STCW II/3 OICNW Less than 500 GT Oceans

Please help me decode something here. Requirements for STCW OICNW are governed by multiple CFRs:
OICNW 500 GT or more is governed by 46 CFR 11.309
OICNW less than 500 GT Oceans is governed by 46 CFR 11.319
OICNW less than 500 GT NC is governed 46 CFR 11.321

For 500 GT NC, sea service required is 720 days - none of it required under the supervision of an officer holding an STCW endorsement.

For greater than 500 GT, 1080 days and you need to provide evidence of having performed, during the required seagoing service, bridge watchkeeping duties under the supervision of an officer holding the STCW endorsement as master, chief mate, second mate, or OICNW, for a period of not less than 6 months.

But for OICNW 500 GT OCEAN, the requirement is 1080 days AND provide evidence of having performed during the required seagoing service, bridge watchkeeping duties, under the supervision of an officer holding the STCW endorsement as master, chief mate, or OICNW, for a period of not less than 6 months. The Coast Guard will accept service on vessels as boatswain, able seaman, or quartermaster while holding the appropriate deck watchkeeping rating endorsement, which may be accepted on a two-for-one basis to a maximum allowable substitution of 3 months (6 months of experience equals 3 months of creditable service);

The bit in bold italics has me confused - and note that this wording does not appear in the unlimited option. If two-for-one time is granted up to 3 months for serving as a rating (boatswain, AS, or quartermaster), what endorsement does CG expect to be held for the other 3 months?

Do they expect the remaining service to be done under an officer endorsement? How is that possible if OICNW is the bottom rung of the ladder for these endorsements?

No one has any thoughts on this? @jdcavo, I’m interested in why you think that language is there for the limited OICNW but not the unlimited.

If I knew I would have answered when you asked this 2 years ago.

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Well, I guess it has been nagging me for two years now. No wonder I can’t sleep well at night.

I’m scratching my head wondering how anybody is going to be able to hawsepipe in the future between these crazy STCW regs that don’t agree with themselves even within one section (tables don’t match with paragraphs), massive training course requirements, and the upcoming deadline where assessments will have to be completed by QAs, of which no one wants to be one.

That I remembered it from 2 years ago indicates we’re aware of this specific issue. While this particular part may be a problem, is this purely hypothetical? Remedial action would have greater urgency if it wasn’t hypothetical. The QA issue has some urgency.

As far as being kept awake at night, I lose sleep pondering is a hot dog a sandwich?

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No, this isn’t purely hypothetical. I’m putting forth the question because I do not currently have OICNW as I have never sailed on anything that requires STCW. I have put off the additional burden of getting STCW endorsements long enough that I’ve missed all opportunities of grandfathering.

But the urgency now is driven by the upcoming end to the waiver for QAs at the end of this year. I think if NMC follows through with their plan to require only QAs sign off on assessments, it will very likely mean 99% of future assessments will be coming from instructors and paid courses rather than OTJ demonstration of skills.

So now is a excellent time for everyone to make sure they have all STCW endorsements they are entitled to.

Only when the dog is in a bun?
https://www.hot-dog.org/

The frustrating thing as that 90% of the companies and 90% of the USCG sector staff don’t know the requirements.

An ocean license is required for voyages in Foreign waters (except Canada), but few people seem to know this.

A STCW endorsement II/2 , II/1, or II/3, (as the case may be) is required for a foreign voyage (except Canada), but no one seems to know this.

The average tugboat company, and average tugboat Captain, think that anyone who has taken a 5 day BT course “has STCW.”

Tug companies send guys without Oceans or STCW on foreign voyages, including long voyages through the Panama Canal all the time. Nobody does anything about it.

This has devalued STCW to the point that I regret wasting my time and money getting STCW II/2.

Same thing with USCG Medical Cards. Owners and the USCG local staff think that the five year National endorsement is the only thing that matters.

Awhile ago I got a call from one of the more knowledgeable owners asking if I would make a foreign trip because his Captain had a medical card problem (the STCW section was expired, and he had some medical issues). But someone at Sector Seattle told the owner that didn’t matter, Master of Towing is a national endorsement, so the five year national section of the Medical Card was the only thing that mattered. There went that lucrative and interesting job.

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From that link: “See a video showing how hot dogs are made.” No thanks. I don’t need to. I have seen how regulations are made.

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Fair enough. I’m not sure how quickly or if a change can be made. Some administrations are loath to any sort of policy or regulation changes, and there is usually a temporary suspension of new policy and regulations when there is a change in administrations.