46 CFR 11.211(c)

Offshore
#1

A former shipmate was just denied his Master’s license because of a new U.S. requirement to have 6 months of sea time on a “conventional ship” other than a MODU. It also requires 6 months of “conventional ship” sea time between 2/m and c/m. Same for 1a/e and C/E. It was part of the same Federal Register that finalized the new red book license last year. Somehow I missed that section when reviewing it, at the time. I know other countries do this, Canada included, but I don’t see it in STCW.

The consequences of this are huge. Companies will no longer be able to grow their own Chief Mates and Captains. Many operators were reluctant to pay for the Chief Mate training before. Why would they pay for Second Mates to go to school now (when they found out about this), if they have to leave to get sea time? Where will we get Chief Mates, Captains, 1a/e’s, and Chiefs from, with drilling experience?

I don’t want want to get into a debate about if this is a good idea or not. The final rule is already published. What I’m curious about is how will we manage this as an industry?

#2

The 6 months deal between 2m and ChMate isn’t new. In fact, in the proposed revision that was discussed at length on this forum severl months ago, this requirement was not included. I thought that proposed change is on hold till the result os the latest STCW pow-wow in Manila gets filtered down. But again the 2m-ChMate 6 months in a ChMates billit on a unlimited ship the requires a ChMate yada yada yada, isn’t new.

#3

Does this include DP Rigs or drillships or are they talking about moored MODUs?

#4

[QUOTE=CaptTomH;41753]Does this include DP Rigs or drillships or are they talking about moored MODUs?[/QUOTE]

That’s a good question. Was this in the old regs before the 2009 changes? I don’t have an old Part 10 with me. Maybe it only applies to moored rigs. I know for a fact though, the mate that was turned down for his Master’s license works on a DP drillship.

© Service on mobile offshore drilling units is creditable for raise of grade of officer endorsement. Evidence of one
year’s service as mate or equivalent while holding a license as third mate, or as engineering officer of the watch
or equivalent while holding an officer endorsement or license as third assistant engineer, is acceptable for a raise
of grade to second mate or second assistant engineer, respectively; however, any subsequent raises of grade of unlimited,
nonrestricted officer licenses or endorsements must include a minimum of six months of service on conventional vessels.

#5

Yes it was in the old regs , I went thru the same problem at one of the RECs in 2005 trying to get my Chief Mates license. My company help me out and sent a letter and it solved the problem but now with NMC - I dont know .

#6

In that case, this seems like an NMC error. I included an NMC letter to the IADC with each upgrade application. It says DP drillships are considered underway for the purpose of sea time. I’ll have to send it to this hand if I can find it.

#7

[QUOTE=Orniphobe;41758]In that case, this seems like an NMC error. I included an NMC letter to the IADC with each upgrade application. It says DP drillships are considered underway for the purpose of sea time. I’ll have to send it to this hand if I can find it.[/QUOTE]

The regulation is not new, prior to the MMC it was 46 CFR 10.211©. The issue is not whether DP vessels are underway, it is whether a MODU is a conventional vessel. The regulation is pretty clear that you cannot get all of the time needed for unlimited chief mate or master on a MODU.

#8

[QUOTE=Jeffrox;41752]The 6 months deal between 2m and ChMate isn’t new. In fact, in the proposed revision that was discussed at length on this forum severl months ago, this requirement was not included. I thought that proposed change is on hold till the result os the latest STCW pow-wow in Manila gets filtered down. But again the 2m-ChMate 6 months in a ChMates billit on a unlimited ship the requires a ChMate yada yada yada, isn’t new.[/QUOTE]

Is the full text of the draft of the STCW amendments from the Manila conference available online yet? I’ve only seen summaries online.

#9

[QUOTE=jdcavo;41759]The regulation is not new, prior to the MMC it was 46 CFR 10.211©. The issue is not whether DP vessels are underway, it is whether a MODU is a conventional vessel. The regulation is pretty clear that you cannot get all of the time needed for unlimited chief mate or master on a MODU.[/QUOTE]

Makes sense to me. There was a US flagged drillship that was classed as a MODU [ probably for manning purposes] and at least one unlimited master was made there even though he never had any conventional time as a second or chief mate.
If I was hiring someone with a master’s license it would be comforting to know that there was no way he could possibly be a master if all he ever did was DP from one spot to another or once every three years or so move a couple of hundred miles. Maybe they could come up with a special Drillship Master license.

