Policy Letter 01-02 vs. 46 cfr 11.416

What’s the deal here? To get my 1600 NC Mate, according to 46 CFR 11.416, I need 2 years of seatime.

But, according to Policy Letter 01-02, I need 3 years of seatime. And wouldn’t you know it, it says it supersedes the cfr, but the old cfr: 46cfr10.

I suppose I have to go with the Policy Letter, right? I don’t want my oceans, just Near Coastal.


FYI…the current “checklist” off the NMC site still references 46 CFR 11.416/720 days and makes no further reference to any policy letter…suggest you e-mail the NMC for written clarification…depending on how you word your inquiry this could be one anomaly in the mariner’s favor??



I think you are looking at the wrong and/or outdated cfr. http://edocket.access.gpo.gov/cfr_2009/octqtr/pdf/46cfr11.420.pdf shows two years service on deck.

See 46 CFR 11.903©

I also see a few other differences too…

One in particular, is the amount of engine room time that is allowed, CFR 11.410 says up to 25%, where as the Policy Letter 01/02 states up to 90 days…In a case like this what is the final result? I have to assume the policy letter is following the STCW code, but you know what they say about people that ass u me…