Policy Letter 11-12

Professional Mariner Forum
1

Please let me know the correct way to get this ITC (dual tonnage) time to count in my favor, I would like to upgrade from 500 GRT to 1600 GRT/3000 GT (ITC), using my 499 GT (ITC) in place of the required 360 days on vessels over 100 GRT… I have been working on a research vessel 499 GT (ITC) in Brazil, at all times manned according to the ITC, STCW 95, the USCG Safe Manning Certificate, the Brazilian Safe Manning Certificate and IMO Resolution A 890 (21) of 25 November 1999. This vessel is a dual tonnage vessels and operation under the ITC tonnage of 499 GT (ITC) The way I read USCG Policy Letter 11-12 is that when it come to Mariner Credentialing, if manned according to the ITC, the ITC sea time counts in place of the (domestic) GRT(dual tonnage vessel), I understand the sea time will not count towards any unlimited license because 499 GT (ITC) is still in the class of less than 200 GRT… I have also come across some interesting information, about Proposed Rule for 46 CFR Parts 10, 11, 12, and 15 [Docket No. USCG–2004–17914] RIN 1625–AA16 Implementation of the 1995 Amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 It has a crossover for GRT to ITC for Mariner Credentialing and will sure help when it comes to stuff like this, 100 GRT/250 GT (ITC) and 150 GRT/375 GT (ITC), this will help for Mariners like me that work internationally, I don’t think this is in effect yet but I hear it might be at the first of the year… a change to the required sea time for 1600 GRT/3000 GT (ITC) is listed, and instead of the 360 days as master on vessels over 100 GTR it will change to 360 days on vessels of 150 GRT/375 GT (ITC) and you can see how this will help people like myself without the use of a Policy Letter and long explanation… Please let me know the correct way to get this ITC (dual tonnage) time to count in my favor, I would like to upgrade from 500 GRT to 1600 GRT/3000 GT (ITC), using my 499 GT (ITC) in place of the required 360 days on vessels over 100 GRT… The vessel is 85 GRT/499 GT (ITC)… Again working and manned foreign for the past 3 years and have not come back to the USA. Thanks, JW

2

All Master…

3

so basically what you are saying is that you are a 200 master with a 500 ITC wanting to upgrade your license to a 1600/3000 ITC master. using the ITC sea time from the vessel that you have been working overseas ? if so i know two people that upgraded to a 1600 ton master using ITC time from crew boats they ran overseas.

4

Yes, that is exactly what I am saying… But I already upgraded to 500 GRT… I am trying to upgrade from 500 GRT to 1600 GRT… But same concept… I cannot get my evaluator to understand what I am asking… All she says is, since the vessel has a GRT also, my time counts for the GRT… The exact opposite the Policy Letter states! Geez

5

From reading your post it appears you are a 200GT/500ITC Master And you want to upgrade to 1600GT 3000ITC Correct?

It sounds to me like you are confusing the GT ITC differences and want to blend it all together (to your advantage)

To step up from 200 to go higher tonnage you have to choose whether you want a 500GT license, or a 1600GT (leave off the ITC for now)

You qualify for the 500GT now. You need more time on vessels over 100 GT to go for the 1600GT. I believe you don’t need time as master of vessels over 100 ton though, just time spent while holding the license on vessels over 100 GT. The difference is time spent ON the license, versus just holding the license as a deckhand.

You mention the ‘proposed regulations.’ They are NOT in force yet if they are ‘proposed’ You can’t make the USCG accept this when the proposed rules are not yet in place.

6

Cappy,

  1. He said he already has a 500 ton and is trying to upgrade to 1600.

  2. According to policy letter 11-12 if his vessel was manned as a 499 gt itc vessel then he gets to use the itc to upgrade with. The problem is that the policy letter specifically says that 200 grt = 500 gt but what gt itc equals over 100 grt?

7

Reading posts 4 and his response in 5 made me wonder about the GT, ITC confusion.

8

Capt. Schmitt is correct… This is my question to you guys/gals… Is this possible, and if so, how can I get my evaluator to understand this.

9

I had the same problem a few years ago, I finally won it on appeal, but it took 11 months.
I thought with the new policy letter this would all be a moot point.
I assume you have already brought up the policy letter,and you have a current application in…'
Have you asked for a reconsideration ?

10

The problem is that the policy letter only spells out that 200 grt = 500 gt and that 1600 grt = 3000 gt. There is no guidance as to what equates to over 100 grt. Even though it seems obvious to a mariner that 499 gt should be essentially like 199 grt (ie under 200 grt but greater than 100 grt) these office guys don’t know anything beyond policy letters.

11

JW Provided you have the 500ton masters license (and sat after 2002 for the original) here is the link I found for the policy letter 11-02

http://www.uscg.mil/tvncoe/Documents/policyletters/CG543PL11-12.pdf

Now dollars to donuts. EXACTLY what does your company provided sea service letter say? It should say something like this: JW-Oceans served asXXXX aboard the XXXX of XXX GT (ITC) for 1234 days, in ITC service. (see paragraph 4 section (b) last sentence)

Usually this is a problem because of the way the seaservice letter was written. If your seaservice letter had: JW served asXXX aboardXXX of XXX GRT for 1234 days in ocean service, then a dumb evaluator would not be able to connect the dots.

Have you actually SENT the NMC the 11-12 letter from HQ with the pertinent paragraph highlighted? That may help. You trying to teach them over the phone won’t go far because they don’t trust what you are saying, they need to SEE it in writing. (And from my experience they are too lazy to find out on their own) You have to hand feed them the info. SLOOOOWWLLLYYY. So they don’t gag on it, or get insulted they couldn’t take it all at once. Or didn’t know it!

12

I had the same problem a few years ago



13

An update to all interested, after asking for reconsideration, the USCG approved my upgrade to 1600 GRT/ 3000 ITC Master Oceans from 500 GRT Master with the use of Policy Letter 11-12. In place of the 360 days as master, mate, pilot on vessels over 100 GRT I was able to use my 499 ITC.

JW-Oceans

14

[QUOTE=JW-Oceans;61142]An update to all interested, after asking for reconsideration, the USCG approved my upgrade to 1600 GRT/ 3000 ITC Master Oceans from 500 GRT Master with the use of Policy Letter 11-12. In place of the 360 days as master, mate, pilot on vessels over 100 GRT I was able to use my 499 ITC.

JW-Oceans[/QUOTE]

Excellent. Can you give us any more details?