USCG memo: Credit for Service on Articulated Tug-Barge Combinations

Credit for Service on Articulated Tug-Barge Combinations

In light of the current shortage of mariners, the Coast Guard has considered the barrier to mariner career progression presented by Title 46 CFR 11.211(d), Service on Articulated Tug Barges (ATB) and Integrated Tug Barges (ITB). This regulation limits the crediting of sea service based on the aggregate tonnage of the ATB or ITB to a two-for-one basis up to only 50 percent of the required service.

The inability to receive sea service credit for the aggregate tonnage of the ATB or ITB limits career progression and is unnecessarily burdensome for mariners holding unlimited tonnage endorsements.

The Coast Guard will recognize service on ATBs and ITBs, with an aggregate tonnage above 1,600 gross register tons (GRT), day-for-day toward the required service on vessels over 1,600 GRT when seeking a raise-of-grade for unlimited tonnage officer endorsements. This credit will only apply to those ATBs and ITBs that operate exclusively as a composite unit. This should be documented by the company on the mariner’s service letter or in supplemental documentation when a certificate of discharge is used.

Mariners with pending applications who have submitted service on ATBs may need to provide additional information to verify that service on ATBs and/or ITBs was solely as a single unit to obtain this credit on their current application.

Sincerely,

/M. Medina/

Mayte Medina

4 Likes

A good first step toward fairness to mariners working on limited tonnage rule-beater vessels.

2 Likes

So as I understand this, if you have the ATB sea service and hold a 1600 mate you could get the 3M endorsement without testing, but if you only have 1600 master you would have to take the exam. Is that correct?

It depends on what exams you’ve taken previously not what license you currently hold.

2 Likes

Yeah that’s what I meant, meaning if you haven’t taken the 1600 mate exam you would need to test.

Correct. If you haven’t taken the 500/1,600 ton mate exam since 2002 you will need to test to get 3rd mate unlimited.

1 Like

Yeah that’s right pretty stupid huh

Why? If you haven’t taken the test you haven’t taken the test. Maybe the USCG should just stop letting anyone get a 1,600 ton Master license without having taken the 1,600 ton Mate exam, is that what you want?

1 Like

Already had a mates license just not that one brother

I thought the exam I was referring to was obvious when I said “not the mate exam” but I’ve fixed it for you.

The typical crossover from Master 1600 is to Second Mate Unlimited.

The OSV guys can go from Master OSV straight to Master Unlimited.

If an ATB guy has a lot of time sailing as Master on an ATB over 1600 GRT, why can’t he go straight to STCW II/2 & Master Unlimited?

If he has at least one year sailing as Chief Mate on an ATB he probably can.

2 Likes

I’ve been sailing as C/M on an ATB for several years. I have STCW II/2 on my MMC, is that because I have 1600 GRT master? I have OICNW with no tonnage restriction listed, but master is limited to 3000 GT. Just wondering what unlimited national license one could qualify for based on this new memo, and what, if any, additional STCW training would be necessary to get the equivalent STCW endorsements. I think I could probably get a 3M endorsement without any additional training, but I get a little confused by the STCW endorsements.

While this is a long time coming and we don’t need to rediscuss the natural evolution of a tug/Jones Act beaters debate here. I’d like to see how the license structure will change. I have 1600T Master and 3rd Unl for the last 15 years and have been an ATB capt for the last 12 years. Would I need to upgrade to 2nd or go straight to Master?

I doubt I would do it anyway, for me it doesn’t really give any advantage and I really don’t want to take any more tests.

1 Like

Really curious to hear more about this…
Does this mean that there is a path to unlimited master on ATB time alone?

1 Like

It sounds like there should be. It might take someone trying and making a really good argument on appeal to get there though.

1 Like