Steersman question

I have enough total time to get my steersman endorsement. I need 360 days on a towing vessel. My question is in the CFRs are those 8 hour days or 12. I believe it is 8 hour days and I have been working 12 hour days. Think I am getting close if I choose to go the brown water route.

46 CFR 10.107 defines a “Day” as:

Day means, for the purpose of complying with the service requirements of this subchapter, 8 hours of watchstanding or day-working not to include overtime. On vessels authorized by 46 U.S.C. 8104 and 46 CFR 15.705, to operate a two-watch system, a 12-hour working day may be creditable as 1 1/2 days
of service. On vessels of less than 100 GRT, a day is considered as 8 hours unless the Coast Guard determines that the vessel’s operating schedule makes this criteria inappropriate; in no case will this period be less than 4 hours…

Referencing 46 CFR 15.705, you’ll see that towing vessels are listed as one of the vessel types that are permitted to credit 1 1/2 day for a 12 hour day worked.

This means you will only need to acquire 240 “12-hour” days to meet the 360 “8-hour” day requirement. Of course, you’ll need to submit your seatime for evaluation. If you had any trouble getting your service credited for 1 1/2 days, I would quote the above mentioned Sections from 46 CFR and ask why it doesn’t apply to your time.

This is all assuming the vessel you acquired the service on was not required to split the watch three ways as per the COI, and the voyages you sailed for were less than 600nm.