How is it rational to require 1600-ton licenses to go offshore


#1

while allowing 1,000+ ton foreign-flagged “private yachts” to continue to cruise the world with 12 charter guests and no other licenses other than a captain. For example, the COI of these boats say something to the effect that these boats must only be manned by an “adequate crew”.

The proposed changes will require a US 200-ton mate to have 1080 days of sea time, while a MCA-approved CAPTAIN of a comparable vessel will still need only FIFTY-FIVE days of sea time.

And, if the playing field is really supposed to be level, all of these vessels should require drug tests… or none of them should. Don’t get me started on the various alcohol policies…


#2

You’d love the thread where I found this:

[QUOTE=Capt. Fran;13397]I did a yacht delivery a couple of months ago from Baja to Florida.

Captain told me he had the following rules:

  1. No music on watch (OK, I can live with that, it is his boat.)
  2. No reading on watch (WTF? Um, OK, I promise to not finish my Harry Potter series while navigating. Scary that he felt that this had to be a rule.)
  3. Take a fix, oh, well, at least once a watch (WTF? Um, OK, is it alright if I take a fix more often than that? Even more scary was the fact that I had to ask permission to write on the chart.)

Totally weird experience. I think that if we had lost our ECDIS, I would have seen the Captain reenact that scene from A Bug’s Life where a leaf falls in front of an ant and he screams, “I’M LOST!!!”.[/QUOTE]


#3

[QUOTE=PMC;31652]while allowing 1,000+ ton foreign-flagged “private yachts” to continue to cruise the world with 12 charter guests and no other licenses other than a captain. For example, the COI of these boats say something to the effect that these boats must only be manned by an “adequate crew”.

And, if the playing field is really supposed to be level, all of these vessels should require drug tests… or none of them should. Don’t get me started on the various alcohol policies…[/QUOTE]

To begin with, if the boat is carrying charter guests it is operating under a commercial registration and will have a Safe Manning Certificate that spells out very clearly the level and number of licenses required. The number of crew actually carried will normally be as many if not more than the number of “guests” on a yacht that size.

The US is the only country that is hung up on drug testing. Other countries figure what you do on your own time is your own business and just like the USA, prohibit the use of drugs onboard. As far as alcohol goes, individual boat policies vary but overall, the rest of the world believes boats are manned by adults. Those who abuse alcohol get fired for all the right reasons and no government agency is needed to help the captain weed out the performers.


#4

Who determines the requirements for the Safe Manning Certificate?


#5

I believe the answer is that all commercial yacht owners and/or managers can submit a manning proposal to the Marine Administration for approval prior to registration. So the owner turns to the captain and says, how many crew do you need? Then they submit a proposal for approval.

I see on the Safe Manning MCA matrix that one can go 60 miles offshore in a <500 GRT boat with a captain and a “Coastal Skipper” I think the sea time requirement for coastal skipper is… zero days? And if a crew member does not have the requirements that the boat proposed, they can submit a request for the crew member to function in the required role if they can demonstrate that they are “working” on the qualification.

I am not bashing the MCA here. Hell, the RYA 200-ton course requires you to demonstrate some shiphandling skills. Whereas, in the US , you can, in theory, become an unlimited master and never dock a boat!

My issue is that the Coast Guard is getting rid of the 500-ton ticket to - let me get this right - to have the same requirements as everyone else?

It sounds like the beginning of a joke… Two guys are sitting in a bar. One has a 1600-ton oceans endorsement that required years and years of sea time and schooling; and the other has letter saying that he is working on his 55 days of sea time… And they are captains of identical boats… And the guy with the approval letter says to the other guy: "hey, do you want to go outside and get high?..

What’s going to happen is any of these yachts that are still American-flagged are going to quickly realize that they are crazy to continue with US crew requirements. Everybody in yachting is going to look for jobs washing boats so they can get their MCA ticket and move-up. And the result will be more people with less sea time, operating in US waters… and with no drug tests. Any why? Because the US Coast Guard effectively forced the industry to go this route.

Who’s interest does the Coast Guard have here?


#6

[QUOTE=PMC;31683]Who determines the requirements for the Safe Manning Certificate?[/QUOTE]

Flag state maritime authority determines the level, there is no negotiation to please the owner or captain. The manning depends on the distance offshore, tonnage, power, and type of vessel - sail or power.

Commercially licensed mariners who hold an STCW license from any White List country can apply to the yacht’s flag state for an endorsement of their license for service on that state’s vessel. Many times a real license will be endorsed for yacht service at a higher level than the underlying license.

While it seems “unfair” and a very good argument can be made that yacht limited licenses are diametrically opposite the intent of licensing (that is my take on the issue) they are a reality and anyone can get one and work on a commercial yacht. They are inherently crippled. They are useless for anything other than yachting.

