Not likely. I’m still wrestling with the 2nd Captain thing.
Comments in the “preamble” for the publication of a regulation cannot change the plain meaning of the regulation. They are used to discern intent when the meaning of the regulation is vague or unclear. If an agency says in rulemaking comments they intend to do one thing, but then write a regulation that clearly does something else, the regulation controls, not the intent.
Consider the following from ancient history. Prior to the mid 1980s, there was no requirement for a Chief Mate service for master unlimited. You could do it with 2 years time as 2nd Mate while holding chief mate. That was changed (a month before I was planning to sit for Master with all 2nd Mate time). So clearly there was an intent to require Master to have experience performing those duties that a Chief Mate has and a 2nd Mate doesn’t. That revised regulation from antiquity is still essentially unchanged.
Except that was not necessarily true. There were, and still are, unlimited tonnage ships that don’t require a “Chief Mate”, they only require three “Mates”.
Understood, that’s why I wanted your input…thanks. All an interesting academic exercise.
Which is what makes me laugh. Last comment was a sarcastic joke because there are so many damn hardos on here. I was self entitled and laughed at but this seems to be quite an interesting topic with many opinions and different interpretations from Mariners with different experiences. It just baffles my mind you can sail as master on a 6000 ton “unlimited tonnage by COI” osv and it does nothing for you towards unlimited master besides skipping chief mate. They (I’m sure someone will ask who I’m referring to so I’ll say I don’t know and don’t really give a sh*t who) really need to figure it out. And those who say just take the test it’s easy like a 100 ton test is makes me laugh the most. Shouldn’t the test be harder for such a position? The test is just a formality then? Almost like a handout being that simple? Maybe like a free lunch one might say?
Well, considering that I’d be interested in why you think there was a need for an OSV only endorsement for 1,600 GRT/3,000 GT or more if there already existed “unlimited” tonnage endorsements…
I’m not sure why you think it would do anything for you, you haven’t taken the exam so you don’t get a license. Be happy there a bullshit Large OSV license that allows you to work on vessels greater than 3,000 GT with only having taken the 1,600 ton Master exam.
Why would service of any kind exempt you from the exam? It doesn’t work that way for anyone else…
The Master Unlimited Inland is a super easy exam, but there’s still no way around it regardless of what prior exams you’ve taken.
“I’m not sure why you think it would do anything for you, you haven’t taken the exam so you don’t get a license. Be happy there a bullshit Large OSV license that allows you to work on vessels greater than 3,000 GT with only having taken the 1,600 ton Master exam.
Why would service of any kind exempt you from the exam? It doesn’t work that way for anyone else…”
…you are making this almost personal as if I said I’m the only person that should be able to do this. If I have to take the test so be it wouldn’t be the first and certainly isn’t the last. I’m also not the first nor last to think this is crazy. I get why they have a Large OSV endorsement. I just find it funny how you can be a limited master but be sailing in the capacity of unlimited master if looked at in a certain light. You have to admit painted in a way like that is kinda silly and backwards.
It is silly and backwards. They should require the Unlimited Master exam in order to get a Master Large OSV license.
Sorry, I didn’t mean you personally, here’s what I meant:
you are not sailing as an unlimited master on a large OSV because they are not an unlimited tonnage vessel requiring the license…they are large OSVs for CHRIST’S SAKE!
you just happen to be lucky that the USCG created the large OSV category to placate OMSA to not be forced to hire men like me and man those vessels as unlimited. You are the beneficiary of this but YOU STILL WANT FUCKING MORE!
NOW STOP YOUR FUCKING WHINING ABOUT THIS HERE…THERE ARE FEW ON YOUR SIDE AND I AM CERTAINLY NOT ONE OF THOSE!
I’d rather be forced to work for olebugge…
You are not sailing as an Unlimited Master since a large OSV doesn’t require one. Honestly, you should feel really fucking lucky that they allow special large OSV licenses at all because otherwise you’d never have a chance to move up from Master 1,600 to an Unlimited license. Be happy you’ve been able to get the sea time you have and go test for Master Unlimited. (Forget the Inland license and just go get Oceans.)
You’re not sailing in the capacity of an Unlimited Master. You’re limited tonnage,AND trade restricted. The tonnage just happens to be over 3000. Allowing you to use that time towards an actual unlimited license commensurate with your service. No different than fishing licenses or ITB time. All other requirements stay the same. CCaptain is right, be grateful this avenue exists, by all rights it probably shouldn’t.
But by and large it has been a successful program, with no incidents attributed to it (That I am aware of). At the time of it’s inception there were probably not enough UL license holders out there to who wanted to fill the positions anyway. Only after all the new tech and pay raises did anyone really even take notice.
BULLSHIT ON THAT! I was there in the GoM at the beginning of large OSVs and was hired by a company (OCLLC) as a backup in case the vessel I was assigned to was not accepted as a large OSV…it was subsea and not supply and the USCG was making noise that it should be a subchapter I miscellaneous vessel which would have made it U/L requiring a U/L master and officers. Obviously, the USCG rolled over and the vessel ended up a large OSV so my position ended up being a dpo (I don’t believe I even made 4th captain in their eyes) working for functionally illiterate captains with faces that looked like a toad! Ironically, the sistership was initially inspected as a U/L subchapter I vessel because it was inspected in Mobile and not Houma but even that was changed eventually.
I had loathed the US offshore industry from before this but afterwards my hatred of all things GoM became set in reinforced concrete. Ultimately, I just became a whore selling my soul to Joe Boss by prostituting myself for his money and from that in 2008, c.captain emerged to contaminate gCaptain with his never ending nasty invective against the avaristic GoM companies and their ignorant serf mariners.
Easy killer, I think I’m on your side on this one. It was just a theory…
GOOD LORD! It just occurred to me that any day now will be the tenth anniversary of c.captain’s first post here…something like 12000 of them ago
what a ride it has been in that decade…we’ve had DEEPWATER HORIZON, the plummet in crude prices and crash in the offshore industry, Shell’s Alaska debacle, the loss of the EL FARO, the ORCA and then the DAUNTLESS but saddest of all, the passing of my dear old dad…still today almost 3 years since his death, this captain’s Captain.
no theory…the OMSA companies never ever wanted educated U/L officers and fought hard to ensure they were able to get their own “good ole boys” stamped approved by the USCG to run new offshore ships just like they were boats.
In Gcaptain years I’m 7 months older than you!
But you’re far more prolific, like Brigham Young…
I sure wished many others who had been here over the past decade were still around…I wonder why someone would just completely stop posting?