U.S. Flagged Ship - Some crew lacks credentials

I apologize in advance that this question is not directly on topic, but there seem to be a few individuals here who might know the answer.

The scenario:

I have information and records showing that a US-flagged ship hauling supplies and cargo under a US government contract is using foreign seafarers (not citizens of the US, etc.) on the crew as ABs and OMUs. They have no MMC or TWIC credentials.

The question:

Can you tell me what section of the US Coast Guard I can contact to provide the information and records I have?

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Call the Jones Act Enforcer!


Ask your congressman. Let us know what they say.

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What do you have? At a minimum I would think you need the vessel’s COI and a copy of the IMO crewlist that shows the people onboard aren’t qualified to meet the COI.

If it’s really definitive proof of what you say, I would draw up an email with those documents attached and send it to the company who’s operating illegally, DOT, MARAD, USCG, USCBP, your Congress reps, Congress reps that are pro Jones Act/maritime, and maritime media outlets like Workboat magazine and gCaptain.

All these email addresses should be readily available via Google searches. Make all addresses visible so everybody knows who else is in copy.

In a lot of cases, all it takes is one of these entities to start asking ‘hey, what are you going to do about this?’ to get something rolling.

Obviously you need to have your shit together before you send it otherwise you’ll look like an idiot.

These the same records you said you were gonna post in another thread then never did?

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Oh is this the MSC thing again? I thought we decided it was MSC, not MSC.


@RiverRats, do they work in US waters? And if so, do they have enough American MMC holders to cover the minimum required on the COI? I’ve been through countless OSV’s USCG inspections with only 2 Americans on board. USCG never seemed to mind as long as the foreign mariners had STCWs & docs from their home country to meet the COI. Back then the the foreign unlicensed mariners had to be relieved the minute the vessel tied up at a US port but I heard a couple of years ago American delivery crew mariners now have to meet the vessels outside of the US if it’s headed back into the US.

Even on a US flagged vessel??

Most definitely. Many countries like Mexico, Brazil, Nigeria, Angola etc. have strict labor laws similar to the Jones Act that requires local crews on board. Some companies only keep American Capts on US flag vessels, others American Capt & CE & at Otto Candies they had a couple of US flagged vessels that kept American Bosuns. I don’t ever recall US unlicensed working the oil fields outside of the US unless it was a speciality vessel like seismic, well stimulation or research for a short term job.


Even on a US flagged vessel??

Absolutely, many US flagged vessels work in other countries waters, some with only a US Master and CE. Just as many foreign flagged vessels operate in US waters. As long as they don’t engage in commerce between US ports they are OK. To my knowledge since the demise of the GSF Explorer there are no US flagged drillships but there are and have been a lot of foreign built drillships and semi’s working in the US for many years.

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See 46 USC 8103(a)(3)(A) and 46 CFR 15.720(b).

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No one really cares, CBP has a bigger issue than a couple seafarers. Good luck with not getting anywhere.

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Have you tried the CGIS Tips app?

Couldn’t agree more. But just because they’re directed to not enforce laws in one area of their scope doesn’t mean they should or will be delinquent in other areas.

Which is exactly the attitude Colin Grabow and his ilk want to see.


[quote=“jdcavo, post:11, topic:64302”]
See 46 USC…[/quote]

Thanks for the link, that clears up the citizenship issue.

What I was focused on was the OPs claim that they didn’t have MMCs. Although the link doesn’t address it, I guess the assumption is that these allowed foreigners are not required to have work authorization in the US and thus would not be eligible for an MMC.

Although this carve-out doesn’t affect my sector of shipping, I find it unfortunate that our flag state allows completely unvetted personnel to work on vessels flying our flag.

Not entirely unvetted, as far as experience and training, although you might question the scope of the vetting and who has to do it. See 46 CFR 15.720(d).


Again, thanks again for the link.

Yes I do. I mean Jesus, even FOC powerhouse RMI requires you to get a RMI credential to sail under their flag FFS. Pathetic.

Yup. Pretty common. Most (all?) offshore vessels that work in Mexico must be Mexican flagged. There is often a US master onboard.

In a few days I’ll have additional records and I want to confirm more before revealing anything else.

Just name the ship and name the company.

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