Hello, Maybe you can help.We are delivering a 190gt Tug w two barges from Texas to Lagos Nigeria, with stops in St.Croix and Cape Verde.
The question is this the Master Capt is a 500gt w M of tow of oceans, 2 capts have 100ton masters all 3 have STCW. The other Capt is a 50ton w 100 ton master pending and no STCW and the 2 deck hands are unlicensed w no stcw.
Is there an issue with this,as its a not for hire delivery one way to Lagos are having the 3 with stcw and 3 w/o ok.
Thanks
Captainmas - First of all, what does the COI list as proper manning? Capt/Mate/Eng/AB? First glance at what your wrote, it appears that you are sailing short. 1 500t Master and the other officers are 100t or less. I would think that you need to have another officer with at least a 200t mate w/towing. But, again that depends on what your COI states.
Below is from 46 CFR Part 15.1103:
Subpart J_Vessels Subject to Requirements of STCW
Sec. 15.1103 Employment and service within restrictions of a license,
document, and STCW endorsement or of a certificate of training.
(a) On board a seagoing vessel operating beyond the Boundary Line,
no person may employ or engage any person to serve, and no person may
serve, in a position requiring a person to hold an STCW endorsement,
including master, chief mate, chief engineer, second engineer, officer
of the navigational or engineering watch, or radio operator, unless the
person serving holds an appropriate, valid STCW certificate or
endorsement issued in accordance with part 10 or 12 of this chapter.
(b) On board a seagoing vessel of [B]500 GT or more[/B] as determined under the International Tonnage Convention, no person may employ or engage any person to serve, and no person may serve, as a rating forming part of the navigational watch, except for training, unless the person serving holds an appropriate, valid STCW certificate or endorsement issued in accordance with part 12 of this chapter.
(c) After January 31, 2002, [B]on board a seagoing vessel driven by
main propulsion machinery of 750 kW [1,000 hp] propulsion power or more, no person may employ or engage any person to serve, and no person may serve, in a rating forming part of a watch in a manned engine-room, nor may any person be designated to perform duties in a periodically unmanned engine-room, except for training or for the performance of duties of an unskilled nature, unless the person serving holds an appropriate, valid STCW certificate or endorsement issued in accordance with part 12 of this chapter.[/B]
I[/I] REFERS TO RO-RO (so I did not include it)
(e) You must hold documentary evidence to show you meet the
requirements of Sec. 10.1105 (if licensed) or Sec. 12.35-5 (if
unlicensed) of this chapter if you are a master or crewmember on board a
vessel that is–
(1) Subject to the STCW;
(2) Not a Ro-Ro passenger ship; and
(3) Carrying more than 12 passengers when on an international
voyage.
(f) After January 31, 2002, on board a seagoing vessel required to
comply with provisions of the Global Maritime Distress and Safety System
(GMDSS) in Chapter IV of SOLAS, no person may employ or engage any
person to serve, and no person may serve, as the master, chief mate, or
officer of the navigational watch, unless the person serving holds the
appropriate certificate for operator of radio in GMDSS.
I would say that there is an issue even though it is not for hire, but you are on hire while delivering the barages. I am not an expert on manning requirements and my statement is based on what I read in the CFR’s. If you have any question as to being properly manned, I would call the MSU in Galveston or Port Aurthur (depending where you are) and ask them to be 100% sure.
Good luck - Safe Sailing,
Capt Brian
Thanks for the input, we’re in the process of checking that now, as far as manning, the first reply from the USCG was we were ok, because of being under 200GT. Where the issue came up is making a fuel stop in Cape Verde and their requirments for the STCW, no one is clear on the answer and before we take the job we need to clear it up, don’t need and issue after we leave US waters
Regards,
Capt. Mike