REPLY That really sucks. These licensing seatime rules need to be changed so that the tonnage for the licensing breakpoints is not the same as the breakpoints for inspection and manning requirements. That rule needs to be changed from 200 tons to 190 tons. That would solve most of the problems. There is no functional difference between a 190 ton vessel and a 201 ton vessel. Experience (especially as an officer) on a 199 ton tug handling 5000 ton barges is far superior to experience on a 201 ton yacht mixing drinks and polishing brass.
About the only bright spot is that the USCG will give credit for the I.T.C. tonnage if a vessel has it (I don't recall which policy letter contains that provision) ---- 199 GRT (domestic tonnage) tug is usually about 499 GT (I.T.C.) If the proposed new licensing rules are ever adopted, the USCG will then give credit for the combined tonnage of the tug and barge on ATBs.
We often hear about how US license requirements are substandard, and that the US had to adopt STCW to come up to international standards, but I have been learning that while some of the well respected foreign licenses may require more classes and have more difficult exams, the seatime requirements are less stringent than ours. The British MCA only requires that seatime "should be on vessels over 25 meters." The Brits also give seatime for everyday signed on to a vessel, not just days underway. Australia only requires that two-thirds of the days be underway.The Canadian license system is about the same as the Brits, but they accept seatime on vessels over 25 tons toward an unlimited license. I hear that there are training programs in the Philippines where a man can get an AB card, including STCW with only 40 (yes 40, NOT 400) days of seatime. And people think the US license system is substandard?