I don’t think so. I think the reach around…errr workaround, or why it may appear that way, is the simultaneous holding of a 1600 Master or Master Large OSV. In those cases you ARE holding a Management Level STCW. See below.
Don’t know about OSVs but deep-sea the Chief mate is not required to hold a master’s license. If say, the second mate holds a masters license and the chief mate does not the Chief mate is still going to be the officer that relieves the master in case of incapacity.
If a person holds an unlimited master’s license but is sailing as Steward Utility that person is a Steward Utility , not the chief mate.
Also, how are you doubting the duties performed are that much different? It may not be as much work or as hard and time consuming but I guess OSV’s have no cargo, crew, or training to that crew that needs to be administered? Just because it’s mud and groceries being taken out to a rig it doesn’t mean the vessel doesn’t need a voyage plan, stability plan and a well trained crew. The Chief Mate is the deck boss and makes sure this is all done. Unless I’m missing something about the duties of a Chief Mate? I guess maybe none of this needs to be done on an OSV? I guess a VLCC is the only vessel that carries cargo then, good to know…
The Master Inland AGT test is at a similar level of difficulty as the basic 100 ton test. To prepare, I brushed up on Rules of the Road, but nothing else. The exam is easy and only takes a few hours. There is no need and no point to spend weeks trying to scam your way into the license without taking the exam.
No, no one agrees with that. Yes you can apply directly for Master Unlimited Oceans, but you will need to take the test. If you want the STCW component you will need to take the classes and do the assessments as well. (You will also need to take the test if you only apply for Master Unlimited Inland.)
The oldest edition of the CFR I have available is 1996, and that definition of “chief mate” is in there and is the same. It only appears to be recent as it really had little effect in the past. When OSVs were all less than 3,000 GT (1,600 GRT) there was no way to meet the requirement for an “unlimited” license to have at least 50% of service on vessels over 1,600 GRT. You could not be the chief mate on any vessel over 1,600 GRT without holding a license as chief mate unlimited. When OSVs became larger than 3,000 GT, that changed, but it was not until the 2013 rule change that formally authorized an OSV endorsement for 1,600 GRFT/3,000 GT or more that anyone took notice of the definition of chief mate and the service requirements for master unlimited, even though they had been there for a fairly long time.
As far as checking COIs, you are mostly correct. NMC evaluators definitely go into “MISLE’ the Coast Guard’s database that includes vessel data. Note on almost all NMC checklists there is a note “check MISLE.” Will they always check the COI? Maybe not. If manning isn’t an issue for evaluating sea service in the application, probably not. But they will still be in the system to check things like vessel tonnage, and possibly whether the vessel is authorized for voyages on the routes described in the service letter.https://www.gpo.gov/fdsys/pkg/CFR-1996-title46-vol1/pdf/CFR-1996-title46-vol1-sec10-103.pdf
That’s wrong ( I was going to say it is “partially correct” but for you I made an exception to my usual practice of polite understatement).
It wasn’t a regulation per se, but the combined effect of several regulations, see my post immediately above that explains the interaction of the tonnage requirements to qualify for “unlimited” endorsements without a tonnage limit (after 20 years I still cannot say or write that with a straight face) and the statutory limits on the tonnage of OSVs.