Understanding the CFRs for AS-D, RFPNW? and new mariner Q's

Professional Mariner Forum
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I know there are many threads like this. I am still confused. I’d love any thoughtful help from someone whos’ had to do this recently.

I’m sending in for OS, Food handler, wiper, AB-Special, AB-Sail (yes useless commercially) lifeboatman-limited, Master 100 ton inland with aux sail and towing, Mate 200 inland with aux sail and towing. I have the sea time (GRT 50-99 on a smattering of tall ships, some NC time, most is inland), took classes for everything. I’m looking into deckhand on research vessels, tugs, NOAA. I want tonnage and sea time. It feels like a catch-22. I want ocean time and large tonnage, and perhaps hawsepipe up to 3rd, but to get that I need ocean time and large tonnage? I’m focused on Able Seafarer-Deck because it looks like the next step for me to get.

  1. People talk about ‘get your AB’. Do they mean national or STCW? Do they mean whatever AB you qualify for? Unlimited, limited, special, osv, sail, fishing, modu?

  2. get your AB “with STCW”. which? Just Basic Training? RFPNW? VPDSD?

  3. Getting RFPNW
    46 CFR 12.605 —180 days of seagoing service, which includes training and experience associated with navigational watchkeeping functions and involves the performance of duties carried out under the supervision of the master, mate, or qualified STCW deck rating, EXCEPT, as identified in 46 CFR Table 1 to 12.605(c) below.
    OR

  • Proof of successful completion of a Coast Guard-approved or accepted training, which includes:
    • Not Less than 60 days of approved seagoing service

Do I need 180 days prior to gettinf RFPNW? Do I understand that If I get my AB Special, and then want to add RFPNW, I don’t need to satisfy the specific sea time requirements for RFPNW? I don’t currently have the sea time But I would need an approved course, or the sign off for the skills from a QA or someone fitting the requirments of NVIC 19-14, per that new exstension? https://www.dco.uscg.mil/Portals/9/NMC/pdfs/announcements/2023/qa_extension_announcement_100223.pdf?ver=8OvTXIv7-MhTNMUEzlOYLg%3D%3D&timestamp=1696256927770

46 CFR 10.232 —Sea time for an oceans, NC or STCW endorsement. day for day on the great lakles. Inland can count for 50%. day for day on any water if STCW applies to the vessel, inside passage is day for day for NC/STCW
To even qualify for RFPNW, I need the sea time above?

Assessments- Proof of successful completion of Coast Guard-approved or -accepted training, which includes not less than 2 months of approved seagoing service;

STCW Code Table A-II/4— So I need to prove all of this from a class, or have a qualified person sign off, per “Record of Practical Performance Assessments from NVIC 06-14” ?

  1. To be able to get RFPNW I would need to have 180 days of seagoing service, and that seatime has to be on the lakes, and half of it can be inaland water. OR i take a USCG approved course that includes 60 days of approved seagoing service? And then I could have the RFPNW STCW endorsement on my MMC?

  2. What’s the difference between meeting the requirements for certifications as RFPNW and being qualified as an RFPNW? 46 CFR 12.603

  3. To get STCW AS-D, I need to already have RFPNW STCW and then, since getting it, have gotten 18 months of seagoing service in the deck department or 12 with approved training 46 CFR 12.603 ? Do I understand that time I got on ships before obtaining RFPNW doesn’t
    count towards AS-D? Or I can get AS-D without RFPNW, but I need to, as seen in the quote below, basically already have everything for RFPNW, besides sending in the application for it? I see on the checklist for AS-D “Not necessary to hold the endorsement for RFPNW but ALL training/assessments, watchstanding and sea service required for RFPNW must be completed before accruing the sea service towards AS-D.”

For Table A-II/5 of the STCW Code, These skills can be signed off from a class or from a qualified assessor, as per NVIC 14-14?

