USCG MMD Expiration And Renewal

How long after MMD EXPIRES can u work on it if you have put in for a renewal?

Zero days.

I’ve been told that up to 3 months if u have the receipt and prove that it’s been submitted
Just trying to reconfirm that

You can’t.

You were told wrong. See 46 CFR 10.205(c ):
A mariner may not serve under the authority of an MMC past its expiration date.

But, if the expiration date printed in your MMC is between July 17, 2020 and June 30, 2021, the expiration is extended until October 31, 2021.

That’s true under the STCW Convention, so foreign Port State Control won’t be up in arms, but not true under US law as the Flag State. US says zero days.

I’d go with Cavo’s interpetation.

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Yea I sent my application off before coming to work and it got lost in the mail and now I have to wait tell I get home to resend my MMC is good tell August I getting home like 2 days before it expires

How long are they taking to issue them?

You should have emailed it the first time and you should email it this time.

They’re taking about 60 days to even start looking at them.

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It isn’t. It’s only being allowed now as a COVID-19 temporary measure. That’s why when NMC had large back logs at the time of the end of STCW grandfathering in 2016, they prioritized the processing of MMCs with STCW endorsements, and extended the expiration of national endorsements only (not STCW).

Under Regulation I/10 Paragraph 5 of the STCW Convention, what the original poster is mentioning is explicitly allowed. However, the United States has chosen not to allow this exemption for mariners licensed under its authority. STCW, as an international instrument, allows for it, but US domestic laws/regulations do not. That’s where the confusion likely stems from.

Perhaps I should have prefaced my comments with “For documents issued by the United States…” or "If you are asking about working on a U.S. flag vessel under an MMC issued by the United States…"But it was pretty obvious by posting in this forum and asking about an “MMD” that the poster is asking about US documents. There’s nothing to suggest this poster holds or is asking about certificates attesting recognition under STCW, which, as you noted, the United States does not issue.

For anyone else who may care, here’s the text of the STCW regulation:

Notwithstanding the requirement of regulation I/2, paragraph 7, an Administration may, if circumstances require, subject to the provisions of paragraph 1, allow a seafarer to serve for a period not exceeding three months on board a ship entitled to fly its flag, while holding an appropriate and valid certificate issued and endorsed as required by another Party for use on board that Party’s ships but which has not yet been endorsed so as to render it appropriate for service on board ships entitled to fly the flag of the Administration. Documentary proof shall be readily available that application for an endorsement has been submitted to the Administration.

That 7-line paragraph is just 2 sentences, the first of which is 6 lines long and has 6 commas.

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You really should email it TONIGHT. Every hour you waste right now is an hour that you will not be able to work after it expires.

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I did not mean to quibble with you, as your knowledge of US licensing is likely unsurpassed by anyone in the world to say nothing of this forum. My intent was only to clarify where the misinformation about 3 months came from so that Sailor0992 did not accuse the source of the 3 month number (whose license may or may not be issued by the US) of being way off base, only to have the bridge copy of STCW waved in his face to add to the confusion. I apologize if it came off differently.

As for the comma-laden text block, it can only be expected from the group of international linguists who came up with the word “recommendatory” as the antonym for “mandatory.”

I just mailed mine off a few days ago and was told 49 days before the evaluation happens. Hope that helps

I did not consider that although I was answering a specific question that response would be read by others whom your information does apply to.

I attribute some of IMO speak to the fact that documents are often drafted by someone whose first language is not English. I have not seen recommendatory, but I suspect it’s that the document was drafted in a language where there is a word for that. The opposite happened when the 2010 amendments were being drafted, the STCW refers to safety and security but in Spanish, they are the same word (“seguridad”).

No idea about the 6 line sentence, but that’s mild to a document being drafted now that I was looking at last week, it had a paragraph that was 12 lines long and was a single sentence with 18 commas.

It has a distictly German ring to it, same as the CEVNI code.

Also if it helps I mailed mine off May 19 and it didn’t get assigned to an evaluator until July 12. Quickly got approved the 13th and received it the next day in the mail