You are incorrect. I certainly hope it is not your lawyer telling you this. If so you need a new one! Congress does not pass CFR’s. The pass the USC. Regulatory agencies promulgate CFR’s after giving public notice and usually holding public hearings. Congress simply does not adopt CFR’s.
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<div class=“CommentHeader]I was going to write a response to you Scarab, but I’ll just cut and paste instead; read it like you really want the answer, not just an opinion that matches yours 
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[li]<span><font color=”#aaaaaa” size=“1]CommentAuthor</font></span>[<strong><font color=”#3354aa" size=“3]anchorman</font></strong>](http://gcaptain.com/maritime/forum/account.php?u=29)<font color=”#aaaaaa" size=“2] </font>
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Scarab,
The reason that there is a Chief Mate, or a 3rd, or a 2nd, for that matter is because its an eventual step to become Master. The intention is to work in each capacity to serve in the next. There are ways to get 2 for 1 days while holding a certain license for up to 6 months of the required time, but you will never bypass all of the required seatime to upgrade. To work in ANY capacity, you must be on a vessel that requires that capacity (3rd & 2nd can be excepted as OICNW). I KNOW exactly what a Chief Mate is, and by definition, any licensed person, from 25 ton and up, can meet that definition, but are they required to? The answer in no. You must have the <strong>requirement</strong> to meet the definition by NMC, and this is where most people trip up. For those that get tripped up in the text, the USCG found it beneficial to draw a picture in the CFR of the career paths to “ease” ambiguity. This has been reiterated by the highest brass and Jim. It is what it is, but NMC will always look at an application on a case by case basis to determine <strong>IF</strong> the definition has been met minus a requirement. This would involve a letter from the company and still doesn’t promise anything.
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I stand corrected about who writes the CFR’s. You are correct. The Code of Federal Regulation is a codification of the general and permanent rules published in the Federal Register by the Executive departments. And no that was not my attorney.
If you are on a vessel which requires one master and one mate. What do you call the mates position. The CFR’s calls that position Chief Mate. It is a required position. The COI may not call it Chief mate but that is what it is. You are gaining training in the Chief mates position. As you stated, that is the intention.
I guess for all of us who have been sailing as masters for years apparently have been doing incorrectly. We must start over as 3rd mates learn it all over!
Here’s an experience I had, with reference to the difference between a Mate and a Chief Mate. Some years back I worked on a small container ship, just under 3000 tons. The COI stipulated 1 Master, 1 Chief Mate, and 1 Mate. The Coast Guard interpreted it to mean only 3 licenses could fill the C/M position. An unlimited Master, unlimited C/M, or a 3000 ton Master. A 3000 ton Mate could not fill the C/M slot. When I left, they were in the process of trying to change the COI to read 2 Mates. At the time I held a 3/M and 3000 Master. When I upgraded to 2/M, I got a call from the REC wanting to know how I sailed as C/M with a 3/M license. I said it was under the authority of my 3000 ton Master, and they accepted that. The tonnage was over 1600, and that’s all that seemed to matter.
Mike173,
I still do not see it as the same animal; it’s the apples and oranges thing. The fact that they “accepted that” means nada, your time was good cuz you sailed on a 3rd Mates license to get the time for upgrade to 2nd Mate. The C/M title is a side issue, unrelated, IMHO. I mean, are we going to get this discussion to the point of saying that if there a 2 guys in a rowboat, one is the master and the other is the chief mate! Cheers!
Yes, that’s a fair point. Fact is, I really didn’t have a point, just one experience. I see where your leaning, and I think I agree. Unless it was a crew-row-boat. Then, wouldn’t they both be Captains!
On the bright side, at least there’s a uniform.
I am a bit confused. Scarab - are saying that one should be able to go from a limited/OSV Mate (weather you call it Chief or Not) to Unlimited Master? The next step up from ANY limited licence is 3rd Mate. That is what I did after over ten years as a limited Master, I can surely say that it should be that way - for anyone. There is a world of difference between limited/unlimited - I am not saying better - just different.
everyone in Fourchon knows that on OSV’s there is no chief mate or any mates for that matter
there’s first captain…second captain…third captain…and on and on forever
that is the difference between a workboat and a ship
c.captain,
On occasion I catch rides on GOM OSV’s and it is confusing when you go to the bridge to check in with the captain, difficult to do when everyone that stands a bridge watch calls themselves captain. On more than one occasion I’ve even had to ask one of the self described captains for THE captain of the vessel. Are all the engineers “chief”?
Damn…they always call me asshole, but when you think about it, there is no asshole license just like there is no captain license, so I guess we’re all even!
On the OSV’s, the man in charge is called the “Master”…as per the license text and title. You can call yourself what you want, but I have, out of respect called some “captain” because of recent or future commands, my wife excluded…that be the admiral.
Anchorman is most often referred to as the “COMMANDER”!!
[QUOTE=todd.harter;5808]Why can’t OSV officer’s just jump through the necessary hoops to get an unlimited licence (a real one) as I have done? No - its not easy, but it is possible. Why does everyone seem to think that the only people with unlimited licenses are academy guys from big ships who have never had to handle a vessel or deal with the oilfield? Despite the efforts of some - as far as I know the hawsepipe has not been welded shut…yet![/QUOTE]
I have held a number of Masters Licenses, in the following order,
Master of Steam or Motor Vessel of Any Gross Tons upon Bays Sounds and Lakes other than the Great Lakes, (which became Inland);
Master 1600 GT Oceans;
Master Great Lakes AGT;
Master Oceans AGT;
Master Towing, Oceans and Inland.
