Navigating through the USCG STCW rules


I think the issue they may have with a discharge book is that it does not show underway days
Simply sign on - sign off - vessel details - stamp and signature


That’s just another example of the difference between a seatime letter and a discharge.

The USCG respects and credits discharges which don’t give any details beyond: name of ship, official number, GRT, date and place signed on, and date and place signed off, nature of voyage, and signature of master, yet discharges are accepted without question.

Company seatime letters should require nothing more than a discharge, yet the USCG seizes the opportunity to demand magic words about drills, drug testing,etc, etc.

Moreover, issuances discharges on sign off are mandatory under the law, but the companies routinely violate this law. The USCG takes no enforcement action.


An inspected vessel is required to do drills so they don’t require mention of drills from ships that issue discharges.

You need a drug test letter regardless of method used to prove sea time.


Neither does a normal sea time letter, at least in my experience. Do you actually think someone from the office goes through vessel logs to see underway days (that you were onboard) in order to write your sea time letter?

Just like what’s on a discharge, what’s wrong with that?


Tugs and fishing vessels are required to do drills too. Requiring the drill language in the seatime letters is redundant and stupid.

Thinking that only days underway show up in a discharge or seatime letter is ridiculous. It’s almost always days onboard, all of them. That’s what the rest of the world does too. Some time at anchor, alongside the dock, doing cargo, and in the shipyard is valuable experience. While someone may occasionally get credit for a couple months in the shipyard, that doesn’t do any harm. Being underway over the horizon in flat calm weather with no traffic is not particularly good experience either.

The drug test wording makes sense because all it might do is make a new test unnecessary. Nitpicking the wording makes no sense. A guy was either tested or he wasn’t; he either passed or he didn’t. No magic wording needed.

But it’s a government bureaucracy, it’s not suppose to make any sense.


You have to keep
Lifeboatman up every 5 years? Does this apply for just people with stcw codes?


I used my MI book from a drillship for some days on my last renewal (December submission) and had zero issues.


46 CFR 10.232 (a)

(2) Documentary evidence produced by the applicant, unless in the form of a Certificate of Discharge conforming to §14.307 of this subchapter, must contain all of the following information:

(i) Vessel name(s) and official numbers listed on the registration, certificate, or document issued.

(ii) Gross tonnage of the vessel.

(iii) Propulsion power and mode of propulsion of the vessel.

(iv) The amount and nature (e.g. chief mate, assistant engineer, etc.) of the applicant’s experience.

(v) Applicable dates of service for each vessel, and the ports or terminals if applicable.

(vi) The routes upon which the experience was acquired.

(vii) For those seeking service credit on towing vessels in accordance with §11.211(e) of this subchapter, the aggregate tonnage of the tug and barges during the mariner’s service.

(viii) Any other information necessary to determine the applicability of STCW to the vessel.

(ix) Whether the vessel is manned and equipped in accordance with SOLAS.


No, you don’t. If you have STCW-PSC you need to revalidate that every five years.


Good reason to forget about letters and go back to discharges.


Probably not. It does not appear to comply with 46 CFR 10.232(a).

See the regulation I cited above. Certificates of Discharge are specifically excluded from having to provide the information required for other forms of documentation.

Days underway are not required.