3 A/E without OICEW Shipping Ideas

Engineering
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I’m testing for my 3rds Unlimited Motors license in a few weeks. I’m getting my license through one of the CFRs that allows you to test with a specific engineering degree and 180 days of engine room time. I’ve been sailing deep sea as a QMED with RFPEW, but am still far short of the sea time required for OICEW. So, I’ll have my 3rds but not the STCW equivalent.

Anyway, I’m trying to think of gigs where I could sail with my license as an assistant engineer but that don’t require OICEW. So far I’ve looked into Great Lakes jobs through MEBA/AMO, or possibly Washington State Ferries. Any other ideas for areas of shipping that I may qualify for?

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Nvic 17-14

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I’m a little behind you in the process, as I’m looking to get seatime to sit for the 3rd a/e test. I have ~10 years in power plants. I’ve talked to some license consultants and they said that it may be possible for the USCG to use my experience from power plants to meet some of the STCW requirements.

I have a friend that is a 2nd and sails steam on the Great Lakes with AMO. No need for STCW.

Also, check out this class. I don’t know what it satisfies: http://www.mamatrains.com/index.php/admissions-and-courses/engine-room-courses/121-officer-in-charge-of-engineering-watch-oicew-diesel-engine

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[QUOTE=ko0k;180640]Nvic 17-14[/QUOTE]

I’m not sure what you’re trying to point out with that NVIC, please explain.

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[QUOTE=johnny.dollar;180648]I have a friend that is a 2nd and sails steam on the Great Lakes with AMO. No need for STCW.[/QUOTE]

Be careful with that route because then you’re stuck with no STCW. Next time the lakes crash you can’t go work elsewhere.

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You can suck up your pride for a little while and go work on a yacht. I was on one recently that did not require an engineer at all so there were no requirements. They only wanted an actual licensed engineer because some bad things had happened as a result of not having and engineer. As long as it’s over 100 tons and 4000HP all the sea time is good. You might have to be away for awhile if you land a gig like that though…like 6 months or a year. Plus side is lots of port time and gourmet food. If your goal is getting sea time towards your STCW, I would say that wouldn’t be a bad way to go.

There’s also uninspected fishing vessels. I have never worked in that industry but I had heard they can do pretty well and get a share of the profits from the fish.

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[QUOTE=johnny.dollar;180648]
Also, check out this class. I don’t know what it satisfies: http://www.mamatrains.com/index.php/admissions-and-courses/engine-room-courses/121-officer-in-charge-of-engineering-watch-oicew-diesel-engine[/QUOTE]

From what I’ve gathered, the 1080 days of sea time requirement for OICEW is strict. There is a provision for 12 months with an approved training program, but it doesn’t seem that any of those really exist outside of maybe the AMO TECH program.

I believe that the above course just satisfies the motors course requirement for OICEW. But there’s no harm in getting an early start taking the required courses (ERM, medical first-aid, etc.) and getting the sign-offs taken care of.

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I just meant sail in the lakes to get the required time and do the STCW assessments and whatever is is required to get the STCW. The whole STCW for OICEW requiring 3 years of sea service seems absurd because the candidate presumably already has the 3rd A/E license. I don’t understand the point of the massive sea time requirements when there is already competency and training requirements built in to it.

And the training requirements are pretty steep too—unless one has gone to an academy. These requirements don’t make people competent. If anything, the folks with common sense and real experience toss in the towel and give up!

[QUOTE=TxsCaptain;180654]From what I’ve gathered, the 1080 days of sea time requirement for OICEW is strict. There is a provision for 12 months with an approved training program, but it doesn’t seem that any of those really exist outside of maybe the AMO TECH program.

I believe that the above course just satisfies the motors course requirement for OICEW. But there’s no harm in getting an early start taking the required courses (ERM, medical first-aid, etc.) and getting the sign-offs taken care of.[/QUOTE]

Has anybody given a definition of an “approved training program”?