I personally believe the IMO should eliminate the yachting license and demand all flag states issue licenses based on a single standard. But since the IMO has its headquarters near the MCA and the purveyors of yacht training and contract licensing are all drinking buddies it isn’t hard to see how the scam originated. It is a money maker for all the Red Ensign flags and it makes it possible to man a growing fleet of yachts.

Sea time aside, it isn’t much different than the US “lower level” thing, there are crippled licenses that tie the holders to a certain trade and maintains a steady but cheap source of labor.


#7

What I know or think I know about manning level requirements only comes from surfing the internet. I did find an application form where the boat makes proposals for manning levels to the MCA. Here is the form: http://www.mcga.gov.uk/c4mca/safemanning.pdf.

I am not attacking the MCA here. I question why the Coast Guard is ratcheting up the 200-500 ton requirements when other flag state agencies already are, in my opinion, already less demanding that the US when it comes to the 200-500 ton licensing requirements.


#8

[QUOTE=PMC;31697]What I know or think I know about manning level requirements only comes from surfing the internet. I did find an application form where the boat makes proposals for manning levels to the MCA. Here is the form: http://www.mcga.gov.uk/c4mca/safemanning.pdf.

I am not attacking the MCA here. I question why the Coast Guard is ratcheting up the 200-500 ton requirements when other flag state agencies already are, in my opinion, already less demanding that the US when it comes to the 200-500 ton licensing requirements.[/QUOTE]

Go ahead and attack, the MCA and its yacht licensing scheme is a legitimate target. It needs a spotlight on it. That application for a manning document is a standard form for the MCA to determine where to start. Just like all the other certificates that make up the vessel’s documentation, you have to request surveys and pay for them. The existence of a form to supply the basic information does not mean that the limitations of the certificate are negotiable. Safe manning certificates are called “minimum” for a reason, if you want to be amazed, look at one for a very large cruise ship.

One thing to keep in mind is that MCA is not a flag state. Relatively few yachts are registered in the UK itself, most are flagged with a “Red Ensign Group” country and while most of those maritime administrations simple cut and paste UK MCA guidelines, they each own their rule books. And for what it’s worth, even the MCA doesn’t accept a yacht license for domestic commercial service. A yacht license is a dead end ticket, it does not lead to higher licensing.

Yachties like to claim they have a “commercially endorsed” license, that is a bit of a play on words since all that means is that the ticket they bought from a storefront yacht license school tacked on the words “commercial yacht” to the ticket they sold with the blessing of the MCA. There is still a wide gulf between a real license and a yacht limited license. But, scary enough, as yachts continue to get larger the MCA is considering a means to allow yachties to crossover to a real license. They don’t want to kill the golden goose of yacht licensing.

As far as comparing yacht licenses to the US system of lower level licensing, it is not worth the trouble as there really is no comparison. US lower level licenses are stepping stones to an unlimited license, each level is a commercial certificate that allows legitimate commercial authority. It is an apples to oranges comparison. Much of the confusion in this area between the yacht licenses and how we look at US lower level licenses is because the yacht schools (who actually issue licenses on their own forms) love to use the same terminology as real licenses, and the holders of those cereal box certificates will never use the term “yacht limited” in any circumstance.

The question that should be asked of the IMO and member port states is how they can allow a commercial vessel carrying passengers for hire (these are not bare-boat charters) on an international voyage to operate in their waters with officers and crew who do not meet STCW requirements for training and certifications that state requires of the crew of a ferry or small passenger vessel performing an identical voyage.

Foreign flag commercial yachts do not charter in US waters. There are a few loopholes that allow them (openly or otherwise) to pickup or dropoff “guests” in the US Virgin Islands but when you see a foreign flag yacht in the US, it is registered private. It is very easy to change from commercial to private registration and it is a common and legitimate practice that some yachts do several times each year in popular yacht destinations in the US. It keeps Florida boatyards full of business. It also keeps south Florida full of blue eyed blonde illegal aliens walking the docks looking for yacht jobs but that is another issue altogether.


#9

Thanks Steamer for this post,well said and on the money.
Thanks to PMC for this thread,it has occurred to me before,but I have never broached the subject.
I am also for keeping the playing field level with concern to STCW


#10

[QUOTE=Steamer;31709]
The question that should be asked of the IMO and member port states is how they can allow a commercial vessel carrying passengers for hire (these are not bare-boat charters) on an international voyage to operate in their waters with officers and crew who do not meet STCW requirements for training and certifications that state requires of the crew of a ferry or small passenger vessel performing an identical voyage.[/QUOTE]

That is exactly right!

Related to your last point - maybe the Mexicans in Arizona would be held in better standing if they came up with their own periodicals like Dockwalk and Triton.