[QUOTE=injunear;51503]Unless the rules have changed recently, licensed engineers are required on tugs over 200gt. Inland tugs require licensed engineers over 300gt.[/QUOTE]Over 200 GT only requires a licensed engineer when the tug goes past the line of demarcation. Tugs over 300GT are in a whole different ballpark altogether since they become covered by a COI.
Deven: Is ALL your seatime aboard this MODU the time you are using for your application? Do you have other time?
You keep reasoning that AB time, or the qualifications found elsewhere in the CFR should apply to QMED… They don’t. I understand your logic, but the written paragraphs provided by anchorman and others are pretty clearcut on how they apply (or don’t in your case) to the 12 hour day. If you had other time on UTV’s or other vessels, then that may be creditable, but just your straight QMED time on the MODU isn’t.
[QUOTE=cappy208;51515]Deven: Is ALL your seatime aboard this MODU the time you are using for your application? Do you have other time?
You keep reasoning that AB time, or the qualifications found elsewhere in the CFR should apply to QMED… They don’t. I understand your logic, but the written paragraphs provided by anchorman and others are pretty clearcut on how they apply (or don’t in your case) to the 12 hour day. If you had other time on UTV’s or other vessels, then that may be creditable, but just your straight QMED time on the MODU isn’t.[/QUOTE]
All the time on the MODU. I agree that how they apply is clearcut in the past 6 months. Before that, not so much.
Isn’t it crazy though that if it were the case I was employed on a UTV, that time would count for more than my work on a 30k hp vessel with probably 100 times the machinery?
[QUOTE=deven;51511]That is really the context of the argument I will make in my appeal. My point about the laws was to basically say that since it is based on an interpretation of the law, it wasn’t really unlawful in the first place. …![/QUOTE]
“My interpretation is different than yours, so you should use mine.” That’s what you’re going with??? Good luck. Maybe Don Hamrick can help you write up your appeal.
It sounds like you are fighting an insurmountable battle. Regardless of who and how seatime was allowed, they aren’t letting it slide anymore.
The precedent has been set each time they have made more stringent qualifications, OR realized they were making a mistake in the process.
I wish I could go back and qualify on old past requirements just because others did too. But it isn’t allowed. You just got caught in the muddle/ middle now!
Not that it matters, but I was caught in a similar predicament about 10 years ago. I applied for pilotage on vessels that when I did my pilot observer trips were 2200 GT. But in the meantime the company readmeasured them to 1500±GT. I was denied because at application they are under 1600_GT, ( the threshold for acceptance as unlimited pilot trips) I surely wish I had run in, right after doing the trips and applied. But, I snoozed, and lost the opportunity.
Duplicate…
[QUOTE=deven;51516]Isn’t it crazy though that if it were the case I was employed on a UTV, that time would count for more than my work on a 30k hp vessel with probably 100 times the machinery?[/QUOTE]
Actually, you could not get 1.5 day credit on a UTV as an oiler either. Oilers cannot work 12 hour days on any vessel. What cappy pointed out is that tugs do not carry oilers so that is never an issue. (Which is another reason why you cannot get 1.5 day sea time on a UTV as an oiler, you cannot work as an oiler on one… 
)
[QUOTE=deven;51516]Isn’t it crazy though that if it were the case I was employed on a UTV, that time would count for more than my work on a 30k hp vessel with probably 100 times the machinery?[/QUOTE]
Actually, you could not get 1.5 day credit on a UTV as an oiler either. Oilers cannot work 12 hour days on any vessel. What cappy pointed out is that tugs do not carry oilers so that is never an issue. (Which is another reason why you cannot get 1.5 day sea time on a UTV as an oiler, you cannot work as an oiler on one… )
Yes You CAN work as an engineer on a UTV with a QMED, and have creditable sea service at 1.5 days to 1! Just because someone works does NOT mean they have to work on the authority of their license, or that working ‘below’ their license is not creditable.
That would be like saying an unlimited master being a skipper of a UTV would not get 1,5 to one seatime! of course he would!
The difference is working in the capacity of your license, and simply working in the engineroom department. When upgrading some of the upgrading a portion of seatime must meet certain parameters ( HP, tonnage, ocean or NC route) some other portion of seatime can be on vessels of ‘lesser’ parameters. Deven only has QMED time on one type vessel so it doesn’t apply to him. Until he stated that, I was (admittedly in a backwards way) trying to get him to reveal any other seatime he may have had.
[QUOTE=Archimedes;51524]“My interpretation is different than yours, so you should use mine.” That’s what you’re going with??? Good luck. Maybe Don Hamrick can help you write up your appeal.[/QUOTE]
Where in Maine are you from?
I’m saying that the Coast Guard changed its interpretation, it was never illegal. I’m not saying “use my interpretation” I’m saying use your own interpretation that was used extensively for decades, and if you’re going to change it, do not do so retroactively at the expense of the mariner. Like I said before, I’d be fine with them changing the policy at a certain point, but to take away sea time before that point and sea time that was already approved through other upgrades is ridiculous. Way to win on sarcasm though.
Does anyone know of any other STCW countries that follow this 8 hour day logic like the Coast Guard does?
[QUOTE=cappy208;51542]Yes You CAN work as an engineer on a UTV with a QMED, and have creditable sea service at 1.5 days to 1! Just because someone works does NOT mean they have to work on the authority of their license, or that working ‘below’ their license is not creditable.[/QUOTE]
I never said he could not work as an engineer on a UTV and get 1.5 days to 1 sea time credit. I said he could not work as an OILER on a UTV and get 1.5 days to 1 sea time because regardless of vessel an oiler CANNOT work 12 hour days. I also said that isn’t an issue since UTVs don’t even carry oilers… (In case you still don’t get it, “oiler” in this context refers to the job position, not his rating or license.)
[QUOTE=deven;51549]I’m saying that the Coast Guard changed its interpretation, it was never illegal.[/QUOTE]
Um, yes it is illegal and it apparently has been for a while. The RECs just never caught that fact and the NMC just recently figured it out. They did not change their interpretation, they began following the law.
If that’s true, then there are hundreds of mariners sailing in violation of the law as we speak.
Before all of this 12 hour thing with watches, the Coast Guard came up with a different reason to not allow 12 hour days, on MODUs, which I’m pretty sure has been documented on here before. The whole conventional vessel thing. They used the same exact logic that you said, that the law wasn’t being followed and now it is, until they were proven wrong, then they allowed 12 hour days again for a while, then moved on to this new interpretation of the 1940s law on watches.