Successful completion of an approve
d training program that includes a
combination of workshop skills training
and seagoing service of not less than
12 months, and that meets the requireme
nts of Section A-III/1 of the STCW
Code;

The link I posted above is for a school that is approved for “Schools teaching OICEW-Diesel Engine” on the USCG site https://www.uscg.mil/nmc/courses/default.asp?tab=1 I believe you are correct in that it just satisfies the engine training class (46 CFR 11.329(a)(4)(ix) (4) Provide evidence of having satisfactorily completed approved training in the following subject areas: (ix) Motor plants, as applicable.)

Mass Maritime has a good summary of Table A-III/2 http://weh.maritime.edu/stcw13/tables/31.html

Page 37(bottom right on pages) summarizes the requirements as well. http://www.mptusa.com/pdf/STCW_guide_english.pdf

Basically, it really is nearly impossible for a non-cadet to get the STCW OICEW in a realistic amount of time/money. Good job, bureaucrats.

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I think I need to read the whole law. Look at 46 CFR 11.329 (e).

(e) 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: Table 1 to § 11.329 (e)

If I read this logically, it says “Entry path from national endorsements: Second assistant engineer any horsepower. Sea service: NONE* * This column provides the minimum additional service required of the seafarer in order to meet the requirements of this section.”

So there ya have it. Maybe a lawyer or somebody smarter than me can confirm. But if you have 3rd A/E national, you just need to satisfy the competency and training requirements.

See the table here:46 CFR § 11.329 - Requirements to qualify for an STCW endorsement as Officer in Charge of an Engineering Watch (OICEW) in a manned engineroom or designated duty engineer in a periodically unmanned engineroom on vessels powered by main propulsion machinery of 750 kW/1,000 HP propulsion power or more (operational level). | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute

It also is on the checklist

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[QUOTE=johnny.dollar;180657]So there ya have it. Maybe a lawyer or somebody smarter than me can confirm. But if you have 3rd A/E national, you just need to satisfy the competency and training requirements.[/QUOTE]

The graph is a good illustration but in this case I don’t think it is legally binding. The rule calls for 1080 days of sea time, just like 3rd assistant normally requires. That’s why the graph says no additional sea time. You might get lucky but I don’t think you’ll get out of the requirement for 1080 days.

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Just for reference, the direct website for the cfr’s is ecfr.gov

Congratulations on finding that table…now print it out and keep a hard copy somewhere safe encase they change it. I have had issues with the CG changing requirements before so I presented them with the original requirements from when I first embarked on what I was trying to do and they honored the original requirements even though they had changed. I could not find the old ones anywhere online, so the Only reason I was able to do it was because I had printed the page.

Secondly, before you get too excited, in the last column in that graph it says, [I]training required by the section ***[/I]. And then “yes”.

Then under that it says:

*** Complete any items in paragraph (a)(4) of this section not previously satisfied.

Paragraph (a)(4) lists a bunch of [I]approved[/I] training courses you have to take. Most of them are pretty standard, however…there are no coast guard approved courses called “Control systems” or “Electrical machinery and basic electronics” that I am aware of. You have to check the approved course list on the CG website for each course. You can try contacting them to find out if any course approvals are pending or seeing if they would let you take courses that are not CG approved, I doubt they would but it doesn’t hurt to try. Whatever ends up happening, make sure you get it in writing.

The last thing I wanted to say is that, well I don’t know you and you are probably a great person an all, but I have to admit that as a marine engineer, I feel a little offended that you think you are already more than capable of doing my job. Us marine engineers, we deal with it all the time, from small boat captains to AB’s, cadets and even diesel mechanics who have no experience with the rest of the shipboard systems. As a power plant engineer I am sure you are more than capable and competent at running and operating machinery…but things are a little different on ships. There are different safety risks. Someone who is overly confident in their knowledge and abilities to the specific application might inadvertently cause someone to get hurt. Let me give you an example:

If divers are in the water to clean the scale off the props, do you know what steps have to be followed before they are cleared to go down there? Ideally the C/E would ensure everything has been tagged out but he or she might be tired, may not have slept in 20 hours due to a long fueling, troubleshooting a critical problem, maneuvering or a biz zillion other reasons. Well it seems simple enough, you have to tag out the propellers, but you also should tag out the CAPAC. If the chief doesn’t think of it, the other engineer’s will, because they have the knowledge, experience and STCW endorsement to prove it, and maybe they have slept so they will do it without him mentioning it because they know it’s something they are supposed to do. Someone who has never heard of a CAPAC wouldn’t think of it, ideally engineers work as a team and if there is a person lacking in some way on the general day to day terminology and knowledge it can lead to an event if no one else catches it. If one person misses something, another engineer should be able to pick it up, and that way things work copacetically.

