Is a Capt. or Operator License needed?

Oil Spill response companies 25ft- 50ft uninspected boom boats & skiffs??? Do they require an operator or Captains licnese?? I have read the CFR and it states if it is for hire and carries passengers then yes it is required. However, we are for hire but do not carry passengers?? My guess is that even though no passengers are carried, the fact that the vessel is for hire needs a capt. or operator? Thanks for the help.

[B][I][U]IMHO[/U][/I][/B] :unless there is some form of “waiver” involved… would imagine as in most “commercial enterprises” a minimum of a USCG “launch” operator license would be required??

http://www.seaschool.com/launch.html

http://www.uscg.mil/nmc/checklists/Master_100_Limited%20Checklist.pdf

Do you have insurance? Sometime that is the requirement even if legally no license required.