People seem to forget that the A in AE means “assistant” and that means under the supervision of a superior.
Thank you for clarifying. I did not mean to imply one can serve as a Chief Eng-Limited with a 2nd A/E…one would actually have to hold the ChEng-lim.
Does that table mean a 2nd A/E can apply for Chief Engineer limited?
DDE with a HP restriction are limited to Near Coastal, DDE Unlimited is Oceans. Assistant Engineer Limited and Chief Engineer Limited are Oceans.
Why do you consider HP limitations so confusing that they’re “different licenses”?
I recall a trip on a 3000 hp fishing vessel:
We had to reject a good Academy grad 1AE for a job (who had previously sailed with me as an unlicensed Chief on a 4000hp tug).
The owners flew in an unknown DDE 4000 from a scumbag Mariner pays the fee recruiter in Louisiana for a pierhead jump. It turned out that he had DDE 4000 near coastal. The owners said: we’ve got to sail today. Don’t worry about it. If we get caught we’ll just pay the fine.
If I had $100 for every time I’ve heard owners say: “it’s not USCG required”, or “don’t worry, we’ll pay the fine,” I could afford to retire in style.
Anyone can apply for anything. The table is a vestige from the pre-2013 regulations, it was published in 1999. At that time there was an endorsement for Chief Engineer-Limited Near Coastal that required 4 years of total service, so someone with enough time for 2nd AE would have those 4 years. In the 2013 rulemaking, Chief Engineer Limited and CE Limited Oceans were combined and it takes the 5 years total service that used to be required for CE-Limited Oceans. So today, someone with the minimum needed for 2nd AE would not have enough time for CE-Limited. The table is still correct that if someone applies for and is approved for 2nd AE and CE-Limited at the same time, there is no exam other than the one for 2nd AE.
What about an academy graduate? They got a 3AE with next to zero sea time, are they credited the equivalent of what it takes to get 3AE for the purposes of upgrading to Chief Limited?
Academy Graduates who are qualified for 3rdA/E per 46 CFR 11.516(a)(3)must submit:720 days as engineer officer while holding engineer officer endorsement180 days as QMED or equivalent (any licensed service may also meet this)…
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The MSM allows Academy graduates to receive 1080 total credit with 720 days as QMED once 1 year as licensed engineer is submitted, the above is the delta
No licensing system is perfect. It’s common for people to be licensed far beyond what their actual ability might be. Unless we train mariners the way the State Pilots do, that will not change. Get over it.
I do not see how the industry, particularly small vessel owners and limited license holders, or society, benefits from excessive licensing complexity which very few people (including USCG boarding officers) understand.
USCG licensing has become like the tax code: clear as mud; and written with the assistance of lobbyists to be intentionally full of loopholes that benefit the special interests (oil patch, tugboats, etc.).
This mess ought to be simplified.
Why not follow something closer to the FAA model? It takes more time/money/class/“training” to get an unlimited 3rd license than an ATP license and type rating to fly captain of a 747. But, the FAA has actual practical flying examinations at various steps along the way.
This is what I found in 46 CFR 10.107, seems pretty specific to OP’s question but maybe there’s more to it than just this. Copied directly from
Officer in charge of an engineering watch in a manned engine room or designated duty engineer in a periodically unmanned engine room (OICEW) means an engineering officer qualified at the operational level.
Operational level means the level of responsibility associated with—
(1) Serving as officer in charge of a navigational or engineering watch, or as designated duty engineer for periodically unmanned machinery spaces, or as radio operator onboard a seagoing ship; and
(2) Maintaining direct control over the performance of all functions within the designated area of responsibility in accordance with proper procedures and under the direction of an individual serving in the management level for that area of responsibility.
Sounds like as long as you have the OICEW endorsement you can serve as DDE in a periodically unmanned engineroom.
That’s not what it means. That;s the STCW definition for operational level. It does not refer to the duties of the only engineer on a vessel, e.g. the “chief.”
Go to the same regulation and look at the definition of “Chief Engineer.” The definition describes the duties, i,e, you are “designated” to be on call (or “duty”) in an unmanned engine room, i.e. you are the engineer on watch during the period you are designated as the duty engineer. There is a difference between the pre-STCW title of the endorsement, and the language used in STCW based on that strange dialect they have acquired on the other side of the Atlantic.
But, feel free to stick with and argue your sea lawyer interpretation with foreign port state control that asks who are the other engineers, perhaps you can make argument that the engine department is an autonomous collective and there is no chief.
Like I began with, that’s just verbatim what the regulation says, and there’s probably more to it. Part 2 of the operational level definition, if you read that far, states that as a DDE at the operational level you’re still under the direction of a management level engineer. So maybe this means for the few harbor tugs that have a DDE that would be under the supervision of a Port Engineer, or a vessel that has multiple DDE’s. I’m sure there’s some other vaguely worded part of the CFR’s that contradicts this section.
Port Engineers are not members of the crew and therefore not the boat’s Chief Engineer.
No, as far as the USCG or any other regulatory agency I know of Port Engineers have the same supervision and responsibility on a vessel underway as the CEO’s comfort dog, wombat or whatever.
That’s correct, BUT if you’re the only DDE onboard you are, by definition, the Chief and must have the corresponding STCW endorsement as such.
That may be technically the case but a lot of times decisions on the boat aren’t made without the port engineers say so. They do have a kind of de facto supervisory role, just my experience.
Before the sea time requirements changed, engineers with 3ae could get a DDE and 2aes could get a CHENG limited, my father got his that way. Now there is no such equivalency. I had a 3ae and had to retest for DDE unlimited and Chief OSV (useless I know). I work on a SOLAS class 10,000hp ATB on the west coast, required to have OICEW, as is the Chief, nothing extra STCW wise, however he does need a chief limited (domestically).
I was told by the USCG the a DDE is “considered management level” and therefore I was required to test again. However the DDE test was verbatim my 3AE test sooooooooooo………in a nutshell its dumb.
If the tug is over 200 GRT (or if it ever goes foreign) that is incorrect. The fact that he needs Chief Limited means the tug is over 500 GRT so he needs STCW III/2 “Chief Engineer” even to run coastwise.
Sounds like the Crowley ATBs. They’re less than 300GT, uninspected and SOLAS. That can have the vettors scratching their heads. I think the Chief LTD was a company requirement.
Seagoing vessels greater than 200 GRT require STCW at all times. The 550 class are 232 GRT so STCW is required and the Chief Engineer is required to have III/2.