I have an ongoing problem in regards to sea time calculation for the vessel I work on. It is a Dynamically Positioned Column Stabilized Mobile Offshore Drilling Unit the West Sirius. IMO# 8768402, GT 30,326, NT 9,070, HP 52,224, Panamanian Flagged. We are held on location with the sole use of our thrusters. Even when we are drilling we are officially underway 24 hours a day.
<table border=“0” cellpadding=“0” cellspacing=“0”><tbody><tr><td style=“font-family: inherit; font-style: inherit; font-variant: inherit; font-weight: inherit; font-size: inherit; line-height: inherit; font-size-adjust: inherit; font-stretch: inherit;” valign=“top”><style> <!-- #yiv420291948 _filtered #yiv420291948 {font-family:“Angsana New”;panose-1:2 2 6 3 5 4 5 2 3 4;} _filtered #yiv420291948 {font-family:“Cambria Math”;panose-1:2 4 5 3 5 4 6 3 2 4;} #yiv420291948 #yiv420291948 p.MsoNormal, #yiv420291948 li.MsoNormal, #yiv420291948 div.MsoNormal {margin:0in;margin-bottom:.0001pt;font-size:12.0pt;font-family:“serif”;} #yiv420291948 .MsoChpDefault {font-size:10.0pt;} _filtered #yiv420291948 {margin:1.0in 1.0in 1.0in 1.0in;} #yiv420291948 div.Section1 {} --> </style>On vessels where a 12 hour working day is authorized and practiced, such as on a six-on, six-off watch schedule, each work day [B]may[/B] be creditable as one and one half days of service.</td></tr></tbody></table>
We do work a 2 watch system 12 hours per day. I have read and referenced all CFR’s, but there is no differentiation between a normal moored MODU and a Dynamically Positioned MODU. I know in the past that service on these types of vessel was credited for 1.5 days for each day worked. I think that our vessel is being confused with moored MODU’s. Any thoughts?
My question is has anyone here experienced this in the past and how was the issue resolved? I wrote an e-mail to NMC West Virginia for verification, but an engineer onboard had his reconsideration for his upgrade to 2AE denied due to not enough sea days, because of the 8 hour calculation versus the 12 hour calculation. The letter was from a Lt. Commander, Deputy Chief of mariner evaluations division. So I am sure he thoroughly investigated the application and it is highly unlikely that he will budge from this decision. From everything I have read, we will only get 8 hour days in the future.
46 CFR 10.227
46 CFR 10.107
46 CFR 11.211