I never had a 2nd Mates License nor a 1st Mates License but have extensive 1st Class Pilotage AGT.
I was surprised recently when my engineer left to work on an OSV in the Gulf and his new boat was over 1600 GT. I was mate and then captain on an inland tanker that was 276’ loa and 1729 GTand carried 30,000 bbls. It required not only an unlimited tonnage license but also 1st class pilotage AGT for everywhere it sailed. We ran in and out of all the little harbors in the North East like Nantucket and Stamford where big tankers and ATB’s couldn’t go. I’m guessing that even on OSVs much larger than that, pilotage is not required. What is the rational for that?
We weren’t going international, unless you consider Nantucket a foreign country, and some of the locals do, and we weren’t going 200 miles offshore, ever. So why are OSVs special?
[QUOTE=Capt_Anonymous;5860]I think what Anchorman is referring to is that fact that in order to move from C/M to Master, you have to have time on a vessel working under manning that calls specifically for a CM. Since Large OSVs don’t, one can progress to CM and no further.[/QUOTE]
I don’t know about OSVs specifically but it is not true in general. You can go from Mate inland to Master inland to Master Great Lakes to Master NC / Oceans without ever sailing as a Chief Mate or even holding the license. I know because I did it that way. I started out on a little coastal tanker as an AB with a 3rd Mates license , got my pilotage, got promoted to Mate, put in my time, got Master Inland AGT and got promoted to Captain when somebody FINALLY retired. I’ve sailed Harbor tugs, done ocean towing and sailed as Chief Mate on a 300,000 ton VLCC (after I got Master Unlimited)
There is more than one way to get to the top and don’t assume that the guy driving the 100’ tug doesn’t have a big license or that the school boy can’t drive. The guy on the bridge wing of the 1,100 footer lightering 50 miles off Galveston’s last job may have been docking containerships in New York.
I just think that everyone should play by the same rules. It is wrong for a 600’ ATB to be captained by a guy with a 200 ton license and require a “ship” half that size to have an unlimited License and 1st class pilot on top of that!
You don’t see ATBs in Europe because they don’t have a loophole you can drive a ship through that gives it and unfair economic advantage.
Too bad you did that, you could have gone as capt. on a traditional tug that was over 200 tons to get the rest. You would have gotten 1.5 days / 1 (12hour days). The othe half just has to be on vessels over 200 GT
How about when you work as Master 1600 tons? Shouldn;t that count as chief mate time? I can not find anything in the CFRs at all about that situation. I have been working for the last year or so after I got my chief mate unlimited license as master 1600 tons on an uninspected fishing vessel. It does not have any COI. We had master, chief mate, 2nd mate, 3rd mate, chief engineer, 1st engineer, etc (all foreign licenses) but none of that required since no COI. Does anyone know anything about this kind of situation. The vessel is 1091 GT working foreign. I would appreciate any leads on where to look for more info specific to this situation. I would like to apply for my master unlimited license and have plenty of time as OICNW and also a couple of months as chief mate on vessels over 1600 tons but need more time as chief mate on larger vessels according to the USCG. I think the rules allow me to apply now since they say only that the time needs to be over 200 GT which it all is.
No matter how you try to twist it, a 9000 ton OSV is a ship. Period. In no way am I knocking OSV guys, and I know they perform a specialized job. But so do Chemical Tanker Officers. But at 9000 tons, they require an unlimited license. No loopholes. No BS license exemptions. To run a 9000 ton OSV, or a 6000 ton OSV for that matter, officers should have to jump through the hoops, and invest a bit more in their future, and guarantee a higher level of professionalism. It takes a lot more than boathandling to make a good Captain. It would also justify the possibility of better wages, etc. The other option would be to stay on smaller vessels if they didn’t have the desire or ability to reach the unlimited level. The 100 ton master on a 150 foot boat has no bearing here. Boat handling and experience aside, this discussion is about whether or not to allow improperly trained and certificated officers to run ships. Read the thread on the TOAR. The concept is the same. The mission of the ship is irrelevant.
I like that statement. It takes more than boat handling to make a GOOD Captain. So if you are unlimited you are better. You have more schooling but I don’t think it makes anyone better. I grew up on boats. I started when I was 15 and now I’m 52 from what I have learn in all those years no one can take that away boat handling is a small part of being a good Captain and I can do this with my eyes closed. But you have everything else to content with also we have 45 plus people on board from several companies. so you have crews relations, bridge team, drills, training, customer relations, maintenance, budgets, route planning, stability,BWM, enviromental, and the list goes on this is every day things we do. but like he said old salts no wanting to spend 30,000 dollars on classes for just a couple more renewals is why I never did it, but don’t sit there and say a better captain that is BS. anyone can study materal and pass a test but that still don’t mean you are a good captain.
I must be getting old… If it can be picked up in a davit, then it’s a boat…
After my Navy time, and having shown the proper qualifications as Officer fo the Deck (Underway) for a Spruance class Destroyer, I was cleared to sit for a 1600 ton ticket. When I asked why it wasn’t an unlimited due to the tonnage, I was told emphatically that “Military vessels didn’t qualify as ships”.
Interesting… By the way, my evaluation was done by an active duty Coastie, not a civilian.