Unlimited Tonnage Time as A.B. for 3rd/2nd Mate


#1

I have 310 confirmed 12 hr. days on an ITB as AB unlimited. I will soon be sitting for 3rd/2nd Mate unlimited but understand that if I can’t show enough sea service time as AB, I will only get issued a restricted third mate license until I serve on a vessel for a certain number of days (think 180) holding the restricted third mate license. I am trying to avoid getting issued a restricted third mate license. Does anybody know if I can apply some of my many, many days as Master Oceans 1600/3000 ton as part of the time required to get issued a Third Mate License without restriction?


#2

Unless you have the required time on vessels over 1600 gross tons, you’re never going to get around the tonnage restriction, but you can have some fun with it anyhow:

Here’s a little know gem:
Holding Master 1600 N/C or Oceans qualifies you for Master AGT Inland, just by applying for it. You can then turn that into 2nd Mate Unlimited Oceans by passing the exam. See Figure 11.403 in Federal Register /Vol. 74, No. 49, page 11241.

From the Marine Safety Manual:

Master 1600 GT Upon Oceans or Near Coastal Waters To Master Any GT Upon Inland Waters.
Mariners holding a license as Master 1600 GT Oceans or Near Coastal may apply for a Master Any GT Inland license utilizing 46 CFR 10.435. A tonnage limitation will be placed on the Inland license as per 46 CFR 10.402(b) and ©. Mariners may remove the tonnage limitation on the Inland license by serving one year on vessels over 1600 GT

Here’s some more mumbo-jumbo for you:

Master Of 1600 Gross Tons To Third Mate.
46 CFR 10.407© provides for a master with a 1600 gross ton license to qualify for third mate any gross tons by showing one year as master of vessels over 200 gross tons. Section 10.402(b) states that an applicant qualifying for third mate under this section shall have a tonnage limitation placed on the license based on
the applicant’s qualifying experience.

And:

Tonnage Limitations.

  1. Upper Level Licenses.
    To qualify for an ocean or near coastal license for vessels of any gross tons, all the required service must be obtained on vessels of over 200 gross tons. Furthermore, at least one half of the required experience must be obtained on vessels of over 1600 gross tons (46 CFR 10.402(a)). If an applicant for an original or raise of grade of a license as master or mate does not have the required service on vessels over 1600 gross tons, a tonnage limitation is placed on the license based on the applicant’s qualifying experience (10.402(b)). The provision made in 10.402(b) for a license issued with a tonnage limitation is for applicants lacking experience on vessels over 1600 tons, not those lacking experience on vessels over 200 tons. All of the service must have been on vessels over 200 gross tons.

From the CFR:

TITLE 46 - SHIPPING

CHAPTER I - COAST GUARD, DEPARTMENT OF HOMELAND SECURITY

SUBCHAPTER B - MERCHANT MARINE OFFICERS AND SEAMEN

PART 10 - LICENSING OF MARITIME PERSONNEL

subpart d - PROFESSIONAL REQUIREMENTS FOR DECK OFFICERS’ LICENSES

10.407 - Service requirements for third mate of ocean or near coastal steam or motor vessels of any gross tons.

(a) The minimum service or training required to qualify an applicant for license as third mate of ocean or near coastal steam or motor vessels of any gross tons is: (1) Three years of service in the deck department on ocean steam or motor vessels, six months of which shall have been as able seaman, boatswain, or quartermaster, while holding a certificate as able seaman.

Experience gained in the engine department on vessels of appropriate tonnage may be creditable for up to three months of the service requirements for this license; or, (2) Graduation from: (i) The U.S. Merchant Marine Academy (deck curriculum); (ii) The U.S. Coast Guard Academy and qualification as an underway officer in charge of a navigational watch; (iii) The U.S. Naval Academy and qualification as an underway officer in charge of a navigational watch; or, (iv) The deck class of a maritime academy approved by and conducted under rules prescribed by the Maritime Administrator and listed in part 310 of this title, including the ocean option program in the deck class of the Great Lakes Maritime Academy; or, (3) Satisfactory completion of a three year apprentice mate training program approved by the Commandant.

(b) Graduation from the deck class of the Great Lakes Maritime Academy with no ocean sea service will qualify the graduate to be examined for a license as third mate near coastal steam or motor vessels of any gross tons.

© While holding a license as master of ocean or near coastal steam or motor vessels of not more than 1,600 gross tons, one year of service as master on vessels of over 200 gross tons operating on ocean or near coastal waters will qualify the applicant for a license as third mate of ocean or near coastal steam or motor vessels of any gross tons.