I found this previous thread STCW endorsement as Able Seafarer-Deck - #8 by jdcavo and it might, if true, answer some of my questions. I’d like corroboration. Like that I won’t be able to count any sea time for AS-D until I have RFPNW, or the last day of my seatime letter that then qualifies me to apply for RFPNW

What ships can I actually get time on that progresses my sea time, rather than stagnate or set me back? Most tugs seem useless if they operate inland, and if they go offshore I need some kind of STCW. Does that mean AS-D or just basic training?

Basic Training I know to just find a class and take it.
If you read this far I sure appreciate it, thanks!

2

Yes.

Usually when someone is that vague they don’t know what STCW even means let alone what you should get.

Yes but I think it needs to be signed off specially. I forget exactly.

I don’t think that’s correct.

Correctish.

Yes.

3

As a new mariner I can understand the confusion in deciphering the language used in National/ Domestic and International/STCW licensing and endorsements. I am posting this for you and the others that will follow.

To assist in answering your questions, I recommend you take out a blank piece of paper. Divide into two columns. Label one as National Endorsements the other as STCW Endorsements. This is done to separate the two as they are separate issues. The goal is to develop a dual track line.

Starting with the National Endorsement Column which reflects the sea time requirement and possible qualified ratings endorsements and the National language used.

Entry level requires no sea time.

@ 180 days - Qualifies for Lifeboatman Endorsement & AB Sail, Fishing, OSV

@ 360 days – Qualifies for Ab Special & MODU

@ 540 days – Qualifies for AB Limited w/ service on vessels > 100 ton

@ 1080 days – Qualifies for AB Unlimited w/ service on Oceans, Near Coastal, Great Lakes

Next using the STCW Endorsement Column reflect the sea time requirement and possible qualified endorsement and the STCW language used.

Again, Entry level positions requires no sea time but there are STCW training requirements e.g. BT and VPDSD that should be completed. Once commencing sea time, start shipboard assessments for RFPNW. NVIC 06 14

@ 180 days – send NMC an application with the completed assessment control sheets for RFPNW Endorsement and commence shipboard assessments for Able Seafarer-Deck NVIC 14 14. You now have a 540 day waiting period while holding a RFPNW endorsement. You should also obtain your lifeboatman (PSC) course and endorsements at this time.

@ 360 days - Obtain the National Able Bodied Seaman - Special endorsement as 46 CFR 11.201 requires that an applicant for STCW must hold the appropriate National Endorsement.

@ 720 days – send NMC completed assessment control sheets for Able Seafarer-Deck Endorsement.

Now flip the paper over. Here use the blank sheet to develop a possible STCW Fast Track Line to Able Seafarer-Deck.

Again, entry level position requires no sea time but there are STCW training requirements e.g. BT and VPDSD that should be considered.

@ 60 days sea time - Complete RFPNW assessments at a USCG approved school. Submit for Endorsement.

@420 days sea time - Complete Able Seafarer – Deck assessments at a USCG approved school. Submit for Endorsement.

Based on your post and my reply we both should get a lot of comments. Good luck on the process.

4 Likes
4

I have not “fact checked” this, but it sounds like a reasonable summary of the NMC checklists.

5

Point well taken. I would recommend balancing what I posted against the appropriate CFR.

Example would be 46 CFR 12.605 - Requirements for RFPNW. Regulatory citing research provides the watch standing duties and possible Sea Letter language to support the requested endorsement.

I believe in “Trust but Verify” which moves my post from an opinion piece to a verifiable document.

6

As already noted, anyone who just says “STCW” and is not specific is not knowledgeable and their advice is suspect.

