Sea time on own commercial fishing boat

I owned my own commercial fishing boat from 08 to 16. I fished it in the pacific ocean off the west coast, past the colregs demarcation line up to 80 miles out. I now have qmed any rating, but have not used any of my time on my boat as well as a small gillnetter I worked on in my youth.
1 Can I count my sea time on my own boat?
2 Can I count the days I worked on it at the dock as engineering sea time? (many days of work before it was ready)
3 I operated the boat by myself, am I forced to evenly split my sea time away from the dock Deck/Eng?
4 How is my time calculated if I’m operating the boat alone 24hr? Do I only get 12hr a day?
5 the boat was documented 23 gross ton, 120 hp, and fishery endorsed, if I end up with split time away from dock, will the deck time be good towards 25T master? I’m thinking the eng time will only be basic time that I can count with my 180 on my qmed for a dde 1000? would this time be countable towards my 3rd AE? I know it wont count for the 18 months as qmed, but maybe for the other 18?
6 I can count any sea time after I turned 16, so I would have a couple seasons in 83 84, If I have the boat owner document it as 12hr deck/eng can I use this time for upgrades licenses as long as its not being used as recency of 5 years of less?
7 Can I count time where I assisted my dad giving sailing lessons?

I did look over this but it doesn’t directly answer my #2,3,4

If I participated in a fueling of a ferry boat, 9000+gal , does that count as a Load for the PIC requirements? does the fuel hose have to go over the water to count? Some ferries are fueled by a fuel truck driving on, gravity feed into tanks.

Thanks for any help!!!

I don’t think you’d be forced to split your time between deck and engine. You may not even be about to get Engineering time on that boat at all, but I can’t say for sure. You should be able to use 23 GRT time for larger than a 25 ton license, ask for a 100 ton and see what the evaluator says.

You cannot use fueling evolutions for a Tankerman PIC endorsement.

The answers to many, if not all, of your questions are in the marine safety manual Volume III:,%20VOLUME%20III,%20MARINE%20INDUSTRY%20PERSONNEL,%20COMDTINST%20M16000.8B

See page A12-4 and Page A16-6 for engineer clarifications

It won’t count. It has to be a load or discharge of cargo to/from a tank ship or tank barge. See 46 CFR 13.203(b) and/or 46 CFR 13.303(b).


I looked at that before I posted the questions. This part: on A12-14 “To be
creditable toward DDE, the service must have been as a full time engineer in an operating
engine room. OCMIs may accept service on vessels less than 100 gross tons provided the
vessel has a “walk in” engine room with an engineering plant comparable to vessels over
100 gross tons (e.g., electrical generators and other auxiliaries independent of the main

also this on A12-2
Creditable Service.

  1. Minimum Vessel Size.
    All service must be on vessels of at least 100 gross tons. This is consistent with the
    requirements for ratings as a qualified member of the engine department. See section
    12.C.8 for exceptions for designated duty engineers.

Q: So what is a “walk in engine room”? If I was to operate a charter boat with a COI (obviously without any paying passengers) how much head room is walk in? if they’re steps? at what angle is a ladder steps? aren’t all steps ladder ways on a ship? the walk in engine room part is in equivalent to a 100T vessel including auxiliaries for ships power separate from propulsion main… etc I also heard that the boat has to be 1000HP?

I posted because the safety manual was slightly vague. Is it 100T, or “like” 100T?

Should I call Grossetti Licensing Consulting or ?

considering the inconsistency and varying interpretations amongst the evaluators at the NMC many swear by hiring a licensing consultant.

In my opinion, a walk-in engine room would be an engineering space you literally walk in to thru a bulkhead penetration, which would be different than say on a small vessel that has a deck hatch with a short ladder.

DDE tickets are based on # of days serving in an engine room, not horsepower. the higher level licenses horsepower ratings are based on a hp calculation of vessels hp served.

100 gross tons can be a significant difference from 100 gross registered tons, best to know which term is being used as a guideline.

Yes I’m all about a good licensing consultant, who? I emailed Gossetti and he doesn’t deal with the small fry stuff, I offered to pay whatever but no response.

Just submit it and see what happens. If you meet the criteria on the checklist for the endorsement you’re going for then submit it.

few years ago when I was upgrading I had a great consultant…however he has passed.

I do have some friends who use jls maritime consultants in san diego. google that to get the number. jewel used to work at the long beach REC way back when and she is knowledgeable.

use the search function on the forum here…there have been other consultants mentioned in the past here.

search gcaptain and google for “USCG license consultants”

The MSM (and NVICs and policy letters) are guidance, not binding regulation. As is explained in the “disclaimer” of every policy document, alternative approaches will be considered.

The following is from a 2014 appeal of a mariner who was applying for QMED, the appeal was granted:

…this requirement in the MSM is only an example of service that would be acceptable, it cannot be interpreted as a statement of the only service that can be acceptable. Moreover, there is no regulation that would require you to provide service in an engine room comparable to that of a 100 GRT vessel or any regulation that an engineroom must have a “walk in” design to qualify for QMED-Oiler.

As noted, this was for QMED so it is not necessarily entirely applicable to DDE, but it is still relevant to your situation.

The requirement for DDE is for service as QMED or an equivalent position. You should provide enough information to support that your service was equivalent to QMED,


Why don’t you give us more details about the boat?

I doubt they’d be likely to give you DDE time on a small vessel with a 200 HP diesel and nothing else but if the machinery was not complex then maybe you’d have a valid argument.

I gave what I had. Would nothing have been better?

  1. You didn’t give any details about his boat.
  2. I doubt you know anything more than he’s said so far, that it’s 23 GRT.
  3. I wasn’t talking to you.

Holly Chetta (license consultant) should be able to help as I believe she has experience with clients using such time:

Holly Chetta
President and Owner at Mariner’s World Central

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All that time baiting traps counts as engine time? Was I a sternman or C/E?

We don’t use or have “traps” in the Pacific. We use pots. Similar in function but not in design because of great differences of the environment they are used in. A New England style lobster trap would likely be pushed by tidal currents across the sea floor faster then the crabs could move. I fished Tuna on my troller, I trolled at boat speed with 12 lines out, a jig on each, for hours. Sometimes I’d have lots of them on the lines, other times was steering looking for birds water temp changes etc. to find them. I operated the boat solo, everything to keep it operating (eng) was me, everything to navigate it was me. Since you sound like your on the East Coast, If a lobster boatman had run a 45 foot 25GT boat with a 250Hp (typical of lobster boats) by themselves, they might have the same question. Thank you for your input.

“Lobster pots” was how they were called in Maine when I was a kid in the fifties. I bet they still are.

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How would I look this case up? This sounds very similar. Was there a license consultant handling it? I’d like to get in contact with them. Gossetti wasn’t interested in my situation so I’ll try everyone else. Have been searching gcaptian threads. From the quoted text it sounds like even if a boat is small, if it has main and gen set, and all the typical systems but small…it would count engineering? However, I have QMED any rating, so I don’t need time to qualify for that. Any eng time I think can be added to my 180 to gain DDE? so my past time operating the boat, if any can be engine would get me there for dde now. In the future I want a boat that eng time will be counted as QMED time. I want time to qualify AS qmed in the future so I can get AE 3rd.

Thanks for the response!

Yes, and they still are, but working on the back deck as a deck hand would not meet any interpretation as eng time.