[CGD 81059, 52 FR 38623, Oct. 16, 1987, as amended by USCG 2002 13213, 67 FR 64315, Oct. 18, 2002]


#3

[quote=Capt_Anonymous;12017]Unless you have the required time on vessels over 1600 gross tons, you’re never going to get around the tonnage restriction, but you can have some fun with it anyhow:

Here’s a little know gem:
Holding Master 1600 N/C or Oceans qualifies you for Master AGT Inland, just by applying for it. You can then turn that into 2nd Mate Unlimited Oceans by passing the exam. See Figure 11.403 in Federal Register /Vol. 74, No. 49, page 11241.

From the Marine Safety Manual:

Master 1600 GT Upon Oceans or Near Coastal Waters To Master Any GT Upon Inland Waters.
Mariners holding a license as Master 1600 GT Oceans or Near Coastal may apply for a Master Any GT Inland license utilizing 46 CFR 10.435. A tonnage limitation will be placed on the Inland license as per 46 CFR 10.402(b) and ©. Mariners may remove the tonnage limitation on the Inland license by serving one year on vessels over 1600 GT

Here’s some more mumbo-jumbo for you:

Master Of 1600 Gross Tons To Third Mate.
46 CFR 10.407© provides for a master with a 1600 gross ton license to qualify for third mate any gross tons by showing one year as master of vessels over 200 gross tons. Section 10.402(b) states that an applicant qualifying for third mate under this section shall have a tonnage limitation placed on the license based on
the applicant’s qualifying experience.

And:

Tonnage Limitations.

  1. Upper Level Licenses.
    To qualify for an ocean or near coastal license for vessels of any gross tons, all the required service must be obtained on vessels of over 200 gross tons. Furthermore, at least one half of the required experience must be obtained on vessels of over 1600 gross tons (46 CFR 10.402(a)). If an applicant for an original or raise of grade of a license as master or mate does not have the required service on vessels over 1600 gross tons, a tonnage limitation is placed on the license based on the applicant’s qualifying experience (10.402(b)). The provision made in 10.402(b) for a license issued with a tonnage limitation is for applicants lacking experience on vessels over 1600 tons, not those lacking experience on vessels over 200 tons. All of the service must have been on vessels over 200 gross tons.

From the CFR:

TITLE 46 - SHIPPING

CHAPTER I - COAST GUARD, DEPARTMENT OF HOMELAND SECURITY

SUBCHAPTER B - MERCHANT MARINE OFFICERS AND SEAMEN

PART 10 - LICENSING OF MARITIME PERSONNEL

subpart d - PROFESSIONAL REQUIREMENTS FOR DECK OFFICERS’ LICENSES

10.407 - Service requirements for third mate of ocean or near coastal steam or motor vessels of any gross tons.

(a) The minimum service or training required to qualify an applicant for license as third mate of ocean or near coastal steam or motor vessels of any gross tons is: (1) Three years of service in the deck department on ocean steam or motor vessels, six months of which shall have been as able seaman, boatswain, or quartermaster, while holding a certificate as able seaman.

Experience gained in the engine department on vessels of appropriate tonnage may be creditable for up to three months of the service requirements for this license; or, (2) Graduation from: (i) The U.S. Merchant Marine Academy (deck curriculum); (ii) The U.S. Coast Guard Academy and qualification as an underway officer in charge of a navigational watch; (iii) The U.S. Naval Academy and qualification as an underway officer in charge of a navigational watch; or, (iv) The deck class of a maritime academy approved by and conducted under rules prescribed by the Maritime Administrator and listed in part 310 of this title, including the ocean option program in the deck class of the Great Lakes Maritime Academy; or, (3) Satisfactory completion of a three year apprentice mate training program approved by the Commandant.

(b) Graduation from the deck class of the Great Lakes Maritime Academy with no ocean sea service will qualify the graduate to be examined for a license as third mate near coastal steam or motor vessels of any gross tons.

© While holding a license as master of ocean or near coastal steam or motor vessels of not more than 1,600 gross tons, one year of service as master on vessels of over 200 gross tons operating on ocean or near coastal waters will qualify the applicant for a license as third mate of ocean or near coastal steam or motor vessels of any gross tons.

