 both say it: "The use of these Assessment Guidelines is not mandatory and alternative means… will be considered." You are not compelled to use the Coast Guard's task sheets. A training provider or a company may build its own assessment scheme.
WARNING — But there is a condition, and it is absolute "…alternative Assessment Guidelines must be approved by the National Maritime Center before use."
Before use. Not afterwards. A company that invents its own assessment scheme, runs a cohort of engineers through it, and then asks the NMC to bless it has wasted everybody's time. The approval is a precondition, not a ratification.
So what is actually binding?
| Document | Status | What it does |
|---|---|---|
| 46 CFR Parts 10, 11, 12, 15 | Regulation — binding | Sets the endorsements, the sea service, the training, the thresholds |
| STCW Code Sections A-III/1, A-III/6 | Convention standard, given effect by the CFR | Sets the competences |
| NVIC 17-14, 23-14, 19-14 | Guidance — not binding | Model task sheets, assessment methods, QA policy |
| NMC checklists | Administrative | What the NMC will actually work your file against |
The practical rule
Follow the NVIC. In every ordinary case the sensible thing is to use the Coast Guard's own task sheets, because they are what the NMC expects to see and they are free. Departing from them buys you nothing unless you have a real reason and the NMC's prior approval.
But when an NVIC and the CFR appear to conflict, the CFR wins — and when someone tells you "the NVIC says you can't," the right question is whether the regulation says so, or whether the guidance merely does not contemplate it. Those are very different situations.
CAUTION — Verify against the regulation, then against the NMC The CFR is amended. NVICs are amended more often — note the change numbers: 17-14 is on CH-8, 23-14 on CH-4. A three-year-old printout of a task sheet may be a superseded edition. Pull the current version from the NVIC index before you start collecting signatures, and pull the current NMC checklist before you file.