My sea service letters specify the days I’ve spent underway vs. alongside. I’m trying to find the relevant CFR’s for credit for sea days while alongside in the deck department. I’ve been told there is a 3:1 ratio, I’ve also been told there is no credit for time alongside for deck. Most of my time alongside was spent standing in port bridge watch and general deck maintenance. Any help appreciated.
1 Like
Thanks for the link. I’ve reviewed this CFR and am still confused.
Sea service on vessels that do not get underway. This requirement applies to service obtained on vessels mandated by the Certificate of Inspection (COI) which are in operation but do not get underway or occasionally get underway for short voyages.
How do you interpret this? Does it apply to all vessels? My vessel regularly gets underway but we spent alot of time tied up for Covid. During this time alongside I was living and working on the ship but I just dont know if any of that time is creditable.
The fact that your sea service letters document the period alongside, you best figure on using the 3:1 ratio for those periods.
Why do they do it that way? Most commercial vessels in familiar with just list days onboard and that’s it.
I wish I knew. Would have been a lot easier for me if they had simply specified total days on board.
Ask them.
Probably because that’s the right way to do it.
Do you specify underway days on your discharges? If it was important why isn’t there a place for that information on the official USCG form?
“Nature of Voyage”
You’re supposed to fill out “shipyard” or some other extenuating circumstance. I agree, most people don’t, but some places (like MSC) give different discharges for pier time or shipyard time vs. underway time.
Yep, I work for another federal agency so my sea service letters sound very similar to MSC. Do you know if the shipyard/pier time is creditable?
It should be the 3:1 that’s quoted in the CFR above.
Or, try and talk the Captain into just giving you a discharge that’s a little vague.
1 Like
From my experience its all qualifying seatime. Your doing shipboard maintenance, standing gangway watches, handling lines, regularly underway that’s almost the job ! I think The NMC is way too busy to figure out how many vessels were dockside or anchored during Covid and if they could then they should even throw in a couple years of seatime for all those Mariners who were literally stuck on vessels with no relief or shore time. Give them all RATINGS !
I have a another pretty unique one. I realize vessels over 100 tons do not have to be underway for sea service. I also get that certain MSC, MARAD, “lift up” boats boats sometimes have the special rules for vessels that infrequently get underway and the day for three credit based on their COI. I also get that large 100 ton and over yachts, without a COI, can get credit for time spent at the dock assuming they are operational vessels that can and do get underway.
Forgive that this is a bit of a long post I am trying to explain it shorter but failing….
I have a question about a more unique situation. What a historic sailing vessels over 100 tons. Some US historic sailing vessels are owned by museams and non profits. These vessels do not have COI’s , or infrequently have temporary Dockside attractions COIs. However these vessels do get underway. When underway they sail without paying passengers or cargo and are considered yachts when underway. To further confuse the matter they also may occasionally obtain temporary Dockside-Attraction-COI’s for dockside events. For brevity of this post I will not go into all the different set ups I have seen, some of these boats are rovers, some stay close to home. I will elaborate if asked.
The actual underway time is pretty cut and dry we should write a letter for the service. I am writing underway seaday letters for the crew of one ship right now. Dockside for me is a bit more muddy.
How the heck should we interprate the non COI dockside time for these over 100 tons when they infrequently get underway? Remember they typically don’t have a COI so the CFR 46 CFR 10.232(e) wich specifically states a COI does not apply. Would the time they have a temporary dockside COI change things?
It would be great to give our crews SOME dockside credit as we do actually practice a lot of the skills needed for this portion of the industry even at the dock. I just don’t know what weird section of the CFRs to reference.
Really? Do you have a cite to a supporting authority? Note the title of the section II of the small vessel service form, “Record of UNDERWAY Service.”
Should have explained more This is straying into areas I need to recuse from It has potential to lead to an appeal that my office will be involved in. If you are looking for a general response on service on historical veesels send a reasonably detailed inquiry to mmcpolicy@uscg.mil
1 Like
No worries, Jdcalvo. Yes, my question is way more than that first paragraph, which I admit was poorly worded by a non-lawyer. Based on your reply, I won’t ask additional questions directed your way.
I do feel I should clarify I did not mean to imply there was automatic dockside sea time for just being on a vessel over 100 tons. I know there are specific instances where some limited amounts of credit on larger vessels can be given for dockside, and I would like to find what of those, if any, that apply to us.
(the vessels I am talking of are over 200 tons, so we can’t use a 719-S either).
In the meantime, I will only ask for credit when the vessel is underway. I try to put on my big boy pants and wordsmith a well-written question to the MMC policy email rather than an internet form, and if there is a path, ask for that credit after we get guidance.
1 Like
Maybe the easiest thing to do is just go get some additional seatime on bigger working vessels.That’s not difficult to do in the current job market.
1.5 days of seatime (for 12 hour days) on tugs, OSVs , or FVs adds up quickly.
If sail time is specifically needed, there are places like SEA in Woods Hole.
I happened to notice an ad for crew the other day for a 500 GT Dutch sailing vessel doing seasonal voyages on the coast of Greenland.
Oceanwide (the Netherlands office) also has a 500 GT sailing vessel doing the same thing. I’ve seen their ads in the past.
As far as I’m concerned if the vessel is “active” the sea time includes all days onboard. Example, if it’s sailing around the country stopping in different ports each weekend for two days then it’s active. If it’s like the Gazela, that lives at the dock and only rarely gets underway for training cruises or the occasional trip somewhere, then it’s not active and the sea time is only when underway.
1 Like