[CGD 81059, 52 FR 38623, Oct. 16, 1987, as amended by USCG 2002 13213, 67 FR 64315, Oct. 18, 2002][/quote]

You are right about the mumbo jumbo part. These rules leave alot of room for interpretation by the individual evaluator. It seems that if you were issued a inland AGT Master, it too would be restricted until you serve a certain amount of time. So if you are not an inland person as I am not, how would I be able to test for second mate. It seems that the Second Mate would have a tonnage restriction on it also unless you took the restriction off of the AGT inland Master.

If I look at 10.407 (a) I should have the time I need. Three years seatime on unlimited tonnage vessels of which 180 days will have been as AB, boatswain,or quartermaster, while holding an able seaman ticket. How can that be interpreted? Would I have to show that I had a AB ticket the whole three years or just during the 180 days (6 months)?
What about ©? It seems that I have that time covered. In 20 plus years as 1600/3000 ton Ocean Master i have more than enough days to cover this part. I just had to show all that time to renew. Where does it say that I would be issued a restricted tonnage Third Mate license?


#4

[quote=stevefoster;12021]
What about ©? It seems that I have that time covered. In 20 plus years as 1600/3000 ton Ocean Master i have more than enough days to cover this part. I just had to show all that time to renew. Where does it say that I would be issued a restricted tonnage Third Mate license?[/quote]

The Master AGT Inland to 2nd Mate Unlimited Oceans is a convenient way to leapfrog the Third Mate license. If you’re gonna get a tonnage restriction anyway, that’s what I would do.

If you have a year or more as Master on vessels over 200 GT, while holding Master 1600, then the 180 days while holding AB time doesn’t seem to matter. It doesn’t say anything about restricting you under the terms of ©, I’ve wondered about that myself.


#5

Let’s not forget about 46 CFR section 10.211

(d) Service on a Dual Mode Integrated Tug Barge (ITB) unit is creditable for original or raise of grade of any deck licenses. Service on a Dual Mode ITB with an aggregate tonnage of over 1600 gross tons is creditable on a two-for-one basis (two days experience equals one day of creditable service) for up to 50 percent of the total service on vessels over 1600 gross tons required for an unlimited license. The remaining required service on vessels of over 1600 gross tons must be obtained on conventional vessels or Push Mode ITBs.

With 20 years, I’m sure you have time with Dual-Mode ITB’s as well (I’m assuming the 310 - 12 hour days are Push Mode). The definition of Dual-Mode seems to be quite loose, as long as the barge has a notch and towing gear, the tug can fit in the notch and has the towing winch, they consider it dual-mode. Combine the tonnage of the Tug and Barge, the result is rounded UP to the nearest 1,000 and anything over 10,000 is considered AGT.

Please share whatever information you find, I’m in a course for a 500/1600T NC Mate’s license but based on my sea service, I’m going to attempt to use this “Loophole” to sit for a 3rd Mate NC AGT. From the people I’ve spoken with it sounds encouraging, but what the individual evaluator is going to do, who knows.


#6

[quote=Cal;12023]Let’s not forget about 46 CFR section 10.211

(d) Service on a Dual Mode Integrated Tug Barge (ITB) unit is creditable for original or raise of grade of any deck licenses. Service on a Dual Mode ITB with an aggregate tonnage of over 1600 gross tons is creditable on a two-for-one basis (two days experience equals one day of creditable service) for up to 50 percent of the total service on vessels over 1600 gross tons required for an unlimited license. The remaining required service on vessels of over 1600 gross tons must be obtained on conventional vessels or Push Mode ITBs.

With 20 years, I’m sure you have time with Dual-Mode ITB’s as well (I’m assuming the 310 - 12 hour days are Push Mode). The definition of Dual-Mode seems to be quite loose, as long as the barge has a notch and towing gear, the tug can fit in the notch and has the towing winch, they consider it dual-mode. Combine the tonnage of the Tug and Barge, the result is rounded UP to the nearest 1,000 and anything over 10,000 is considered AGT.