What you need will depend on the vessel you work on, and the capacity you will work at. If the vessel is subject to STCW, you will need the STCW endorsement that corresponds to the national endorsement for the position you are in. So for “AB” you will need a national Able Seaman endorsement that allows you to work on the vessel, and an STCW endorsement for Able Seafarer-Deck. (“AS-D”). AS-D has its own sea time requirements. AS-D has a prerequisite requirement of qualifying for an STCW endorsement as Rating Forming Part of a Navigational Watch (“RFPNW”). You cannot start counting sea time for AS-D until you have met all the requirements for RFPNW (service and assessments). In addition to AS-D, to work as an AB on a vessel subject to STCW, you will almost certainly need Basic Safety Training and Security Awareness. Depending on your duties, you may also need Proficiency in Survival Craft (“PSC”) or PSC-Limited, and also Vessel Secuiorty with Designated Security Duties (“VPDSD”)

As noted above, you need to QUALIFY for RFPNW before you can start counting sea time for AS-D. You do not have to hold RFPNW, just have met the requirements for it. That means you can only start counting sea time for AS-D after the LAQTER of either the day you got the last day of sea time for RFPNW, or the day you got your last RFPNW assessment signed off. If you hold a national Able Seaman endorsement before you qualified for RFPNW, you can’t use the same sea time you got before you qualified for RFPNW.

You do need all of the assessments. You can get them from a course, if one exists, but that will likely be expensive. If you still need sea time for AS-D, it might be better to get them signed off on the vessel you’re working on while you get any sea time you need for AS-D.

Generally, yes. Not exactly, but for this discussion those are your options. If you meet either of these service options AND meet all of the assessments, you would be QUALIFIED for RFPNW, and could be issued the RFPNW. You could also, as noted above, hold off on applying for AS-D until you have met the requirements for that. Which is better for you will depend on whether you will need RFPNW where you will work.

Basically, none. They both mean you have to have met all of the requirements for RFPNW, but do not mean you need to hold it, i.e. have it added to your MMC.

As noted above, yes. You need to QUALIFY for RFPNW by meeting all of its sea time requirements AND completing all assessments before you can start counting sea service for AS-D.

Others here might have more specifics, but it would be a “seagoing” vessel, which as you noted would be Great Lakes, Near Coastal, or Oceans and Inland with limitations on how much. You can get this on a coastwise tug, if they are on domestic voyages, they do not require STCW.

How does that apply to someone who wrote the NVICs and was part of writing the regulations…?

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It’s kind of wild how complicated it is considering what the job is and what it entails, and the demographic that usually fulfills it (no college degree, prefers working with their hands.) Even as someone who has been doing this for awhile, I have to slowly read it. Now imagine someone brand new to the industry. No wonder there’s an AB shortage, well one reason among a list of reasons.

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8

Mr. Cavo, my point of view is based on understanding the Coast Guard system and working with it not against it.

In my past, I have had to break out the NVICs and regulations to insure that I have a correct understanding of the citing and the complication that it implies.

Key is researching the problem especially before submitting an USCG application or taking a position. I have no interest in receiving and reading an AI letter reflecting I did not do my research.

If there is an issue in the submission, then I can contact NMC (contractors) regarding a credential to find out what I am missing or miss reading. At other times, NMC contractors have passed me on to the evaluator, where I have the ability to talk and work directly with them. This usually resolves the problem between me and the NMC.

On very rare occasion, If I don’t agree with what I am being told by NMC, I know I can move on to a “reconsideration” and eventually an “appeal”.

Before, I submit reconsideration or an appeal, I use gCaptain and search past or current threads for the problem and specifically for your post and guidance on the subject. At times, I have to decipher your post on reconsideration.

I understand your position within the NMC system so I realize you can not provide specific guidance but you do provide a possible direction to the mariner.

Again, My job is to work within the system.

9

First, comment wasn’t intended to impugn you. As for the “NMC system” that’s backwards. They are a component of the mariner credentialing system. As to my question, knowing what was intended and what is actually done may not always be the same…

10

Mr. Cavo i have never taken anything you have said as negative.

I do realize and agree with “knowing what was intended and what is actually done may not always be the same…” is true.

A point that extends beyond the mariner credentialing system. Especially working with the various regulatory systems, guidance documents, policy letters, FAQ’s, Marine Safety Manuals etc of the USCG.

11

I don’t think this is accurate. NMC has consistently interpreted the National Crossover table that is included in the CFRs and checklist ( Table 1 to § 12.603(d)—STCW Endorsement as Able Seafarer-Deck) to mean that as long as you have RFPNW and the national A/B unlimited/limited when you apply for STCW AS-D, they don’t care when you actually qualified for RFPNW. Or if you have RFPNW and A/B special, you can get AS-D after six more months of service.

