I’m renewing my credentials and the NMC is telling me I’m short on Sea Service. They are counting back from November 2021 to November 2016, and CFR46/10.227 says “the previous five years”. In the past it was my understanding that NMC accepted sea service for the entirety of those 5 years. In my case that would mean that all of 2016 counts from January 1st to December 31st. This would alleviate me of taking BT refresher, PSC Refresher, and AFF refresher. I have all ready taken BT and AFF reval courses believing my sea service to be sufficient.
Can anyone point me to a CFR contradicting or supporting NMC’s interpretation of the above mentioned CFR?
It’s 46 CFR 10.107 Definitions. If you look at that CFR you cited, it defines the term “Year” as it applies to that regulation:
Year means 360 days for the purpose of complying with the service requirements of this subchapter.
Therefore “5 Years” is equal to 1800 days. 1800 days from Nov 2021 would put you around Nov 2016.
If that were the case you’d be double-dipping on the sea time. Since a credential is only valid for 5 years (~1800 days) from when it was issued, that means that any sea time before that would have been on the previous credential. You are essentially asking to re-use sea time you already used for your current credential.
Thanks for the reply, and that’s pretty clear. In the 15 years I’ve been sailing, sea service hasn’t been an issue. But a recent pivot to a different career in the maritime industry and the pandemic has left me a bit short on sea service it would appear. At least of the “on a vessel that is required to hold regular drills” to qualify for STCW variety. Looks like I’ll be taking those courses.