Please share whatever information you find, I’m in a course for a 500/1600T NC Mate’s license but based on my sea service, I’m going to attempt to use this “Loophole” to sit for a 3rd Mate NC AGT. From the people I’ve spoken with it sounds encouraging, but what the individual evaluator is going to do, who knows.[/quote]

Hey Cal thanks for your input about the dual mode ITBs. The one I was on (the Jamie A. Baxter) was unlimited tonnage single mode meaning that it could not tow…no towing winch…and the Licensed persons onboard had to have Unlimited tonnage licenses. I served onboard as an AB and Bosun. I received a letter from the CG acknowleding 310 days as an AB. Though I worked a 0600 to 1800hrs. day watch I am sure that they will only count this time as 8 hour days. That’s been discussed on some previous threads and I think that the consensus was that the CG would only give you 8 hour days for that time. I have been sailing as Master on offshore supply vessels for 20 years and have had a license for 26 years. That 20 years is what I think should count for something in obtaining the Third Mate Unlimited. It is true that I can sit for the 3rd/2nd mate no problem but unless I can show unlimited tonnage time as AB for 365 eight hour days, I will end up with a restricted tonnage 3rd mate license. At least that is how I am reading the CFR and I need some one to prove me wrong. The CG has lost my time form 1971 to 1979 when I sailed with the SIU on unlimited tonnage ships as OS and AB. I am trying to find that time and have some folks working on it, one of which is Chief Cavo and his colleagues in the CG. Read Title 46 10.407 (a) and tell me what you think it means about the 3 years of sea service…must I be holding an AB ticket the whole time or just during the 180 days?


#7

How does 0600 to 1800 only count as 8 hours? I count to 12 using my fingers and toes.


#8

I know what you mean. I don’t understand it either except that we had 4 ABs on that vessel and three of them stood regular 8 hour watches. I guess that the CG interprets a 0600/1800 watch as a regular 8 hour watch with 4 hrs. overtime. I don’t know, perhaps someone reading this thread can explain it.


#9

The Coast Guard should (operative word here) accept whatever sea service letter the company provides you. If the company provides you with a sea service letter that states 310 - 12 hour days, I don’t see how the Coast Guard would not accept that. If you don’t have that, go back to the company and request they provide you with a letter specifying the service. If need be, produce the sea service letter yourself, including applicable tonnages etc using the Coast Guards form, and provide it to your company for verification and signature.

As far as 46 CFR 10.407(a) is concerned. This has not been a question in my mind from reading the CFR nor anyone I’ve spoken with (including personnel with the GMATS program at Kings Point). 3 years sea service is numerically equivalent to 1,080 - 8 hour days. To answer your question directly, of the 1,080 days of sea service required, you only need 180 days of that while holding an AB ticket. Further breakdown…
[U]
8 Hour Days[/U]
1,080 days must be on vessels of 200 GRT or more.
540 days of the 1,080 must be on vessels of 1,600 GRT or more.
For 180 days of the 1,080 you must hold an AB ticket.

[U]12 Hour Day (equivalent)[/U]
720 days must be on vessels of 200 GRT or more.
360 days of the 720 must be on vessels of 1,600 GRT or more.
For 120 days of the 720 you must hold an AB ticket.

Now enter 46 CFR 10.402(b)
If the applicant for an original or raise of grade of a license as master or mate does not have the service on vessels over 1600 gross tons required by paragraph (a) of this section, or is qualifying for third mate under the provisions of paragraph § 10.407© of this subpart, a tonnage limitation is placed on the license based on the applicant’s qualifying experience. The license is limited to the maximum tonnage on which at least 25 percent of the required experience was obtained, or 150 percent of the maximum tonnage on which at least 50 percent of the service was obtained, whichever is higher. Limitations are in multiples of 1000 gross tons, using the next higher figure when an intermediate tonnage is calculated. When the calculated limitation equals or exceeds 10,000 gross tons, the applicant is issued an unlimited tonnage license.

This is where any dual-mode experience you may have comes in. If you can get the Coast Guard to recognize your 310 - 12 hour days as 12 hour days, then you have 465 creditable days on vessels over 1600 GRT (Push Mode ITB’s count as a vessel over 1,600 GRT). So any vessels that were not Push Mode ITB’s (or what we working in the NE refer to as ATB’s) that you have experience with pushing and towing a barge with a notch, you can get the remainder of the time you need. 75 - 8 hour days or 50 - 12 hour days. However, Dual-Mode ITB time is creditable on a 2 for 1 basis, so it would be 150 - 8 hour days or 100 - 12 hour days.

From what you have indicated, I’m going to assume that the Push Mode ITB you worked with is in excess of 10,000 GRT (or rounds up to 10,000 GRT). With that in mind, your tonnage would be “limited” per the CFR’s but would end up be an AGT because it exceeds 10,000 GRT.

I hope this has helped, it’s confusing as hell and I hope I haven’t made it worse.


