I’m a mate w/ a PIC endorsement on an ATB effectively married to an oil barge. We carry dedicated AB/tankermen who handle the cargo, and for the most part the “tug guys” don’t have much to do with the transfers at all. My captain recently renewed his license (also w/ a PIC endorsement), and without any documented recency as far as transfers or a course (46 CFR 13.120) and says the NMC kept his PIC endorsement on the license; no separate continuity, no questions asked.
I was under the impression that according to the aforementioned CFR, that you need proof of participation in two transfers in 5 years as recency for a tankerman renewal. Is there some other CFR I’m missing here… possibly a related service equivalency, or was this a glitch by the NMC to his advantage? I find the latter hard to believe, because rarely does an NMC screw up help someone.
I’m afraid I dont quite understand the meaning of the question. In reality, my inquiry stands regardless of my situation, but I post because it is of interest due to my renewal in the near future under similar circumstances… officer w/ PIC endorsement, service on a tank vessel, w/o service as a PIC (ie. no proof of transfers as stated in the CFR), who would like to keep said endorsement upon renewal. From my initial readings of the CFRs I assumed I needed transfers, but then theres an example that says maybe I don’t. That’s all. I figured that was all assumed.
[QUOTE=wafinator;47607]I’m a mate w/ a PIC endorsement on an ATB effectively married to an oil barge. We carry dedicated AB/tankermen who handle the cargo, and for the most part the “tug guys” don’t have much to do with the transfers at all.[/QUOTE]
[B][U]IMHO[/U][/B]…as mate w/[B]PIC[/B] what makes you think you “don’t have much to do with the transfers at all”??you might not be opening and closing valves but I wouldn’t express that opinion to the USCG the next time something happens…which with that attitude the probilities are fairly high that a situation is forth coming…might want to re-think that one!!
[QUOTE=seadawg;47614][B][U]IMHO[/U][/B]…as mate w/[B]PIC[/B] what makes you think you “don’t have much to do with the transfers at all”??you might not be opening and closing valves but I wouldn’t express that opinion to the USCG the next time something happens…which with that attitude the probilities are fairly high that a situation is forth coming…might want to re-think that one!![/QUOTE]
don’t get me started on that one, it has been thoroughly discussed on board and noted ashore. The barge is essentially operated as a manned barge with dedicated tankermen. And for the sake of a PIC endorsement, how do you prove recency if you are not the one signing the DOIs and not involved in operations whatsoever? That is a statement of fact as per our operating policies, not my opinion. Yes, it is silly not to involve licensed officers on a “unit” in the unit’s cargo operations, but that is how it currently is. Besides, the USCG knows full well, the AB Tankerman “Barge Captain” takes them through the barge inspections as well various vettings and such inspections are done entirely separate between tug and barge; on paper and in the company regulations the tankermen are fully in charge of all cargo ops, and the mates and/or tug crew have absolutely nothing to do with it; this is extremely clear, and yes, causes operational problems and ambiguity as far as authority. Perhaps this was done purposely to limit culpability on the part of the tug officers, I don’t know, but the policies stand as if the barge were manned and the tug were separate, despite the ATB arrangement. However, this is entirely too far off topic.
From a cynical perspective I do indeed see your point and like I said, we are well aware of the situation, but still, the question remains as per my original post. I appreciate the interest in viewing the thread, but if everyone would focus instead of getting side tracked. There are far too many threads on this forum that have ventured well beyond their intended purpose.
I just renewed and they would not let me have the tankerman asst. Put on my license as I did not have two transfers in 5 years. I think he got lucky maybe?
In the year prior to renewing, go out, take the time, spend a little energy, and ‘just do it’… Get the couple loads, discharges, and make sure your HR lady writes the sea service letter up correctly.
Yes. You DO actually have to pay attention, and actually DO something. But if you want to keep your PIC it actually takes a little energy.
It doesn’t matter what you SAY you do, or what others think, it IS what your seaservice letter documents as to what you have for experience in the past 5 years.
On the same note: If you sent in your renewal app with NO recent sea service they would NOT renew your license either! So since you have a PIC you need further proof to renew that, They don’t just ‘give’ them out!
[QUOTE=cappy208;47648]In the year prior to renewing, go out, take the time, spend a little energy, and ‘just do it’… Get the couple loads, discharges, and make sure your HR lady writes the sea service letter up correctly. [/QUOTE]
The NMC flagged my app for renewal last year for proof of discharges. One of the mates dug up a couple of DOIs with my name and e-mailed them to me. I then faxed them to the NMC. Relativley painless.
Thanks for the responses everyone, especially Mr. Cavo as always, and those with insightful details.
On an aside, I knew the CFRs and am fully capable and willing to satisfy their requirements, but was just curious due to an example I was presented with and figured I’d ask a question. If I only knew it’d end up with sweeping judgments of my character and essentially being called a lazy, inattentive mate with a bad attitude and disregard for safety, ha. I guess its poor timing to ask you fellas to be references…?
No comments or judgments on you. Just an example that EVERYONE who is renewing must ensure their HR dept writes the seaservice letter correctly, and prior to that you have gotten the requisite re-certifications done. E.G. Loads and discharges, Physical, sea time, vessel info, and all typed in the correct format on the company letterhead.
