Licensing Question


#1

I have an raise-of-grade application in to NMC right now for 2AE unlimited HP and STCW III/2 Second Engineering Officer. The evaluator called me today and they approved my 2AE unlimited HP. Great!

However, they would not approve the STCW III/2 Second Engineering Officer and seemed much perplexed by the stated requirements for this endorsement. The evaluator kept stating that because I don’t have national 1AE, I do not qualify. However Table 46 CFR 11.327(d) clearly states: “Seafarers with one of the following national officer endorsements are eligible to apply for this endorsement upon completion of the requirements in the following table: National Second Assistant Engineer - no sea time required”.

I don’t see how this can be more cut and dry? I meet all of the other requirements as far as classes, sign-offs, etc. Does anyone have any experience with this or perhaps Mr. Cavo can shed some light?

I submitted a reconsideration request at the recommendation of the evaluator but this could take many weeks to resolve and I would like to prepare my appeal paperwork in the meantime just in case.


#2

STCW III/2 is the management level, for Chief Engineers and “Second Engineer Officer.” Second enfgineer officer is STCW for First Assistant Engineer.

See the definition of Second Engineer Officer in 46 CFR 10.107:
Second engineer officer means an engineer officer next in rank to the chief engineer officer and upon whom the responsibility for the mechanical propulsion and the operation and maintenance of the mechanical and electrical installations of the ship will fall in the event of the incapacity of the chief engineer officer.

Now compare that to the definition of First Assistant Engineer also in 46 CFR 10.107:
First assistant engineer means the engineer officer next in rank to the chief engineer and upon whom the responsibility for the mechanical propulsion and the operation and maintenance of the mechanical and electrical installations of the vessel will fall in the event of the incapacity of the chief engineer.

They are separate endorsements for the same position.

While you don’t need any more sea time to qualify for the STCW endorsement, you to have a corresponding national endorsement to qualify for an STCW endorsement. As described above the corresponding national endorsement for the STCW endorsement of Second Engineer Officer is First Assistant Engineer. I’ll update this with a cite to the regulation for this when I have the time to locate it.


#4

Thanks. That’s the regulation I was looking for. The tables are accurate, but incomplete and easy to misunderstand. It’s meant to show what you would need when upgrading but it isn’t the entire picture for a few instances where the national scheme requires more total sea time than STCW. Your situation is one of those.

Second assistant engineer is the “operational level” so a 2nd assistant engineer on a vessel of less than 4,000 HP would need an STCW endorsement for officer in charge of a navigational watch. The USCG only issues one level of OICEW, 1,000 HP or more.


STCW just imperfect or actively bad