#10

[QUOTE=jdcavo;41759]The regulation is not new, prior to the MMC it was 46 CFR 10.211©. The issue is not whether DP vessels are underway, it is whether a MODU is a conventional vessel. The regulation is pretty clear that you cannot get all of the time needed for unlimited chief mate or master on a MODU.[/QUOTE]

Mr. Cavo, can we revisit this? This affects a lot of people.

The letter I have is dated 02 May 2000, from Captain Boothe (NMC-4C) to the IADC. In there he cites MSM III.10.B.5 which hasn’t changed… “Service aboard self-propelled, dynamically positioned MODUs which are not anchored or otherwise bottom bearing will be credited without restriction towards all grades of unlimited deck licenses in the same manner as conventional vessels. All other MODU service will be credited in accordance with 46 CFR 10.211©.”

He goes on to write “I consider a self propelled, dynamically positioned MODU, maintaining station by means of dynamic positioning, to be “underway” even if connected to the seabed by drill pipe or marine drilling riser. Such service will be credited without restriction toward license upgrade for both deck and engineering licenses.”

#11

Has anyone got any more information on the NMC not accepting MODU time. I am planning on sending my Chief Mates time (all on DP MODUs) in a couple months for my Masters license . I sent NMC a letter asking about it and they said they would look in to it .Have they invalidated Marine Safety Manual III CH 10 B 5 ?

#12

Any more word on this? I work with plenty of guys that went up through the ranks on drillships only, weird this is coming up now.

#13

I haven’t heard of anyone else having a problem. I suspect the shipmate that I know (which prompted this thread) had an evaluator that wasn’t familier with the MSM Vol III.

#14

Just noticed on the agenda for the 24Jan IMO STCW Sub-Committee meeting is a line item "Development of unified interpretations for the term “approved seagoing service” ".

That discussion should be interesting.

#15

Good to know thanks, we’ll see what happens in Jan. then… should be good!!!

#16

This is still an issue.

I am upgrading (or attempting to) from First Assistant Engineer to Chief Engineer. I have 268 days as third and second assistant engineer while on board “freight ships” vessels. The remainder of my time is as second assistant and first assistant on board a DP3 Drillship. My 180 days as first assistant engineer is on board the drillship.

I received a letter from my evaluator requiring an additional 92 days on board a “conventional” vessel. What she is doing is combining 46CFR11.211 and 46CFR11.510.

The Marine Safety Manual, Chapter 10 only addresses Deck licenses.

"5. [U]Service On MODUs. [/U]
Service aboard self-propelled, dynamically positioned MODUs which are not anchored or otherwise bottom bearing will be credited without restriction towards all grades of unlimited deck licenses in the same manner as conventional vessels. All other MODU service will be credited in accordance with 46 CFR 10.211©. "

Chapter 12 is about Engineering licenses but MODU sea service is not addressed. The Marine Safety Manual that I am looking at is dated 1999, is there a newer on that I am not finding.

Any ideas on how to go about getting this resolved? I’m not a fan of “I know so-and-so did it, so give it to me too” but I do know a few unlimited chief engineers that recently upgraded that have only worked on semis and drillships their entire careers.

Thank you for any and all input.

Jeff

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#17

It may be beneficial if you were to scan and upload that letter. I would like a copy for future reference…

#18

Hi Guys,

Any news on this topic? I know a bunch of people who have recently gone from 2m to CM with only DP MODU time. I am in the same situation, only DP MODU time and not about to quit my job to fulfill this requirement. I was about to start CM classes but with this issue unresolved what should I do?

Thanks!

#19

[QUOTE=El Segundo;58014]…
I received a letter from my evaluator requiring an additional 92 days on board a “conventional” vessel. What she is doing is combining 46CFR11.211 and 46CFR11.510.
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46 CFR 11.211© is intended to be applied to the regulations for other unlimited tonnage and HP licenses, including 46 CFR 11.510 (chief engineer any HP). Modifying clear regulations with policy documents like the MSM, or correspondence (the CAPT Boothe letter) is of questionable legitimacy, but this notwithstanding, they are silent on engineer licenses, so 46 CFR 11.211© clearly applies.

#20

So you know, the chief mate courses aren’t required anymore.