You got the word that you DON’T have to be signed on the DOI for the experience to count, but someone who WAS in charge must certify it so the HR can write it. (and sign it)
I’ll bet your Captains’ renewal sea service letter was written differently than yours. I would bet if you could get a look at it you would see why he ‘got it’ and you didn’t.
No aspersions on your qualifications or experience. We all need reminding how to do… sometimes! And others on this blog aren’t aware that in some cases (like yours) Mates on some ATB’s don’t handle cargo, and are pretty much out of that part of the business. The Tankerman/PIC Barge is in charge and signs the DOI in some cases.
Hello,
This is my first post to the forum as I found this thread while searching for answers to the same topic. I have held a tankerman pic dl and wheelhouse license for over 20 yrs. My first tankerman ticket was grade B and all lower, then took the courses and upgraded to PIC back in the mid 90’s. I am now renewing both, and ran into a problem with my recency. I have been in the wheelhouse pretty much all of the last five years. When I took this job, I asked to do transfers refueling the vessels (tugs) so I could get the time in and get a letter. I turned in a letter to NMC with my renewal showing I had more than 3 yrs and proof of 22 transfers in the last five years, transfering fuel over water from truck to vessel and vessel to vessel. I also get paid extra for this. The NMC turned this down because they said it was bunkering and not cargo, so I can’t use thses transfers.
My question is, on the NMC webpage and in the CFR’s, it states you can use 3 years closely related service or employment in place of the transfers. What do they consider “closely related”? I also am a designated examiner for towing, I tow oil barges occasionally, and I do all oil spill drills and QI notification drills, and I evaluate others doing the same.
Should I appeal their decision?
[QUOTE=jdcavo;47668]You need to either show “participation” in two transfers (not necessarily serving as the PIC) or re-take the tankerman course. See 36 CFR 13.120[/QUOTE]
Excuse me Sir, have a problem maybe you could help, I sail Qmed ,and I’m trying to upgrade to 4000 hp DDE, I have 167 12hr days that my evaluater wont recognize. She say policy states that my vessel would have to have three watch system to be credited, frankly Sir I dont think any supply in the GOM has this set up. Is there any thing i could do , how could i work 12hr days and not be credited for them? Thanks in advance for your reply!
[QUOTE=newqmed;47840] policy states that my vessel would have to have three watch system [/QUOTE]
Need more info. What DOES your vessel COD, COI state for manning levels? How many engineers are required?
If there is no special conditions stated on manning the vessel then she is wrong about the manning. You need to show her the proof in writing what the manning of the vessel is from the certificate.
[QUOTE=captmsr;47828] I asked to do transfers refueling the vessels (tugs) so I could get the time in and get a letter. [/QUOTE]
It doesn’t matter what type vessel (or tank, drum, vat or pit you are on) unless the vessel you are on is certificated (by the USCG) to carry the product grade you are being ‘renewed’ for, it doesn’t count. Uninspected towing vessels have not come upon this fully yet. They have recently made the engineers PIC tugboat ‘company approved’ endorsements. (But this is NOT acceptable at any other company, nor is it recognized by the USCG anywhere else) You could argue that the COD says the fuel type is Diesel, and you have 22 copies of the DOI’s; but i doubt that would fly.
Yeah, I know all about it. I lost my Tankerman’s endorsement because I just gave up on going out on deck, and didn’t want to have to pay the course fee. It still irks me when I have to go out and show a 15 year barge PIC how to get suction when they loose it, and how to repack a deep well pump. But hey, I am not credentialed anymore to sign the DOI. Good thing too. There’s enough liability running around here lately!
If you really want to renew, why not call around to some companies, and explain to them what you need. Go visit a barge loading and discharging and ‘participate’ that way. You may have to really dig around to find one though, since in this twic era some terminals won’t let you in from a phone call.
[QUOTE=captmsr;47828]
My question is, on the NMC webpage and in the CFR’s, it states you can use 3 years closely related service or employment in place of the transfers. What do they consider “closely related”? [/QUOTE]
That stumped me at first as well, but have come to the conclusion that it is 2 transfers,[I] in addition to[/I] any of the other choices they give you. In other words, the “closely related service/employment” can only substitute for 360 days of service OR open book exam OR refresher course – not the transfers, they pair that requirement with the “AND”. Poor word processor formatting really. The CFRs backed by the opinions and experiences expressed here confirm that 2 transfers is a steadfast requirement. Their rules about what is a transfer for your purpose however, I leave to someone else.
Thanks for the replies and the help. I am just going to put it in continuity until I can do some transfers.
I did find this in the CFR’s if anyone is interested in their definitions of transfers and participation.
Transfer means any movement of
dangerous liquid or liquefied gas as
cargo in bulk or as cargo residue to,
from, or within a vessel by means of
pumping, gravitation, or displacement.
Section 13.127 describes what qualifies
as participation in a creditable transfer
[I]Participation, [/I]when used with regard
to the service on transfers required for
tankerman by § 13.120, 13.203, or 13.303,
means either actual participation in
the transfers or close observation of
how the transfers are conducted and
supervised.