What counts as an “Equivalent Position” when working toward larger licenses?

Good evening,

My question is- Will time earned working as an O.S be honored as an “equivalent position” when accruing time toward a larger license such as 500/1,600/3,000?

I currently hold my 100t NC and have recently started working on OSV’s using my O.S. as a way to catch up on sea time and as a means to diversify myself.

Any and all direction would be appreciated, thank you.

Depends on the evaluator and how the letter was written.
I have an example that somewhat applies.
Years ago I was considering going for a 1600 mate in addition to 500 master. I had a letter that said I was a deckhand. At the time I held an AB special. To make a long story short, I had to go back to this previous employer and have them rewrite the letter that I was working as an AB as opposed to a deckhand.
Couple weeks later, I then had to ask them to provide an explanation in writing for me to the evaluator on why I was listed as a deckhand previously, and why they changed a 10 year old sea letter…
So possibly in your case, if you intend to go for a mate’s license, since those require ‘AB’ time or ‘equivalent position’, safe to say an OS won’t count in that case…

Probably not. Generally, the term “equivalent position” is meant to refer to military service being equivalent to service on a commercial vessel, see 46 CFR 10.232(d)(1). The only times I’m aware of that “equivalent position” is used for national deck officer endorsements is for service equivalent to mate or master. You will have an extremely tough, if not impossible time getting time as an OS accepted as being equivalent to mate or master.

I’m curious what specific time you want the ‘equivalent position’ of?

Anything that would count towards my 500+ GRT.

I emailed the NMC and received this answer-
“Equivalent positions are positions where you are serving the same function as a credentialed mariner, but on a vessel that does not have manning requirements for that position.”

If the COI calls for 0 OICNW’s, as long as I hold those duties my time could be written off as so and would could towards my 500/1600.

They also specified AB - Deckhand - Deckineer would not count toward master time aside from total sea service accrual.

You stand watch underway, alone, and only have an OS? What vessel is this? Does the COI require a Mate?

As I said, it will be impossible, or nearly so, to prevail on an assertion that as an OS you were equivalent to a Mate.

You’ve got a 100 ton ticket. Go sail on it as master or mate on boats over 50 GT. Plenty of gigs out there to get the experience you need to move up to 500. Sailing as OS isnt going to help. You need Master/Mate time.

GOM crewboats with 2 watch rotation will get you there pretty quick (1.5 days credit per). Trying to gather up the requisite 720 days on dinner cruise boats or similar takes forever.

Equivalent Position: Think deck watch officers on military vessels. They are effectively saIling as “Mate”, but most likely dont hold a USCG MMC.

Why not? It’s sea time towards mate 500 or 1,600 GRT and it’s on good tonnage. Plus, it will let him get his RFPNW and OICNW assessments done.

Sailing as Mate (or Master) is a plausible scenario for an OS on a fishing vessel under 200 tons, as no MMCs or licenses of any kind are required.

He needs an additional 720 as Master or mate (while holding his current 100 ton license). His service has to be on vessels over 50 GT to count towards the master 500.

Does RFPNW count as “mate” time towards master 500? Isnt that a professional deckhand designation?

Is the USCG going to credit him “mate” time sailing on a vessel over 100 tons? Maybe the fishing boat if no license is required?

Doesnt make sense to me. I upgraded from master 100 NC to all oceans 500 master with 1600/3000 ton mate. As I recall, all my time needed to be as a mate or master on vessels over 50 GT to get there. Granted, there wasnt any RFPNW, or OICNW designations at that time.

I confirmed with the NMC and shared the vessel COI with them.

Since the COI for the OSV only calls for one master, one licensed mate (2nd captain), one AB, and one OS.

Due to the fact that I hold watches with the mate (2nd captain) I can have my sea service written down as OICNW or Mate since the COI doesn’t call for a 2nd mate nor a OICNW.

In short- As long as the COI doesn’t require a licensed position OR if that manning requirement is already met, and as long as you carry out those same duties; you are allowed to claim time above your grade.

This is also how I was able to receive time as engineer on a vessel with no engineer requirement (private yacht).

I stand watches with the captain. (There’s a master and a captain)

I’m just repeating what the NMC emailed back to my inquiry and showing them the vessels COI.

Right. So you’re not in charge of the watch. And thus not equivalent to a Mate. Good luck with arguing that you are.



I appreciate it. Thankfully I have emails from an NMC rep saying I can do exactly that.

There’s a master, who is responsible off the vessel in an ownership like perspective.
A captain, who runs how the 1st mates would run on most boats.
An AB / Unlicensed Engineer.
An OS.

Are you trolling us or serious? If you have a Master and a Mate who is not the Master, then you have a Master (Captain) and a Mate (Not-Captain), especially since you said that’s what the COI requires. If the guy “runs how the 1st mates would run on most boats”, that makes him the Mate! Legally, and per the COI, he is not the Captain.

I say this because how you worded your inquiry to the NMC might have affected their reply. If you said you stood watch with the “Captain” (you didn’t) they may have assumed you were like Mate (you weren’t), making it equivalent. If you told them you stood watch with the Mate, they would rightly assume you were like the AB/OS (you were) and have said it is not equivalent to being a Mate.

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You are correct.
My wording within the post was improper and I was using company directive for titles. I apologize.

The COI specifically calls for a master, a licensed mate, an AB, and OS.

It’s a 180’ OSV that operates with 4-5 crew and operates 12 hour watches.

As I said, I presented the COI to the NMC as well as my exact intentions for sea service accrual and current position.
Per the rep: When I am actively standing watch with the mate or captain I am then allowed to be considered any of the following-
-chief mate
-second mate / OICNW
-third mate
since the COI does not require any of these to be on board.

Due to the fact that I “hold” my OS, I satisfy the manning requirement per the COI and can simultaneously act in a grade above, because again, it’s not required on the COI.

We can argue it all day, but the fact remains I have written communication from the NMC stating I can write off my sea service in an “equivalent capacity” above my grade as long as it’s not required to be held by a licensed individual.

No. I’m not trolling, and I am sorry you feel that way.

That “written communication” isn’t binding and wasn’t written by an evaluator so their opinion really doesn’t matter.

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True, I guess all I can do is wait and see.

The experience I’m gaining regardless has been fantastic so it’s hard to complain.