Quantifying "three years of service" for hawsepipers

I am currently third mate on a foreign-flagged passenger vessel. I sail under a 3000 ITC ton license and am looking to upgrade to a restricted unlimited license.

My work day requires 0800 -1200 watch; 1300 - 1600 safety equipment related issues; and, 2000 - 2400 watch. Officially an eleven-hour day. I also relieve the chief mate for dinner, show up well before my scheduled watch, schedule all drills and have the usual deal with a lot of 0700 pilot stations etc… My days are easily 12 hours. All of my safety inspections are quantified time-wise on on a software program know as TITAN.

In the past officers on my boat got credit from the Coast Guard for 12-hour days on this schedule. But that was before NMC.

Has anybody had recent experience with NMC about 12-hour days? I don’t need 12-hour days as watch keeper for the “three years of service” requirement. I just want to get credit for 12 hour hawsepipe days. Any advice?

Here is the relevant portion of the CFR:

Sec. 10.407 Service requirements for third mate of ocean or near coastal steam or motor vessels of any gross tons.

(a) The minimum service or training required to qualify an applicant 

for license as third mate of ocean or near coastal steam or motor
vessels of any gross tons is:
(1) [B]Three years of service in the deck department on ocean steam or
motor vessels[/B], six months of which shall have been as able seaman,
boatswain, or quartermaster, while holding a certificate as able seaman.
Experience gained in the engine department on vessels of appropriate
tonnage may be creditable for up to three months of the service
requirements for this license; or,…

Thanks

[QUOTE=PMC;43889]I am currently third mate on a foreign-flagged passenger vessel. I sail under a 3000 ITC ton license and am looking to upgrade to a restricted unlimited license.

My work day requires 0800 -1200 watch; 1300 - 1600 safety equipment related issues; and, 2000 - 2400 watch. Officially an eleven-hour day. I also relieve the chief mate for dinner, show up well before my scheduled watch, schedule all drills and have the usual deal with a lot of 0700 pilot stations etc… My days are easily 12 hours. All of my safety inspections are quantified time-wise on on a software program know as TITAN.

In the past officers on my boat got credit from the Coast Guard for 12-hour days on this schedule. But that was before NMC.

Has anybody had recent experience with NMC about 12-hour days? I don’t need 12-hour days as watch keeper for the “three years of service” requirement. I just want to get credit for 12 hour hawsepipe days. Any advice?

Here is the relevant portion of the CFR:

Sec. 10.407 Service requirements for third mate of ocean or near coastal steam or motor vessels of any gross tons.

(a) The minimum service or training required to qualify an applicant 

for license as third mate of ocean or near coastal steam or motor
vessels of any gross tons is:
(1) [B]Three years of service in the deck department on ocean steam or
motor vessels[/B], six months of which shall have been as able seaman,
boatswain, or quartermaster, while holding a certificate as able seaman.
Experience gained in the engine department on vessels of appropriate
tonnage may be creditable for up to three months of the service
requirements for this license; or,…

Thanks[/QUOTE]

If you are on a vessel with a three watch system there is no way you can get credit for a 12 hour day.

Robert, I have heard that but can’t find anything about that in the CFRs. The duties of the safety officer on a boat are not the duties of a watch officer. I could nothing but chip paint in a chain locker for three years and become an unlimited third mate. It would seem to me that the duties of the safety officer would be recognized by the NMC as legitimate service on deck.

[QUOTE=PMC;43894]Robert, I have heard that but can’t find anything about that in the CFRs. The duties of the safety officer on a boat are not the duties of a watch officer. I could nothing but chip paint in a chain locker for three years and become an unlimited third mate. It would seem to me that the duties of the safety officer would be recognized by the NMC as legitimate service on deck.[/QUOTE]

To get a 12 hour day, you have to be on something approved for a two-watch system, and be practicing that system. Try “46 USC 8104”

[QUOTE=PMC;43894]Robert, I have heard that but can’t find anything about that in the CFRs. The duties of the safety officer on a boat are not the duties of a watch officer. I could nothing but chip paint in a chain locker for three years and become an unlimited third mate. It would seem to me that the duties of the safety officer would be recognized by the NMC as legitimate service on deck.[/QUOTE]

“Day work” on a vessel can be counted as sea service, but unless you work in the field where a two watch system is practiced and authorized, you are still stuck with only getting one days service no matter how many hours you work in various capacities.

It may be right, or wrong, But a company sea service letter is the key. How the letter is written makes all the difference. I think you need to consider your work contract. If you are ‘heavily suggested’ to work the extra 3 or 4 hours per day (to keep the company happy) then you can’t take the 12 hour day. If you are ‘required’ to work the 12 hours, then you get credit.

Therein lies the rub. Some companies take advantage of, and abuse the two/three watch system. You must understand the difference.

On a different note; these company’s membership in some industry organization does not indicate actual professional competence or diligence. Unless we take them to task and ensure the compliance they will keep being as evasive and non committal as possible.

[QUOTE=cappy208;43901]It may be right, or wrong, But a company sea service letter is the key. How the letter is written makes all the difference. I think you need to consider your work contract. If you are ‘heavily suggested’ to work the extra 3 or 4 hours per day (to keep the company happy) then you can’t take the 12 hour day. If you are ‘required’ to work the 12 hours, then you get credit.

Therein lies the rub. Some companies take advantage of, and abuse the two/three watch system. You must understand the difference.

On a different note; these company’s membership in some industry organization does not indicate actual professional competence or diligence. Unless we take them to task and ensure the compliance they will keep being as evasive and non committal as possible.[/QUOTE]

You can write what you want on any letter, but the Coast Guard will not give 12 hour days for passenger vessels.

[QUOTE=Robert;43892]If you are on a vessel with a three watch system there is no way you can get credit for a 12 hour day.[/QUOTE]

He’s right, if it’s 3-watches, you won’t get 12 hour day credit. The definition of “day” in 46 CFR 10.107 says the 12 hour credit [B][I][U]may[/U][/I][/B] be awarded if a 12-hour day is “authorized and practiced.” “Authorized” means the vessel’s manning and 46 USC 8104 allow the vessel to have two watches, and practiced means the vessel did in fact have 2 watches. If both are not present, 1.5 to 1 credit is not awarded.

It would appear that 46 USC 8104 could not apply to a foreign vessel, where more than eight hour days are required for deck officers even though there are three watches. Catch-22.

p.s. Thanks for the responses.

[QUOTE=PMC;43915]It would appear that 46 USC 8104 could not apply to a foreign vessel…[/QUOTE]

See 46 CFR 11.205(b)(3). You won’t get higher credit for foreign vessel service than you would for service under equivalent operating conditions on a U.S. vessel.

[QUOTE=jdcavo;43917]See 46 CFR 11.205(b)(3). You won’t get higher credit for foreign vessel service than you would for service under equivalent operating conditions on a U.S. vessel.[/QUOTE]

Game, set, match.