License renewal question - Master of Towing with no Seatime


Having a difficult time getting a straight answer on this topic.

I have a Master of Towing and 1600 OC Master. I have not sailed in the previous five years and am looking to renew these capacities. I am not looking to renew STCW, although I currently have it.

Renewing the Master 1600 seems straightforward.

For the master of towing renewal there is an additional requirement to either demonstrate capability in front of DE or “Participate in ongoing training or drills”. On the national renewal checklist below the “ongoing training and drills” requirement there is a line saying “Renewal of BT will also meet training and drills for renewal of Master or Mate of Towing.”

I asked the NMC if I renew the BT portion of my STCW, by taking the three day course, will that allow me to renew the Master of Towing without sea time by satisfying the “ongoing training and drills requirement”.

The phone/email (first line) people at NMC are saying that is not what that means. They are saying that only applies when someone renews BT with the one day class when the have the sea time.

I talked to a competent person at maritime training centers and one said they have helped with multiple renewals on Master of Towing with no sea time by taking the three day BT class.

Hesitant to make arrangements and spend thousands with no clear answer. I’ve searched through the CFR and NVIC 3-16, and don’t see any clarification.


I believe you need at least 90 days in the past 5 years to renew

I believe that you are on the right track.

The reading of the National Renewal Checklist, 46 CFR 10.227(e), and NVIC 03-16 - Questions 22 and 23 all seem to point to three elements for a renewal of Master or Mate of Towing:

(1) open book test for the Master or Mate (Pilot) of Towing; and either

(a) complete the practical demonstration before a DE; or

(b) provide documentation in participating in training and drills:

They provide two possible options for documenting “training and drills requirement”:

(1) for those that have not sailed on towing license but could have sailed on their commercial license they could provide documentation in participating in training and drills. Questions 22 and 23. or

(2) take a BT refresher course you meet the training and drills for that portion of the Master or Mate of towing as per the STCW Renewal Checklist.

In summary, without 360 days sea time in the last 5 years, it looks like a 1600 ton and towing vessel open book tests; and a BT refresher course.

If this sounds reasonable, then I would type this up and send an email to AskNMC for clarification to get their response in writing.

I say this knowing that the only real answer will be the one coming from NMC evaluation team.

Thanks for your reply, I have asked the NMC twice and I have not been able to make contact with anyone who seems to understand the premise of the question. I’m just not confident I am getting someone who understands my question/is’nt just making things up as they go.

My gut feeling is the the BT course will meet the requirement of “ongoing training and drills” from the CFR, but that is based on the checklist mention of BT alone.

I am getting the same results. As I said I would draft an email and get one back from them as they sign their return documents. I have used the paper trail for future conversations. Also as you do not have the 360 days seatime you will need the BT Refresher. I have done this with Port Captains and Port Engineers. Remember to cite your sources.

I went through this on my last renewal. Due to the pandemic and a transition from a full time seagoing career to a part time gig oriented model, I did not have the 360 days in the last five years.

I renewed all of my STCW credentials by taking the refresher courses, or the full course when a refresher did not fit my schedule. I took a BT refresher (3 day) course.

I renewed all my national credentials with the open book tests. This included a Mate of Tow NC route. The sea service that I did submit was on passenger vessels as master. I did not submit any towing vessel time on this renewal.

In a cover letter submitted with the application I did site checklists as well as CFR references. My theory was: make it easy for the evaluator to give me my credentials. Other than an incredibly long processing time my renewal went smoothly, and there was no squabbling from NMC concerning the MOT renewal.

The only people at the NMC qualified to give a definitive answer are the evaluators and they’ll only give you an answer if you apply.

Any sea time can be used to renew towing licenses, it doesn’t need to be time on tugs.

Did you ever complete a TOAR?
If so, do you still have a copy?

I did do a TOAR, not sure if I still have it though as I’ve had the MoT in the license for some time now.

If you have it, or a scan of it, then losing the Master of Towing isn’t that big of a deal. You still have the Master 1,600 and a TOAR…