Considering you have a 3rd Assistant Engineer Motors Unlimited, you will also have a QMED and would be able to serve in many positions and your response was about as helpful as a chipped screw driver, its only usefulness is to piss me off.
Congrats on your new job as a 3AE on the Lakes.
I say the rest of this only for the benefit of others who might otherwise be confused or misled by previous comments.
As usual, Capt. Phoenix is correct.
NMC reviews license applications and issues licenses. That’s all it does. And it does not do that very well. It has nothing to do with determining what endorsements are required for what ships or voyages. The people who answer the phone when you call NMC do not even work for the NMC, they work for a defense contractor that supplies phone answering services and non-binding preliminary advice.
If someone is an active applicant for a license, they might have an opportunity to speak with the evaluator reviewing their application. The evaluators are USCG employees, but most of them are incompetent new hires. They know nothing about what ships require STCW, nor do they have any authority to make such determinations on behalf of the USCG.
In general, STCW is required on all ocean and Coastwise voyages outside of harbors, Lakes, bays, and sounds. There are a few exceptions that are discussed above: vessels under 200 GRT, fishing vessels, vessels on the Great Lakes, US or Canadian tugs in US or Canadian waters, etc.
A 3AE, and any other national license without STCW, is valuable and opens many opportunities, but it does not authorize service on ocean or Coastwise voyages (with some exceptions).
What they are saying and you aren’t listening to is NATIONAL License.
I will probably regret engaging a troll who joined gCaptain last week, apparently for the sole purpose of bitching and arguing…
You talked to a contractor at the NMC. The NMC issues MMCs. They don’t make regulations or policy. The issue you are raising is manning. The NMC doesn’t do that. Try contacting an office responsible for manning regulations and policy.
You’re completing misinterpreting 46 CFR 15.1103(f). It says that certain personnel on passenger ships have to meet the requirements of Regulation V/2 of STCW. That regulaton is titled Mandatory minimum requirements for the training and qualification of masters, officers, ratings, and other personnel on passenger ships. Chapter V of STCW is additional requirements for certain vessels beyond the “core” requirements of Chapters II and III. It’s also the source of the requirement for additional qualifications for tank vessels. 46 CFR 15.1103(f) prescribes requirements for passenger vessels that are in addition to the endorsements in 46 CFR 15.1103(a).
You also seemed to have stopped when you found something that you thought supported the interpretation you wanted. You missed 46 CFR 15.825(b).
The above notwithstanding, let’s assume that you are right. Are you going to have this argument with a prospective employer who disagrees with your interpretation and wants the engineers on their vessels to hold OICEW? And even if they agree with you, are they willing to risk detention of their vessel ($$$) while they argue with a foreign port state control offical who believes an OICEW endorsement is required?
Perhaps you should either get a thicker skin or find another forum where everyone will agree with you and praise your astute legal skills.
Who should we contact at the USCG about manning issues?
I am frequently pressured by owners to sail with crew that does not meet my interpretation of the USCG manning regs. Sometimes it is unclear.
Owners often say “we have a good relationship with the USCG. I called my buddy at the USCG and he says it’s ok”.
I’ve learned not to ask “did your USCG buddy give you that in writing.”
I’d like to know who to call for definitive guidance in such situations.
I’ve never rated out a current or former employer tobthe USCG, but I might be tempted in the future for the worst cases?
The OCMI that issued the vessel’s COI for vessel specific questions, or CG-CVC-1 for general questions that aren’t related to a specic vessel.
A COI solves most problems.
However, It’s more of a problem on Tugs with no COI. No COI , or true USCG inspection, is why Subchapter M is a sick joke.
It’s also an issue on fishing vessels over 200 GRT which have no COI.
You would not believe the ways many owners routinely play very fast and loose with the rules. They are seldom caught.
I was Chief Mate on a ship that required 6 ABs but allowed up to two OSs that had RFPNW. The exact wording confused people and I’m sure we were under manned:
“Up to two (2) ordinary seamen with an STCW 95 certificate or endorsement as a rating forming part of a navigation watch may be substituted for two (2) able seamen.”
I read that to mean the OS needs to have RFPNW. The master told me that the COTP office claims it means they either need to have an “STCW 95 certificate” (basic training) OR have an endorsement as RFPNW.
I hope the master had that interpretation in writing…
Most ships that I’ve seen only carry engineers and oilers. Also, many people simply use “oiler” as a generic term for unlicensed engine room crew unless you’re talking about a specific ship.
Saying it three times doesn’t make it correct.
You didn’t actually read the CFR then, I’ll post it again with added emphasis for you.
46 CFR 15.1103
(a) Onboard a seagoing vessel of 500 GT or more, driven by main propulsion machinery of 1,000 HP/750 kW propulsion power or more or on an international voyage beyond the boundary line as described in part 7 of this chapter, no person may employ or engage any person to serve, and no person may serve, in a position requiring a person to hold an STCW endorsement, including master, chief mate, chief engineer officer, second engineer officer, officer of the navigational or engineering watch, or GMDSS radio operator, unless the person serving holds an appropriate, valid STCW endorsement issued in accordance with part 11 of this subchapter.
It was worse when a ship I was on had that same language in the mid '80s. We had no idea wtf “specially trained” meant, but it was apparently briefly explained in NVIC 3-83:
OCMIs may at their discretion and in accordance with 46 CFR 157.15-1(b), issue an amendment to the Certificate of Inspection allowing for the substitution of ordinary seaman physically qualified and trained in basic indoctrination and lookout procedures for Able Seaman
I assume it did not adress helm duties as an AB was (and still is) required to be on the wheel when entering port and in congested waters.
Your interpretation was correct. it said “STCW certificate or endorsement…” because at the time, we had not fully transitioned to the MMC. Prior to the MMC STCW credentials were “certificates.” With the MMC, they became “endorsements” to the MMC. Considering that the original policy specified lookout duties, it would seem faily obvios that your interpretation was the better one, although the words “basic indoctrination” might encourage the erroneous interpretation you mentioned, at least to some one pre-disposed to that answer. Had anyone anticipated your Master’s novel interpretation, it might have been better to say “STCW certificate or STCW endorsement as… (RFPNW).” The current language is more clear, from page B4-2 of Volume III of the Marine Safety Manual:
UP TO TWO ORDINARY SEAMEN WITH A STCW CERTIFICATE ENDORSED FOR REGULATION II/4 ‘RATING FORMING PART OF A NAVIGATION WATCH’ MAY BE SUBSTITUTED FOR TWO ABLE SEAMEN WITHOUT FURTHER ENDORSEMENT AS ABLE SEAFARER-DECK II/5
IIRC this was a new or newish COI so I was surprised it was using the old language. When did the language change take effect?
I’m not sure exactly as the COI section of the MSM has been revised several times in the last few years. However, it’s certainly possible that the MSM wasn’t strictly applied, and the MSM is certainly good authority on interpreting what it did say.
Come on’ Capt_Phoenix, show a little class, leave the QMED alone.