Upgrade to 1600 Ton Mate Inland Waters

Currently employed as deckhand on 1600 Ton riverboat (Inland Waters) Want to upgrade from 100 Ton Master to 1600 Ton Mate. CFR 11.416 states that I must have six months service as an AB on the vessel but an AB is not required on my boat. I am performing the functions of an AB but NMC claims that my time is not valid since I don’t hold an AB. Since my boat does not require an AB is there a chance of some sort of waiver for this requirement? I’m seeking the Mate - Inland Waters only which does not seem to be offered. It’s only near coastal that is addressed in CFR 11.416 Thanks for your assistance!

46 CFR 11.416 is only for mate near coastal, you need to look at the section for mate inland.

There is no AB requirement for the inland license. (I believe they removed that requirement for all licenses to come in line with STCW. They changed the wording to “performing bridge watchkeeping duties”.)

46 CFR 11.444 – Requirements for mate of Great lakes and inland self-propelled vessels of less than 1,600 GRT.

(a) The minimum service required to qualify an applicant for an endorsement as mate of Great Lakes and inland self-propelled vessels of less than 1,600 GRT is—

(1) Two years of total service in the deck department of self-propelled vessels. One year of the required service must have been on vessels of 100 GRT or more. Six months of the required service must have been while performing bridge watchkeeping duties under the supervision of the master or a qualified officer on vessels of 100 GRT or more;