Letter of Designation or Tankerman-PIC

USCG is considering doing away with MMC and Tanker-PIC requirement for fuel transfers in favor of just having a LOD from your company. Curious on the thoughts of this group.

Notice of Proposed Rulemaking

Good, get the liability away from the deck officers and onto the guys doing the pumping.

When I was on uninspected tugs if we needed to fuel and didn’t have a licensed engineer onboard the licensed port engineer has to go with us to the fuel dock to be PIC. We didn’t have any deck officers with Tankerman PIC to make sign for the transfer.

I personally disagree. I believe a PIC should be on board during ANY petroleum transfer.

That’s just me though.

Would this “letter of designation” be similar to the “letter of appointment” in the security plan for the vessel security officer? That thing is worthless.

I was no fan of getting my PIC but I can see the benefit of having it to vet out who has put in the time and has something above basic knowledge of dangerous liquid cargo transfers. Get the tug and barge guys on the same page.

I’d be inclined to “follow the money” … so much seems to be dictated by insurance concerns and the like. I don’t know how liable I’d of been had I ever made a mistake with a tanker and certainly wouldn’t of wanted to find out!

That’s stricter than what is currently required. A licensed engineer can fuel a vessel without needing to have a Tankerman PIC onboard.

I hope y’all are going to make these comments on the docket for the NPRM. They count for nothing if you only make them here.


And I believe a licensed engineer should have a PIC. Why shouldn’t they?

To get a Tankerman PIC you have to transfer oil as cargo so no, engineers don’t, and shouldn’t, have a Tankerman PIC.


I know several engineers who would love to get a PIC endorsement but they can’t because most engineers don’t discharge anything. We receive & then make internal transfers until we get low then receive again. The USCG would have to change the requirements to get a PIC, it would be too much hassle.

1 Like

From my understanding, when the engineer (or whoever) signs the DOI to receive fuel then they are one of the PICs of the transfer & must stay onboard the whole time unless they get special permission from the Captain of the Port. The dockman/bargeman who is pumping the fuel should have a Tankerman PIC endorsement & be the PIC of the discharge.

1 Like

True. But that is different from having or needing Tankerman PIC.

Unless they are receiving fuel as cargo the transfers don’t count towards a Tankerman PIC.

1 Like

I know several as well, problem is they are too lazy to get out on deck and help with cargo to get their loads/discharges. The opportunity is always available, at-least on tankers.


In what way would it benefit them though? Just the option to sail as Tankerman if the market goes to shit?


Actually we (shipboard engineers) do make external transfers. At least once a trip a a barge comes along side and we discharge the contents of our slop tanks. Since those entries must be made in our oily record books I think that counts. I have also been involved on more than one occasion in the pumping off of oil (fuel and lubes) on ships that have been laid up.

Our rate of discharge may be low but that has nothing to do with being a PIC.


If they are an unlicensed engineer then they should get the Tankerman PIC Restricted to Fuel Transfers on Towing Vessels. If they are licensed then it won’t benefit them any so there’s no point.


I’ve renewed my Tankerman PIC by receiving fuel as an engineer. I got my 2 renewal discharges by helping a dockman pump fuel to another vessel.

I don’t think it really would. Most of the time it’s them throwing a fit because they had to fix something, and then they see the tankerman walk by whom which they believe have an easier job for the money. Just being honest.

That time isn’t supposed to count but the NMC fucks up occasionally.

1 Like