Master of Towing on 26’ pushboat

Does anyone know if it is possible to get master of towing or mate of towing while operating a 26 pushboat? Thanks

Does it require you to have Master or mate of towing in order to run it?

No it doesn’t

Then you probably can’t get it from working on there.

Sorry, but nope

What type of service endorsement does the vessel have on it’s CoD (look on PSIX). If it states it is endorsed for “Towing Service,” then the vessel is a T/V and it could qualify you for TOS.

every towing vessel of at least 8 meters (26 feet) in length, measured from end to end over the deck (excluding sheer), must be under the direction and control of a person holding a license or MMC officer endorsement as master or mate (pilot) of towing vessels, or as master or mate of vessels of greater than 200 GRT, holding either an endorsement on his or her license or MMC for towing vessels or a completed Towing Officer Assessment Record (TOAR) signed by a designated examiner indicating that the officer is proficient in the operation of towing vessels.

If the vessel is a towing vessel under 26 ft, it would not require Master or Mate of Towing.

A push boat under 26’ requires no license of any kind.

Yes! But expect a fight if you are the owner and self-employed. I went head to head with the 11th District over a policy instituted by a JG that was in violation of the CFR’s stating the qualifying SeaTime. If you were an owner/operator, self-employed, he would only approve your testing for a lower tonnage License than for which you were entitled. Do your homework prior to application and perhaps meet with the OIC of the REC in your area. If you have the funds, you might consider meeting with an Admiralty Law expert. The information is there in the CFR’s no matter what some officer may think “should be” the rules. Good Luck! Mkriewer Master of Towing Vessels


Dear Captain Phoenix, When the dispute arose, I requested a meeting with the OIC of the REC, and requested that an officer from District Legal, as well as an officer from District Command be present. I told them that if they found my affidavit of qualifying Sea Time to be of “questionable veracity”, I can appreciate their concerns and handed over a list of the names and addresses of the people from which I had obtained my qualifying Sea Time. I told them that this is my career, that I had already, from age 4, committed to meeting the qualifications. The real irritant was that if you were an 18 yr old Bait Boy with no Wheel time at all, he would accept your Sea Time but not if you were self-employed, or an owner/operator. I had done my homework and provided the CFR’s pertaining to qualifying Sea Time. I stated that I felt that the practice of allowing a junior officer to make policy affecting my livelihood, my future, etc. was not only discriminatory, but in violation of the pertinent CFR’s. I told them that if they did not accept my Sea Time, I would file suit in Federal Court and take out a full-page ad in the LA Times stating how the US COAST Guard practiced active discrimination to those who were Owner/Operators, Self-Employed, or in my case, Female. I invited them to contact the people who had provided me with affidavits of service, that I would pay for the calls and postage out of pocket. But I could not accept being approved for a 25- Ton License when my Sea Time qualified me for a 100-Ton License, it would make me unemployable and affect my ability to earn a living at my chosen occupation. Look, I get it! We all know people who have lied through their teeth, or had their employers provide false records of Sea Time if it was to their benefit. An Affidavit is a Legal Document. If someone provides a false affidavit, they should be prosecuted. But do your homework, study the CFR’s and be prepared to fight for the License for which you are entitled. Postscript- When the meeting concluded, I thanked the Officers for their time and asked when I might receive an answer to my appeal? They replied “within the next 10 days”. I got a call two hours later telling me that my appeal had been granted and that I was eligible to test for a 100- ton License.

I asked you to prove your claim that a towing vessel that is under the length to require a Master or mate of towing somehow qualifies one for those licenses.

If it is a “towing vessel,” that is all that the CFRs require. There is nothing in 46 CFR Part 11 that relates sea service to the manning requirements in Part 15.

I don’t know how the REC or NMC define “towing vessel,” and that is why I asked if the push boat has a towing service endorsement. I doubt it does, which would make a hard case to prove a push boat is a towing vessel.

I’m pretty sure they require it to have this:

Towing vessel means a commercial vessel engaged in or intending to engage in pulling, pushing or hauling alongside, or any combination of pulling, pushing, or hauling alongside.
33 CFR 164.70
Does a push boat under 26’ qualify as a commercial vessel? Not by any CFR definition I can find…

Yes, that is the same definition for towing vessel found in 46 CFR 27 Subchapter C, which is probably more relevant to Subchapter B sea service.

Is it involved in commerce? If it is work related, then it is. But of course, under this definition, I wouldn’t understand why every Towboat US wouldn’t qualify.

By this definition, if it is delivering fuel to a stranded boater, it would.

Commercial service includes any type of trade or business involving the transportation of goods or individuals, except service performed by a combatant vessel. 46 USC 2101(5)

Does a TowboatUS operator need a license if he’s not carrying passengers? Their want ads specify at least a six pack but that just may be because it’s a way to weed out wantabees.

Seems like a very grey area.

§15.410 Credentialed individuals for assistance towing vessels.

Every assistance towing vessel must be under the direction and control of an individual holding a license or MMC authorizing him or her to engage in assistance towing under the provisions of §11.482 of this subchapter.

So yes, but I don’t understand how the line is drawn between a towing vessel for the purposes of time of service for Master/Mate of Towing.

When was this? These determinations have been made at the NMC since 2009.

If I remember correctly it was 1981. The main beef was that a Lieutenant JG who was, at the time, given the power of career life and death at that particular REC, over people who were applying for a License, decided that people who worked for other people would have their Sea Time accepted without question. Those that owned their own vessels, were given the lowest tonnage License in existence despite the strength of their documentation. I learned a lesson long ago that has served me well, particularly when dealing with any “Gubbamint” body. Always learn what the Rules are so you know which ones you can break and HOW! I cannot emphasize highly enough how important it is to keep a copy of the CFR’s in your Gear-Bag. You might also have that book spiral-bound for easier reference. The whole point was that that officer could decide who got what License no matter what documentation the Mariner presented. The CFR’s, for good reason, do not permit this! When I presented the Chapter and Verse of the CFR’s in question, and invited them to audit my Sea Time by contacting the people who had given me their affidavit of Sea Time served, the CG abandoned their illegal position of granting that officer powers that did not exist in law. I must state another point of Law- A statement can be “They said, he said, etc.”. An Affidavit is a statement of Legal Fact and one given the full power of LAW! To present an Affidavit that is false, is to present a fraudulent document. You are legally committing an act of PERJURY. That Mariners, and specifically, their employers, have been doing so since the first log slid into the water, is immaterial. I hope you see the legal minefield you are dancing into. If you allow the officer challenging your Affidavit to do so without Question, you are admitting to PERJURY. I cannot remember reading of the last instance when CG challenged an applicant’s Sea Time in a court of law. Do not accept it when CG fails to honor their own Rules of Engagement. It can affect your entire career.