There is a HUGE difference between ‘having a license’ and being competent. I don’t mean to bash the school system, but there is a HUGE disconnect between what is being taught and what is needed to stand your [U]own[/U] watch on a towing vessel.
Most of the teachers sailed on ships that are smaller deadweight tonnage wise than some of the ATB, and tug barge combinations out there today. In virtually every case, when the ships hit the pilot station, the Pilot does the actual harbor entry, and then a docking pilot actually docks the ship. If the ship does the docking themselves, the Third, second and chief mate don’t actually do the ship handling, but the Master does it. Having sailed on ships I know the truth! The third goes out on deck, the second keeps the bell book, and the chief is usually doing cargo paperwork, to speed up the port turn around time. Yet the industry is told that ‘Unlimited’ licenses are worth more both experience wise and proving competence than the ‘Limited’ tonnage licenses with regards to operating the towing vessels. You can learn theory of Electronics, ships business, navigation, Rules, and spend hours (days) on a simulator. But NOTHING is a substitute for actually seeing/feeling/handling tugs and barges underway, alongside, astern in all the different possible combination’s. Not just talking about it and drawing it on a dry erase board, but seeing it happen, and seeing what happens when it goes awry. They all handle differently, and the changes in draft and apparent wind change everything.
Now we have this 30 day check off and TOAR system. This was tailor made expressly for, and to benefit maritime graduates. No other category of new mariner meets the criteria to be able to qualify for this 30 day rule. The only other mariners who can benefit from the 30 day rule are individuals who already have a 500 ton (or larger) license, which shows they already have over 5 years sea time actually doing, learning and earning.
You must be aware that the job of third mate is a ‘sea mate’ position. When you get to the sea buoy the master comes up, and babysits the pilot. On a tug, there is just a master and a mate. Working 6 on and 6 off the master can’t cover the mates watch if the mate is inexperienced. The mate must be self sufficient and be able to stand their own watch. There are some tug companies who do have a three watch system. But those ‘second mates’ are not doing any more than following the autopilot, and ensuring the vessel doesn’t stray off course.
Now to answer your question. As I understand it (as a DE) your TOAR only counts when you do the evolutions and have a license over 200 tons. You don’t have a license yet! So what you are trying to do is to have the TOAR ‘pre done’ so when you graduate and get your license you’re ready to go. I think that is not the intended spirit of the regulation.
If you find someone (a DE) who will sign you off like this, then I would suspect their professional judgment!