Do you know what a CAPAC is?

You may have worked at a hydroelectric plant, and already know all about them and in that case I put my foot in my mouth. Actually, I’m not even sure they use them there since those are mostly fresh water but anyway, the point is, things are different on ships, it is not [I]just[/I] a power plant. Ships have some different types of equipment and procedures than you would typically find on land, and that was just ONE example. That is why the coast guard and the IMO have the regulations in place, because they have already figured that out.

I do think the that the three year sea time requirement is a bit steep, but it isn’t a good idea for anyone to walk into this thinking they know it all already. It can cause a potential for major accidents.

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Are “Day 3rds” a thing of the past? And another stupid question since I have been ashore for a bit and working primarily in the energy industry. . . is an OICEW required for ships with unmanned engine rooms as is quite the norm these days? Or is having the overnight duty considered a watch. . .

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[QUOTE=cmakin;180668]Are “Day 3rds” a thing of the past? And another stupid question since I have been ashore for a bit and working primarily in the energy industry. . . is an OICEW required for ships with unmanned engine rooms as is quite the norm these days? Or is having the overnight duty considered a watch. . .[/QUOTE]

Yes there are ships that still have Day 3rds. But if they stand a watch such as supper relief they would have to have OICEW. If someone got sick they would be expected to fill in.

On ships with unattended engine rooms the Duty rotates almost the engineers. That Duty covers the daywatch as well as the unattended hours, so yes I believe OICEW would be required.

If there were multiple engineers on watch the junior engineer would probably not be required to have OICEW.

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[QUOTE=johnny.dollar;180648] I have ~10 years in power plants. I’ve talked to some license consultants and they said that it may be possible for the USCG to use my experience from power plants to meet some of the STCW requirements. [/QUOTE]

For STCW, that’s extremely unlikely.

[QUOTE=johnny.dollar;180648]…Also, check out this class. I don’t know what it satisfies: [/QUOTE]

If the school is accurately stating the approval the course was given, it’s approved to meet the motor plant course requirement for OICEW that takes effect after December 31, 2016.

[QUOTE=TxsCaptain;180654]From what I’ve gathered, the 1080 days of sea time requirement for OICEW is strict. There is a provision for 12 months with an approved training program, but it doesn’t seem that any of those really exist outside of maybe the AMO TECH program. [/QUOTE]

It is very strict. The only options are an approved program (the academies or AMO) or three years of sea time.

[QUOTE=johnny.dollar;180648] Mass Maritime has a good summary of Table A-III/2 http://weh.maritime.edu/stcw13/tables/31.html[/QUOTE]
That summary is specific to Mass. Maritime’s program. For the hawse-piper, there is a better and more useful “summary” here.

[QUOTE=johnny.dollar;180657]I think I need to read the whole law. Look at 46 CFR 11.329 (e).
If I read this logically, it says “Entry path from national endorsements: Second assistant engineer any horsepower. Sea service: NONE* * This column provides the minimum additional service required of the seafarer in order to meet the requirements of this section.”
[/QUOTE]

You are picking and choosing only the parts that support the result you want. The reason it says no sea service is required when seeking OICEW from 2nd AE is that holding 2nd AE is sufficient evidence of having acquired the sea service needed for OICEW. But you ignored the other two columns of that same table, “competence” and “training” Both are marked as “Yes” so you still need to complete all the courses and do all of the competency assessments, this table does not mean if you have 2nd AE you are automatically qualified to be issued OICEW.

Also, if there was a conflict between that table and the rest of the regulation that precedes it (there isn’t), general rules of legal and regulatory interpretation would apply and a summary cannot prevail over the specific provisions it summarizes.

[QUOTE=johnny.dollar;180657]…So there ya have it. Maybe a lawyer or somebody smarter than me can confirm[/QUOTE]
Guilty on both counts.

