ACN 047/18 - MAY 2018 INTERIM CHANGES TO AIDS TO NAVIGATION STRUCTURE CLIMBER PERSONNEL QUALIFICATION STANDARDS

ALCOAST COMMANDANT NOTICE    CANCEL DATE 15 MAY 2019

R 160944 MAY 18
FM COMDT COGARD WASHINGTON DC//CG-5PW//
TO ALCOAST
UNCLAS//N16500//
ACN 047/18
SUBJ:  INTERIM CHANGES TO AIDS TO NAVIGATION STRUCTURE CLIMBER PERSONNEL
QUALIFICATION STANDARDS
A. Aids to Navigation Structure Climber Personnel Qualification Standard (PQS)
Manual, COMDTINST M16500.14 (series)
B. Aids to Navigation Manual – Structures, COMDTINST M16500.25 (series)
C. U.S. Coast Guard (Boat) Operations Manual, Volume I, COMDTINST M16114.32 (series)
D. U.S. Coast Guard (Boat) Operations Manual, Volume II, COMDTINST M16114.33 (series)
1. This ACN provides interim changes to REF (A) and (B). Units with personnel that climb
ATON shall immediately integrate these changes into their ATON Structure Climber (ASC)
Program. These changes will be incorporated into the next update of REF (A) and (B).
2. Climber PPE: All ASC PPE shall meet ANSI, ASME, EN, or NFPA certification standards.
Any equipment not meeting at least one of these standards shall be taken out of service.
This requirement will be included in the next update of REF (B).
3. Climber Program Specifics: REF (A) will continue to include 3 separate qualification
levels of climber with the following changes.
   A. ATON Structure Climber - Basic: CO/OICs will ensure that members seeking
orders to NATON's ATON Structure Climber Course (Course ID 501850) are at a minimum Basic
Climber certified before attending. Certified Basic level climbers shall receive the
competency code - ASBC.
   B. ATON Structure Climber – Advanced: The following is a significant policy change for
Advanced Climbers. Advanced Climbers certified by their CO/OIC may serve as the mandated
safety observer for unit ATON structure climbs less than 20 feet in height. To be able to
serve in this capacity, the Advanced level climber shall complete Rescue Climber PQS task
RC-02, Safety Observer, and this completion entered into TMT. This change negates the
current requirement in REF (A) that a Rescue certified climber be present at every unit
climb. Certified Advanced Climbers shall receive the competency code – ASCA.
   C. ATON Structure Climber – Rescue: These climbers are certified to conduct rescues,
climb ATON structures of any height, sign off PQS for Basic or Advanced level climbers,
function as the unit’s OSHA mandated competent person, serve as a safety observer for all
unit ATON climbing operations (mandatory for ATON structures over 20 feet), assist with
managing their unit’s currency maintenance program, provide personnel qualification/
certification recommendations to the unit CO/OIC, administer the unit’s ATON Structure
Climber equipment maintenance and inspection program, assist the command with the unit’s
working at heights program, and create and maintain updated rescue plans for all of the
unit’s ATON structures. Rescue Climbers can only be qualified by attending the ATON
Structure Climber Course and must be certified by their CO/OIC. Additional details can be
found in REF (A). Certified Rescue Climbers shall receive the competency code – ASCR.
4. Recertification of members transferring from ATON unit to ATON unit: If a previously
certified member transfers to an ATON unit and was not assigned structure climbing duties
and more than 6 currency cycles pass before the member returns to an ATON unit with
structure climbing duties, the member shall not be eligible to recertify as outlined in
section D.3 and D.4 of REF (A). In these situations, Basic and Advanced level climbers shall
requalify by completing the appropriate climber level qualification tasks in REF (A), while
previously certified Rescue Climbers shall follow the requirements set forth in Section D.5
of REF (A).
5. Climbers certified under the previous CEU training program: The CO/OIC shall evaluate
their CEU qualified climbers based on the type of formal training received. Climbers trained
by a CEU or CEU Train the Trainer Instructor must have maintained an active certification
since their training and have been actively climbing at their current unit. Members meeting
these criteria are authorized to continue to climb as long as they are certified by the
CO/OIC, but shall complete the applicable level of the ASC PQS within the next 6 months.
6. CEU Rescue: The member must have completed a CEU Train the Trainer Course and maintained
an active certification since their training and be actively climbing at the unit. If the
CEU Train the Trainer Course is identified as the member’s sole source of training, the
member must submit an email waiver request to COMDT (CG-NAV-1) to be granted a temporary
ASCR competency. Before a member requests a waiver, they must complete the tasks for Rescue
Climber in chapter 4 of REF (A), have an active ETR on file for the ATON Structure Climber
Course (Course Code 501850), and shall attend NATON training at their earliest opportunity.
7. First Aid:
   A. Initial Certification: Initial first aid certification shall now match the requirements
found in REF (D). Completion of initial certification for boat crew positions concurrently
meets the initial certification requirement for ASC.
   B. Currency Maintenance: The annual first aid currency maintenance requirement found in
the Basic Climber currency maintenance now also applies to Advanced and Rescue level
climbers. OSC has updated TMT to allow units to accurately document this change. First aid
currency requirements shall match those in REF (C). Completion of annual currency maintenance
for boat crew positions concurrently meets the currency maintenance requirements for ASC.
8. The CO/OIC shall take into account each member’s judgment, maturity, climbing skills and
willingness to serve as either a Basic, Advanced or Rescue Climber before allowing the member
to train and qualify as an ASC. Note that the first requirements for any climber is that they
be a responsible volunteer and physically capable.
9. Commercial Training: NATON’s annual ASC training quotas have been significantly increased
since the promulgation of REF (A). As a result, commercial training is no longer an
authorized training source for unit ATON Structure Climbers. Units shall train Basic and
Advanced level climbers using the ASC PQS and unit Rescue Climbers shall attend the NATON
ASC course. Certifications gained through commercial training will remain in effect as long
as the member's certification remains active.
10. NATON ASC Training: NATON is currently authorized up to 160 student quotas and up to 10
convenings for FY19. Units shall continue to submit ETR’s and include enrollment concerns
pertaining to departing unit Rescue Climbers. This information will assist NATON in
prioritizing the candidates for each upcoming ASC course. As per 3.A, certification as a
Basic Climber is now a prerequisite to attend NATON training.
11. District (dpw) ATON Training Teams (TT): TT members who have attended the NATON ASC
course, commercial rescue training, or meet the criteria in paragraph 6, may, with the
approval of the unit CO/OIC, sign unit personnel PQS tasks and assist their units with
currency maintenance (rescues and climbs). Units should contact their District TT to schedule
assistance. TT members shall adhere to the currency maintenance requirements in REF (A) and
the updates contained in this ACN.
12. These changes will be reflected in future updates of REF (A) and (B) and will released
within the next year of this ACN.
13. Questions regarding the ASC Program should be directed to Mr. David Merrill of
COMDT (CG-NAV-1) at 202-372-1548 or David.Merrill@uscg.mil.
14. Released by Mr. Michael Emerson, Director, Marine Transportation Systems Management.
15. Internet release is authorized.