What does "Sea Service under authority of the endorsement" mean?

I’m trying to add STCW Able Seafarer - Deck to my MMC using my National A/B Special as the entrypoint via that table in § 12.603(e) (see below). I have over 6 months sea service since obtaining my A/B Special, but very little of it is as A/B. The vast majority of my sea service while in possession of my A/B has been as Master on a vessel that does not require A/Bs. I assumed that NMC would accept my time as master to count towards the Able Seafarer per the table, but I’m apparently mistaken. I’m kind of stuck since I can’t seem to find a good definition of what “Sea service under authority of the endorsement” really means. Obviously sea service as an A/B would count, but if A/Bs aren’t required (or even if they were), why wouldn’t service as the A/B’s boss count?

Table 1 to § 12.603(e)—STCW Endorsement as Able Seafarer-Deck

Entry path from national endorsements Sea service under authority of the endorsement 1 Competence—STCWTable A-II/4 2 Competence—STCWTable A-II/5 3 Trainingrequired by this section 4
A/B unlimited None Y Y N
A/B limited None Y Y N
A/B special 6 months 5 Y Y N
A/B-offshore supply vessels 12 months 6 Y Y N
A/B sail 12 months 6 Y Y N
A/B-fishing industry 12 months 6 Y Y N
1 This column provides the minimum additional service required of the seafarer already holding an RFPNW endorsement in order to meet the requirements of this section.
2 Complete any items in paragraph (a)(2) of this section not previously satisfied.
3 Complete any items in paragraph (a)(4) of this section not previously satisfied.
4 Complete any items in paragraph (a)(5) of this section not previously satisfied.
5 The service may be reduced to 3 months if training has been completed as part of an approved training program meeting the requirements of paragraph (a)(4) of this section.
6 The service may be reduced to 6 months if training has been completed as part of an approved training program meeting the requirements of (a)(4) of this section.

And just so I’m clear, I recall that @jdcavo said he was against these tables when they were writing the rules. But the table is obviously based loosely on the service requirements in § 12.603(a)(3) While qualified as an RFPNW, have seagoing service in the deck department of - (i) Not less than 18 months;

You can track the time required to get RFPNW and A/B Special and understand how they came up with the requirement for an additional 6-months. But nowhere except in the table does it require “service under authority of the endorsement.” Who comes up with regulations like this just to screw the mariner over? I need some thoughts before I pull the “reconsideration” trigger. I feel like there is no possible way that the regulators meant for the table to be interpreted this way… yet that is what it says.

Often explanations lie elsewhere in the CFRs. In this case its 46 CFR 5.57:

A person employed in the service of a vessel is considered to be acting under the authority of a credential or endorsement when the holding of such credential or endorsement is:

(1) Required by law or regulation; or

(2) Required by an employer as a condition for employment.

So if you were not required to hold an A/B endorsement by either law, regulation, or your employer, then you were not acting under the authority of said endorsement. If your employer required it, then you likely were.

Than you, shipengr. That is the answer I was looking for. Unfortunately, it doesn’t really help my case much.

Since the STCW code doesn’t require any of the service time be as any type of A/B in order to get the endorsement, I think I will have to dissect the intent of that table.

Use the checklist, it’s literally the cheat sheet because that is what your evaluator will be using:
https://www.dco.uscg.mil/Portals/9/NMC/pdfs/checklists/mcp_fm_nmc5_219_web.pdf

Read the checklist, it has explanation and details. You’ll also need required assessments if you don’t have them.

Thanks, I already followed the checklist for my application. The only issue I’m having with the evaluators is that my National A/B is A/B special rather than unlimited and the evaluator is insisting my additional 6 months service in the table has to be done as an A/B rather than an officer.

Shouldn’t your officer license supersede any unlicensed rating?

Probably time to get a license consultant that knows how to deal with the incompetence. I use one for even my most simple upgrades, because they even mess that up!

You said you were sailing as Master and as an officer…what credential do you hold/were you sailing on?

Sailing on Master 500. Just never bothered with A/B until recently. But also hold A/B special.