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[QUOTE=cmakin;180668]Are “Day 3rds” a thing of the past? And another stupid question since I have been ashore for a bit and working primarily in the energy industry. . . is an OICEW required for ships with unmanned engine rooms as is quite the norm these days? Or is having the overnight duty considered a watch. . .[/QUOTE]

The full STCW title of the endorsement is [I]Officer in Charge of an Engineering Watch (OICEW) in a manned engineroom or designated [U]duty engineer in a periodically unmanned engineroom[/U] on vessels powered by main propulsion machinery of 750 kW/1,000 HP propulsion power or more[/I] [Emphasis added].

That alone probably answers your question. If you are designated to be the engineer on call on a vessel subject to STCW with an unmanned engine room, you probably need OICEW.

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[QUOTE=cajaya;180659]Then under that it says:

*** Complete any items in paragraph (a)(4) of this section not previously satisfied.

Paragraph (a)(4) lists a bunch of [I]approved[/I] training courses you have to take. Most of them are pretty standard, however…there are no coast guard approved courses called “Control systems” or “Electrical machinery and basic electronics” that I am aware of…

The last thing I wanted to say is that, well I don’t know you and you are probably a great person an all, but I have to admit that as a marine engineer, I feel a little offended that you think you are already more than capable of doing my job. Us marine engineers, we deal with it all the time, from small boat captains to AB’s, cadets and even diesel mechanics who have no experience with the rest of the shipboard systems. As a power plant engineer I am sure you are more than capable and competent at running and operating machinery…but things are a little different on ships…[/QUOTE]

I think the list comes from the international standards. If there are no specific classes, then how would ANYBODY get the endorsement, especially a hawsepiper? The whole purpose of this discussion is to try to form a strategy for navigating the bureaucracy.

Regarding you being offended, well please quote where I said I am capable of doing your job?

To get a 3rd A/E, I need at least 180days at sea. Then there is the STCW requirements. To move up from 3rd, I would require all the same requirements as everybody else.

Let’s put this in perspective. Somebody like me, has 10 years of experience operating, maintaining, repairing, teaching others, etc etc in steam, gas turbine, and diesel (yes, 40MW slow speed Man B&W) plus 4+ years of rigorous study for a mechanical or electrical engineering degree. AFTER 180 days at sea, we can sit for the 3rd assistant. I don’t believe I can do your job. I don’t know all the systems on a ship, don’t know the lay of the land, the expectations and job duties of the various positions, and the ship specific equipment. But I do know machines, pumps, control systems, boilers, etc. And besides staying at a Holiday Inn Express a few times, I also grew up on the water with small boats.

Please don’t tell me that working experience is not useful on a ship for the TRANSITION (I’ve said transition many times, in my posts). How about I say, “I feel my knowledge and experience will let me be in a great position as I LEARN marine engineering operations.”

Compare this to a academy grad, who has their 3rd and STCW and has been trained up and down, but has a max of 1 year experience, and very little real life experience. Also, I’ve been beaten down already, know my roll, and know how to be humble!

Let’s just be fair…does somebody with directly RELEVANT experience and engineering training that is very similar to an academy grad really fall into the pathway as coming up the hawsepipe? If you believe the experience is garbage and the mechanical engineering degree is of zero value, then it’s completely fair to say do the time…but if you value any of the experience and training, it’s hypocritical blow people off that are just trying to transition into the industry. People, that you’d probably enjoy working with because they really want to do this job, and know what it entails.

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[QUOTE=jdcavo;180690]
You are picking and choosing only the parts that support the result you want. The reason it says no sea service is required when seeking OICEW from 2nd AE is that holding 2nd AE is sufficient evidence of having acquired the sea service needed for OICEW. But you ignored the other two columns of that same table, “competence” and “training” Both are marked as “Yes” so you still need to complete all the courses and do all of the competency assessments, this table does not mean if you have 2nd AE you are automatically qualified to be issued OICEW.[/QUOTE]

I was not picking and choosing. I merely was stating that the table (which is introduced in line (e)) states no sea service is required for those holding a 3rd A/E (per the 1st column, Sea Service.

