Renewing Unlimited License w/ Sea Time Under 100 GT

Hello, this is my first post…

I have been thinking about joining the towing industry after working on unlimited vessels for the past six years. I just got my Chief Mate’s license and 1600 GT Master.

My question: If I work on towing vessels under 100 GT, and it comes time to renew my MMC, will I be able to renew my C/M Unlimited and 1600 Master?

I reviewed the renewal checklist and associated CFR (46 CFR 10.227), and it doesn’t mention tonnage requirements for renewal. It just says “present evidence of at least one year of sea service during the past five years.”

So, I contacted the NMC for clarification, and this is what they said:

[I]“In order for your time to be accepted towards renewal you must be working within the scope of your current credential. Time gained while working outside of this may not be accepted.”

[/I][I][B]May [/B][/I]not be accepted??

Does anyone have any experience with this or know someone who has?

Thank you

You can renew with no seatime. You’ll just have to take an open book take-home exam and BST refresher

You should be able to renew with sea time as an OS. It is within the scope of your credentials. +1 to having to do the BST and any other necessary STCW renewal requirements for your highest officer endorsement. I know this has been touched on in a old thread but could not find it. JD Cavo could probably weigh in with a better answer.

I would lean on the premise that regardless of tonnage you’re still performing chief mate or masters duties. No basis for my opinion legally but that’s what I’d argue.

I’ve renewed an unlimited masters license twice with 360 days of service with nearly all time submitted on vessels under 100 tons using the small vessel sea service form. The first time I had to take a take home test for my QMED endorsements because I had no engine time, but the deck time on under 100 ton vessels all counted fine.