ETO time toward Engineer Unlimited

There’s not much on this site about ETO’s. Can time served in the engine department as an ETO count toward an original Unlimited Engineer license??? CFR’s don’t address this. I would think it would since you’re assigned to the Chief. Any ideas???

I would think righting it up as QMED on your discharge/sea time letter would fix that.

[QUOTE=“Wrench;113868”]There’s not much on this site about ETO’s. Can time served in the engine department as an ETO count toward an original Unlimited Engineer license??? CFR’s don’t address this. I would think it would since you’re assigned to the Chief. Any ideas???[/QUOTE]

They don’t recognize ETOs you will need to hold a QMED and have your sea time letter reflect the QMED time. Make sure to also have a RFPEW (Rating Forming Part of an Engineering Watch)

Good Luck!!

At a minimum, it will count for at least one year towards 3rd AE. Third requires a total of 3 years in the engine department, with at least 2 as QMED. I’m not sure uf it would be credited for the remaining 2 years as QMED. Unlike some other licenses, the service for 3rd AE just specifies it has to be as QMED, and not “or equivalent supervisory experience.” So while it would be easy to determine ETO is equivalent to (or superior…) to QMED Electrician, this reg clearly says as QMEDF and doesn’t allow an alternative.

It won’t count towards any other unlimited license besides 3rd, they all require you to hold the lower level license while getting the time (e.g. 2nd requires you hold 3rd, 1st that you hold 2nd, etc.)

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[QUOTE=exsubguy;113872]I would think righting it up as QMED on your discharge/sea time letter would fix that.[/QUOTE]

If the vessel is over 1600 GRT, they are probably using certificates of discharge signed by the Master and sent to the Coast Guard. Masters signing CDs are often less willing to take lliberties in “righting up” CDs than some office types are with service letters. The threat of a license suspension probably makes them hesitant to embellish.

Sorry to dig up an old thread, but I’m curious if there have been any updates on this topic in the last 10 years.

I noticed that the current CFRs reference “QMED or equivalent position” as part of the sea time requirement. I’m not sure if that language was there when this was originally posted. For reference:

46 CFR §11.516

“Three years of service in the engine room of vessels, 2 years of which must have been as a Qualified Member of the Engine Department (QMED) or equivalent position.”

Also, does anyone know a good way to look up historical versions of the CFR prior to 2017? The ECFR changes-through-time tool only seems to go back that far.

Finally, if anyone has real-world experience getting evaluated for 3rd based on ETO sea time, I’d appreciate hearing how evaluators are interpreting this—especially when it comes to what qualifies as “equivalent position.” to QMED.

Thanks in advance to the community!

There have been no changes since 2014. The STCW (and other stuff) rule in December 2013 added “or equivalent position.” Generally, 'equivalent position" refers to military service in a comparable position. In this case it could also apply to service on vessels not required to carry QMEDs.