I did not discuss the 2nd or third column, which must be satisfied (A-III/1) and training required (this is (a)(4) of the section). This has to be completed by everybody.

I found a sample sign-off book for satisfying the competence. Correct me if I’m wrong, but for a short while longer, these can be signed off by a superior that has STCW endorsement.

Regarding the training, I don’t see how anybody can get the STCW outside of cadets if these courses do not exists or prior experience is not eligable. The Gap closing training by AMO isn’t sufficient to GET the STCW, from what I can tell. But, AMO does appear to have a pretty nice 3rd A/E with STCW 2.5 year program for highschool grads that is tuition free…why go to an academy?

Lastly, my guess would be starting 2017, schools and the industry well figure out the STCW training for obtaining OICEW. Right now there is no pathway for those that don’t attend academy and the market hopefully will solve this.

Is there another path to gain it via reciprocity from another country?

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[QUOTE=johnny.dollar;180695]I was not picking and choosing. I merely was stating that the table (which is introduced in line (e)) states no sea service is required for those holding a 3rd A/E (per the 1st column, Sea Service.[/QUOTE]

That’s picking and choosing. That take doesn’t override the regulation requiring 1,080 days of sea time. It is based on the fact that the 3rd AE requires 1080 days of sea time to acquire in normal circumstances

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[QUOTE=johnny.dollar;180695]I was not picking and choosing. I merely was stating that the table (which is introduced in line (e)) states no sea service is required for those holding a 3rd A/E (per the 1st column, Sea Service.[/QUOTE]

For 3rd AE, it’s a plausible argument. The table was based on 3rd AE requiring 3 years of sea service or a program, and may not have considered the alternative you are using for the national endorsement (license). The issue of legal interpretation and summary v. specific text may hold, but it’s a plausible argument.

[QUOTE=johnny.dollar;180695]…I found a sample sign-off book for satisfying the competence. Correct me if I’m wrong, but for a short while longer, these can be signed off by a superior that has STCW endorsement. .[/QUOTE]

I would be cautious with privately prepared booklets, the one in NVIC 17-14 is OK to use. A privately prepared version identical in substantive content would also be OK. Until December 31, 2016, assessors do not have to be approved, see the response I gave on this earlier today, here.

[QUOTE=johnny.dollar;180695]…,.But, AMO does appear to have a pretty nice 3rd A/E with STCW 2.5 year program for highschool grads that is tuition free…why go to an academy?[/QUOTE]

A B.E. degree may have some appeal. Many academy graduates do not make a career of going to sea.

[QUOTE=johnny.dollar;180695]…Is there another path to gain it via reciprocity from another country?[/QUOTE]

Not really. In STCW terms, that is known as an “endorsement” of a certificate issued by another country, and the country recognizing the credentials of another country would provide a certificate of recognition of the original country’s certification. This is not to allow mariners to seek a way around their own country’s requirements, it is primarily to meet the requirement that mariners employed on a vessel must have documents issued by the country where the vessel is registered. In any event, the United States does not currently “endorse” STCW documents issued by other countries.

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[QUOTE=jdcavo;180700]For 3rd AE, it’s a plausible argument. The table was based on 3rd AE requiring 3 years of sea service or a program, and may not have considered the alternative you are using for the national endorsement (license). The issue of legal interpretation and summary v. specific text may hold, but it’s a plausible argument.[/QUOTE]

It’s not an alternative path to a national license. It’s in code. Just like going to an academy as a pathway is in the code (with stipulations).

Therefore, how one obtains their 3rd A/E is of no consequence to obtaining the STCW, would seem like a logical conclusion. But, I’m not a lawyer, and (more importantly), I’m not the enforcer!

However, I still don’t understand what you refer to as summary text. Line (e) specifically states “(e) 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:” The table–Table 1 to § 11.329 (e)–specifically states the requirements…requirements that are not listed elsewhere in the section.

PS: I’m not trying to argue, just understand. Also, I spoke with an AMO staff member that explained some of the STCW stuff to me today. Nearly all the rules come from international standards, and the USCG is implementing them which is causing the confusion.