Enclosure (1) to COMDTINST 16721.1
8.
ACTION ON MINOR DISCREPANCIES.
a.
Minor discrepancies (i.e., incomplete student course evaluation forms, information
missing from student files, the inability to produce required administrative files for an
inspection within a reasonable period of time, continually reusing the same written
examinations) must be discussed with the administrators of the training organization. The
problem(s) should be reviewed, appropriate remedial actions(s) determined, and a
reasonable time frame established in which to correct the discrepancies, usually not to
exceed 30 days.
b.
Failure of an instructor to professionally conduct a course is also a discrepancy and should
be noted in a discrepancy letter. If an auditor evaluates an instructor as being ineffective,
the auditor's evaluation should be compared to the opinions of the students attending the
course. If students' critiques substantiate an auditor's appraisal, the training organization
and the instructor must be provided the opportunity to modify the individual's instructional
technique for re-evaluation at the next course presentation. A serious breach of an
instructor's responsibility may result in the suspension or withdrawal of a course's
approval until that instructor's name is removed from the list of instructors approved to
teach the course.
9.
SUSPENSION.
a.
Suspension entails the temporary removal of the approval of a course. Because of the
serious implications, the basis for imposing a suspension must be well documented. The
OCMI in whose area of responsibility a course is being offered has the authority to
suspend an approval if one or more major discrepancies are discovered. In the rulemaking
on the issue, the Coast Guard indicated that it would allow time for correction of a
discrepancy. The OCMI should notify the training organization in writing of his or her
intention to suspend the approval, the reasons for the proposed suspension, and set forth an
appropriate period of time to correct the deficiencies. However, in an instance of a
flagrant or egregious discrepancy, the suspension may be imposed immediately even if the
course is still in progress. If the training organization fails to correct the discrepancies
within the allotted time, the course's approval will be suspended and the matter referred to
the NMC. The NMC will review the information presented by the OCMI and will contact
the training organization about the period of suspension and corrective action on the
discrepancies. The NMC may grant the training organization up to 60 days to correct the
deficiency and may withdraw the course's approval if not corrected.
b.
Suspension is the appropriate response to multiple and/or frequent discrepancies that
would normally warrant only a letter of notification. Suspension is also an appropriate
response for the following violations:
(1) Failure to comply with the provisions of the course's approval such as failure to
provide required training aids or facilities;
(2) Receipt of three letters of notification of minor discrepancies during any three-year
period may render the course liable for suspension for not less than 30 days or until
the discrepancies are corrected, which ever is longer;
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