I had an old chief engineer that told me there was a clause in the CFR’s that said something about sea time on research vessels being able to be counted as time and a half as far as sea days went. He said some CG evaluators would give them to you with that time and a half multiplier and some would not, based on their interpretation of the clause.
…Is this a real thing? Anyone got any experiences related to this?
Thanks.
from cfr 46 10.232 (2) 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 11⁄2 days of service.
I have worked on research vessels and my time was counted as straight time
Took a wander through the ol’ CFRs to see if there was something new or different but the only thing that would apply there is what @Ctony said. I’d be more worried about getting hit with CFR 46 10.232 (e) which talks about 3 dockside days for 1 sea day for service on a vessel that does not regularly get underway. I’ve been lucky enough to only work on research ships with constant schedules but I know that many of them sit moored for long periods of time so watch out.
Research vessels are not included in the types of vessels allowed to work a 12 hour watch that would get you time and a half by 46 U.S.C. 8104 and 46 CFR 15.705.
Good luck
I have worked research ships as well and sea time was counted using 12hr work days therefore giving me 1.5days per 12 hr day.
Which research ship were you working on?
NOAA ships
If the sea time letter is written for a 12 hour day one will likely receive 1.5 days of sea time from the NMC, although you might need to point out that it says 12 hours.
That’s NOT actually allowed, but the evaluators just see the 12 hours and don’t know any better.
Additionally, you’re NOT allowed to be standing 12 hour watches on research vessels so your sea time letter shouldn’t be saying such, whoever signs it is lying under oath on a federal form.
Are you sure about that? I’m not. NOAA vessels are government vessels and the provisions you are thinking of may not apply. Unfortunately, I don’t have the time to research it.
Also, the requirement is for two watches to be “authorized and practiced.” Practiced is obvious, but “authorized” may not be. If the Coast Guard issued a COI that only calls for a Master and only one mate, you can make a very compelling argument that two watches were authorized.
Good point. I’ll make a follow-up with better wording.
12 hour WORK DAYS don’t qualify one for 1.5 sea time credit, only 12 hours of WATCH does.
You may be right, but
“46 CFR 10.232 h) (2) On vessels authorized by 46 U.S.C. 8104 and 46 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.”
I just haven’t found the caveat that public vessels also fall into the list of authorized vessels, which they are not listed.
46 CFR 10.232(d)(6):
Service gained in a civilian capacity as commanding officer, master, mate, engineer, or pilot, etc., of any vessel owned and operated by the United States, in any service in which a license or officer endorsement as master, mate, engineer, or pilot was not required at the time of such service, will be evaluated by the Coast Guard for a determination of equivalence.
Coast Guard took my time with NOAA at day for day. Sea time in the USCG was taken as 60%. Of course that was 30+ years ago.
Because on a vessel authorized for only two watches a “12 hour work day” can be assumed to be 12 hours of watch. See the part of the definition of a day in 46 CFR that you cut out if your quote:
46 CFR 10.232
(h) Day. (1) Except as noted otherwise, for the purpose of calculating service in this subchapter, a day is equal to 8 hours of watchstanding or day-working not to include overtime.
If you actually worked two watches, like on a tug, that’s one thing, but just working a twelve hour day doesn’t count.
Does it only count if you stand the whole watch or do they deduct hours when you sit down for watch?
Haha.
I am in agreement with you regarding research vessels that are inspected, but there seems to be a gray area with government run research vessels.
It comes down to how the vessel was operated then.
Did any mate or deckhand stand 12 hours of navigational watch?
Were you REQUIRED to work 12 hours or was it 8 hours plus optional overtime?
There’s no sitting down on watch on a govt vessel if you’re an AB steering. 