So, trying to (a) verify which rules regarding working hours apply to people working on ferries <100 GRT, and (b) get any information in how such rules are interpreted.
46 USC 8104 seems to say that that a master or officer must have 6 hours off-duty in the previous 12 in order to take the deck, and that any licensed individual may not be required to work more than 12 hours in 24 underway.
Assuming this is the only set of rules applicable here, are these rules applied strictly as written? Or does the coast guard ever say, “Well, you’re underway for 45 minutes and then you’re tied up at the dock for 15, so 12 hours is more like 15” or something similarly ridiculous? Because I would read this and interpret it as your shift, including any time at the dock, cannot be more than a maximum of 12 hours, unless there is an actual designated rest period in the middle. Am I wrong?
Yes, as a practical matter you are wrong. You are reading the law too literally and overthinking it.
Don’t even ask such questions. No good can come of it.
Just get a sea service letter from the employer and apply for your license.
Another thing, don’t argue with your company office girls if they make a mistake in your favor.
I am licensed, thank you. And believe me I am aware of what might happen if I ask directly. Why do you think I’m asking here instead?
Assuming your typical voyage is less than 12 hours in duration, your COI should have a blurb on it that reads something along the lines of “IF THE VESSEL IS AWAY FROM THE DOCK, OR PASSENGERS ARE ON BOARD OR HAVE ACCESS TO THE VESSEL FOR A PERIOD EXCEEDING 12 HOURS IN A 24 HOUR PERIOD, AN ALTERNATE CREW SHALL BE PROVIDED.” That’s essentially the CG interpretation of what constitutes work hours on a small passenger vessel. At the dock WITHOUT passengers onboard does not count against the 12 hours, but everything else does.
The NMC generally accepts the seatime letters at face value. If the letter says 30 days, you get 30 days.
NMC doesn’t have time to look into the type of nuances and details that you discuss. If the Coalminer’s daughters at the NMC started parsing seatime letters for those details, routine license applications would take a year instead of three months to process.
Everyone has a modest amount of time alongside the dock, in the Anchorage, or at the shipyard. That’s expected and understood.
You misunderstand. I’m not worried about getting my seatime. I’m trying to figure out the legality of the schedule.
Okay thank you this is the information I was looking for. I’ll see what is written on the COI.