Tug Sea Time Question

First off, sorry for what’s most likely the most over posted topic.

I am currently 42 days away from being able to submit for my second mate unlimited. I worked on a tug boat as an AB working 12 hour watches for 44 days. My question is this. Having worked 12 watches as an AB, could the 2 for 1(days) be excused for 1 for 1? I called the NMC and they said it was up to the evaluator, but I was just wondering if anyone has submitted anything like this before, and received 1 for 1.

I should add, the GRT for the tugs I was on are: 114 and 189.

Any input is much appreciated!

Nothing is “up to the evaluator.” They must all follow the same regulations and policies. They have no discretion to make their own determination of what to accept.

As long as your sea service letter is written as 12 hour days you should be fine.

Unfortunately they don’t all follow the same regulations and policies. Many people have been granted licenses and endorsements without meeting the proper requirements.

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I think they do try to follow the same policies. But all evaluators must apply judgement when evaluating applications. Not all judgement is the same.
I can’t count how many times I’ve read through 46 CFR, but every time it is painful and often I come to different conclusions on requirements then I had the last time I read it.
NMC has tried to dumb it down for the evaluators there by applying the checklists. But these sometime have issues of their own. The CFRs are often more flexible, but this won’t matter if you aren’t willing to challenge the system.

No. Your 44 (12) hour days are equal to 66 “days” that then get counted 2 for 1 for 33 days towards your unlimited mate upgrade.

After thinking about it some more, I came to that conclusion as well. Definitely a hopeful reach with the 1 for 1, but I’ll take the 33.

Thanks all