I even note that in the latest checklist mcp_fm_nmc5_219_web.pdf (uscg.mil) they have changed Note 1 that used to say “minimum additional service” to just “additional service.”

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Isn’t there some way to make this more complicated and less comprehensible?

There must be some way to measure more meaningless distinctions without a difference.

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13

Thank you for the detailed response, I appreciate it.

In Enclosure (3) to NVIC 06-14, it involves use of a magnetic and gyro-compass, and changing from automatic pilot to hand steering and vice versa. The ships I’ve sailed don’t have gyro compasses or automatic steering. As I understand, that means going forwards I need to find a ship that has those two things to get the sign off.

I want to clarify sea time for those endorsements.

"Service toward an oceans, near-coastal, or STCW endorsement will be credited as follows:

1) Service on the Great Lakes will be credited on a day-for-day basis up to 100 percent of the total required service.

(2) Service on inland waters, other than Great Lakes, that are navigable waters of the United States, will be credited on a day-for-day basis for up to 50 percent of the total required service.

(3) Service on vessels to which STCW applies, whether inland or coastwise, will be credited on a day-for-day basis. For establishing credit for sea service, the waters of the Inside Passage between Puget Sound and Cape Spencer, Alaska will be credited for a near-coastal and STCW endorsement."

Because RFPNW and AB-Deck are STCW, that means inland waters only count for up to 50%? So when looking at that track line you wrote, I would need time on the great lakes or a vessel STCW applies to on any waters, or the inside passage?

How do I reasonably find out of the company I want to work for has a vessel with the necessary equipment to be singed off, like a gyrocompass for RFPNW, or identifying and hoisting signal flags for AB-Deck?

14

I really appreciate the response, thank you! To follow up a little,

I see that on the checklist, " Mariner who qualifies for VPDSD will also be endorsed with SA". Would the reason people get SA is it is quicker/less knowledge requirements, as I see in the NVIC?

On the RFPNW assessments. How easy is it to work on a ship/for a company that you can’t get them signed off at? How reasonable is it to ask if they have ships with gyrocompasses etc and an officer with the required endorsements to sign me off?

I do think I am wrong about my understanding of sea service now. It seems oceans and near coastal do not count?
"Service toward an oceans, near-coastal, or STCW endorsement will be credited as follows:

1) Service on the Great Lakes will be credited on a day-for-day basis up to 100 percent of the total required service.

(2) Service on inland waters, other than Great Lakes, that are navigable waters of the United States, will be credited on a day-for-day basis for up to 50 percent of the total required service.

(3) Service on vessels to which STCW applies, whether inland or coastwise, will be credited on a day-for-day basis. For establishing credit for sea service, the waters of the Inside Passage between Puget Sound and Cape Spencer, Alaska will be credited for a near-coastal and STCW endorsement."

How do I reasonably find out of the company I want to work for has a vessel with the necessary equipment to be singed off, like a gyrocompass for RFPNW, or identifying and hoisting signal flags for AB-Deck?

15

What company do you want to work for? Call them up and ask. You have a lot of tall ship experience but for what you want to do, a lot of it won’t necessarily translate well to work boats. So you might have to start as an os. Or go to some sort of school

16

Nobody is going to actually make you do this one.

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Blockquote

As I understand, that means going forwards I need to find a ship that has those two things to get the sign off.

Blockquote

You are correct.

Blockquote

I want to clarify sea time for those endorsements.

Blockquote

Focus on the wording used for these specific endorsements -

Seagoing service means service onboard a ship/vessel relevant to the issue of a credential or other qualification.

Seagoing vessel means a ship that operates beyond the boundary line specified in 46 CFR part 7.

Based on your situation you may have served on vessels that meet the above requirements, This would be part of your documented sea letters. Take a moment to consider some vessels are exempt from STCW that go beyond the boundary lines.