#10

Capt Anonymous,

I have a Third Mate Unlimited NC and I am planning on taking the Inland Master Unlimited test soon, to cross over, but I know the CG has put the brakes on that, I think due to STCW95 issues. Have you heard that at all? However, I am going to try it. It is still written in the CFR’s but I personally know guys that have had arguements with NMC personnel about it. I am trying to get offshore after serving most of my career as a Great Lakes Pilot. I worked in the GOM in 98’ on osv’s and want to persue that venue again. The work has really slowed on the Lakes. If the cross-over is not successful, I was planning on just upgrading to oceans once I get the remaining 48 days required to have my 180 days. Then I am trying fo figure out what I need to get 1600t ocean master. I should be able to sit for that too, I believe.

Rob


#11

On June 1st I submitted my application:

Evaluate 3rd Mate Oceans (Issue 3rd Mate NC)
Issue Master AGT Inland.

I will post the results from my app when I receive them. Keeping my fingers crossed.


#12

[quote=Capt Brian;14055]On June 1st I submitted my application:

Evaluate 3rd Mate Oceans (Issue 3rd Mate NC)
Issue Master AGT Inland.

I will post the results from my app when I receive them. Keeping my fingers crossed.[/quote]

I just applied for Master AGT Inland, and 3/M Oceans. I hope the give me Master AGT Inland, and deny my 3/M. Then I can apply for the Master AGT Inland to 2/M crossover. Badda bing.


#13

[QUOTE=dougpine;14058]I just applied for Master AGT Inland, and 3/M Oceans. I hope the give me Master AGT Inland, and deny my 3/M. Then I can apply for the Master AGT Inland to 2/M crossover. Badda bing.[/QUOTE]

loet us know what happens, I have heard that NMC will not issue the 2nd mate unlimited because you did not do the OICNW assestments and classes for the 3rd mate

will be interesting to see what happens


#14

I have completed the OICNW assesments, excluding the celestial portion. So I am covered on that end.


#15

I have plans for Inland Master to 2nd oceans also. I have friends that have run into snags, but I am going to try it myself. NMC put the brakes on it due to STCW95 issues, apparently. Hopefully it was only the OICNW that was holding back my friends. I am good in that department. Keep us posted on how it goes.


#16

rjbpilot, I am in the exact same situation as you are (in fact, I think we were in the same class at GLMA, but I’ll stay on point here). I was recently down at Star-Center in Dania with a former ASC guy who was approved for the crossover from Mate of Great Lakes to Master of Inland Waters and 2nd Mate Oceans. He had NOT yet completed his STCW requirements. I know that REC Toledo had said no to this option two or three years ago, but apparently it can still be done. I’m gonna get the ball rolling on this ASAP.


#17

Yeah, I have been studying and I have another friend taking the test on Monday. I think that since I have all my stcw95 stuff all straight I should be ok. 2nd Mate Oceans here I come…oh yeah…


#18

[I]Here’s a little know gem:
Holding Master 1600 N/C or Oceans qualifies you for Master AGT Inland, just by applying for it. You can then turn that into 2nd Mate Unlimited Oceans by passing the exam.

[/I]I tried this and the CG says “Per 46 CFRR 11.435, a Master AGT Inland requires proof of 360 days service on Great Lakes or Inland waters, not Near Coastal, as a Mate or FCP of GL or INL vessels over 1600 GRT.”

Has this changed?


#19

What they just told you is the way I’ve always read it; there is service on Inland and/or GL water required, it’s not just for the asking. I just studied it again and it still reads the same way to me. Anyone else’s mileage differ?


#20

Mariners holding a license as Master 1600 GT Oceans or Near Coastal may apply for a Master Any GT Inland license utilizing 46 CFR 10.435. A tonnage limitation will be placed on the Inland license as per 46 CFR 10.402(b) and ©. Mariners may remove the tonnage limitation on the Inland license by serving one year on vessels over 1600 GT
That reads to me that you don’t need time on the GL or inland, but you need time over 1600 tons or you will get a tonnage limitation. I don’t see how you can you have an “any gross tons” license with a “tonnage limitation” but it is the government so anything is possible.

Three years seatime on unlimited tonnage vessels of which 180 days will have been as AB, boatswain,or quartermaster, while holding an able seaman ticket.

That reads to me that you need three years seatime while holding an AB ticket, but that only 180 days has to actually be as an AB. Read it after taking out the 180 days part, Three years seatime on unlimited tonnage vessels … while holding an able seaman ticket.