License Continuity


I have had opportunity to discuss in the office. The consensus is that to restore previously held STCW endorsements, all that would be required is whatever would be required to renew those endorsements at the time the national endorsement is taken out of continuity, plus any intervening one-time, gap-closing requirements that took effect while the national endorsement was continuity (e.g. Leadership and Managerial Skills, or ERM). It would not be necessary to repeat courses or assessments done previously.


That’s my understanding! To my knowledge there is no provision internationally or with the USCG for STCW endorsements/rating. Continuity is only mentioned for the National renewal and not the STCW renewal


You do need the Medical cert. in order to renew the MMC they go hand in hand from what i understand


Check the “Continuity” tab here.


Yes, you do need the Medical Certificate to renew. But you don’t need to renew your Medical Certificate simultaneously. So, if your MMC and MC both have not expired yet, you can renew your MMC even if you only have one day until your Med cert expires. Your new MMC will only be usable until your old MC expires, but all you need to do is get a physical after you are fit and reapply for a new Medical Certificate. In essence, you can get an extra 5 years on your MMC without a physical as long as you renew before the certificate expires. Again, this won’t allow you to sail, but it will keep your license active.


Also, this got me thinking. Since the Medical Certificate is issued at no cost, how often should a mariner renew it? I assume most of us wait until it is about to expire. But it seems like it would be a good idea to renew it annually instead. That way, if a medical condition that disqualifies you arises, you will have the maximum length of time left on your old medical certificate which give you extra time to get fit for duty before you must renew.


There may be no fee for the application, but does the same apply to your doctor? And while there is no requirement to report a change in medical condition, there might be civil liability for operating a vessel with knowledge of a disqualifying condition.


My insurance (and I assume many others) covers a free physical annually. That is why I suggested this time period. And please don’t think that I am suggesting that any mariner should use this loophole to actually sail with any condition that would disqualify him for duty. If you are not fit for duty, you should not sail. Period. But that doesn’t mean you can’t take advantage of the way the regulations are written to make sure your license status doesn’t expire while you are waiting to recover.


The medical certificate can lapse as long as you don’t work on your license/MMC while it has expired. It does need to be current at renewal of the MMC, but It doesn’t need to be continuously valid for the entire period of the MMC.


This is what I’ve been preaching to my crew for several years now. I’ve already seen several instances where someone couldn’t return to work because they forgot about this certificate.


I recognize that it doesn’t need to be continuously valid for the entire period of the MMC. That is what has created this loophole. Previously, you needed to get a physical prior to renewing any license, so the license and physical went hand-in-hand (nominally every five years unless you add endorsement in between). But doesn’t your medical certificate need to be unexpired in order for you to sail legally under your MMC?


I tried finding the answer for this in the CFRs, but without success. But it seems like a valid medical certificate must be a requirement to sail (not just to renew), or else why do they have separate expiration dates for national, STCW, and pilots?


It does have to be valid to sail, but if you are not sailing, you can have a lapse in the medical certificate.

But your general idea is good, but I’d suggest applying it to your MMC and sea time - if you have STCW endorsements and currently have one year of service in the last 5 years, but anticipate that you may not have it when it’s time to renew your MMC, consider renewing it early so you can take shorter “revalidation” courses and not the longer and more expensive “refresher” courses.


Yes - I agree with that, too. You need to spend a little money to renew but will save lots of money with the courses.

I am interested in what part of the CFRs state that you must have a valid medical certificate in order to use your license. As I say, I assume that must be the case, but I can not find it in writing. There is nothing on the medical certificate itself that states that the card must not be expired in order to for your MMC to be valid.


46 CFR 15.401(d).


A rep at the NMC said this morning they won’t issue an MMC without the medical cert.


Btw what is the turn around time now for the NMC to complete a renewal?



Don’t you already have a medical certificate tucked into that stupid plastic pocket of your current MMC? If you do and it is not expired, the NMC just needs a photocopy of it to renew your MMC. Or is your current MMC old enough that you got it before they changed the rules requiring medical certificates?


(d) Each individual referred to in paragraph (a) of this section must hold an MMD or MMC that serves as identification, with an appropriate endorsement for the position in which the seaman serves, and the MMD or MMC, along with a valid medical certificate, must be presented to the master of the vessel at the time of employment or before signing Articles of Agreement.

I notice that it doesn’t say the medical certificate must be valid throughout the period of employment. Just at the time of employment or before signing articles. Just saying…


I gave you the link to all of 46 CFR 15.401. From 46 CFR 11.401(c ):
A person may not employ or engage an individual in a position required to hold an MMC unless that individual maintains a current medical certificate. [emphasis added]

Do I need to start charging for legal research…?