Posted by: towmasters | May 25, 2009

Tugboat License Tonnage & The New MMC

Last week, after reading the Tugboat Licensing Tonnage post, a reader contacted us with  a question about his newly issued Merchant Mariners Credential (MMC). He had upgraded to Master <1,600GRT and when he got his new MMC back it listed his Master of Towing Vessels endorsement as being limited to vessels of less than 200GRT. This contradicted the information in the post that explained how the U.S. domestic towing license, in and of itself, technically has no tonnage limitation. He was wondering what had happened and what he might be able to do about it.

Much confusion remains with our licensing system and how it aligns, or doesn’t, with the STCW regulations. To start with the new MMC’s are broken up into two sections: one has your STCW/International qualifications (the various applicable provisions of the STCW Code such as II/2-4, IV/2, VI/4, etc. which stand for the OINW, OIEW, GMDSS, FRC, MEDPIC, RFPNW, RFPEW and other qualifications), which formerly were placed only on your STCW letter, and the other lists your qualifications under U.S. domestic regulations, which in the past were mostly on your license and/or z-card. Some were listed on both and there was a general lack of consistency in wording between the different CG REC’s that issued them. Furthermore, the terminology isn’t the same. Under STCW, for instance, they don’t differentiate between towing vessels and other motor vessels. For better or for worse (worse, I think), they are treated the same. The primary distinction between vessels is made by the tonnage as measured under the International Tonnage Convention (ITC). That is why, a few years back, you started seeing licenses and STCW letters being issued with the dual US/ITC tonnage on them.

So in our readers case the towing endorsement in the domestic regulations section should have said Master of Towing Vessels, with no mention of a tonnage restriction. The National Maritime Center simply made a minor error. It’s sort of a fine point but he was worried that someone, like a personnel manager at a company, would look at it and think that he couldn’t operate a towing vessel over 200 GRT, even though he also had a 1,600GRT Master endorsement. This wasn’t the case, the two endorsements together covered him, but I could certainly understand his concern. Sometimes, it seems, no one can give you a straight answer that isn’t contradicted somewhere down the line by someone else who sounds just as authoritative. He was also wondering if he should go through the hassle of trying to get the bogus tonnage limitation removed. That is a personal choice to make. Is it worth the potential aggravation? You won’t know until you try.

In the course of things Mr. Andy Hammond, a maritime licensing consultant, got involved in the dilemma to clarify some points and correct our misconceptions. He is the former chief of the CG’s Boston REC, a well-known authority on all things licensing and STCW, and a self-desribed “STCW purist.” What came out of the discussion was his personal opinion that the following should be the way things are interpreted and done:

  1. In the STCW section there should never be any mention of towing vessels because the STCW Convention does not recognize them as a distinct class of vessel for qualifications purposes. A mariner’s credentials should simply say Master or Mate with whatever tonnage limitation is applicable, if any.
  2. The Master or Mate of Towing Vessels endorsement, in the U.S. Domestic section, should not have a tonnage limitation. This would keep it consistent with our domestic regulations as they currently exist.
  3. Notwithstanding #2, if you have only a U.S. Master or Mate of Towing Vessels license with no higher authority (such as Master or Mate of <500GRT, <1,600GRT, or Unlimited) then in the STCW section only it should have a tonnage limitation of <200GRT/500ITC placed on your Master or Mate endorsement. This would keep it consistent with the Officers Competency Convention of 1936 and the STCW Convention.

He has long been deeply involved in these affairs so his opinion carries a lot of weight, but it isn’t chiseled into granite. Will this one day actually be the way it’s done all the time? The case of our newly upgraded mariner’s towing endorsement shows that basic differences of opinion on this subject exist amongst the CG’s evaluators, possibly because of insufficient or confusing policy guidance, or else minor but easily-avoided mistakes are still being made. It’s a well-known fact that Volume III of the Merchant Marine Safety Manual , the evaluator’s “shop manual” for mariner licensing and certification, is way overdue for a rewrite so that they (and we) will have accurate, up-to-date guidance on how to get this stuff right. A quick policy letter might do the trick in the meantime.

I suspect it may be a while, if ever, before the consistency promised from the merger of all the licensing evaluation and issuance functions at the National Maritime Center becomes a reality. So we continue to wait…..

Editor’s Note: we at the MTVA greatly appreciate Mr. Hammond’s involvement and his willingness to share his expert knowledge directly with our members and readers. Another valuable source of information is Mr. Jim Cavo, the CG’s equivalent to the Shell Answer Man, who freely dispenses valuable and accurate information over on the gCaptain forum. Mr. Hammond himself is an occasional contributor on the gCaptain blog. Check ’em out some time.

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Responses

  1. Dear Towmasters,

    Thanks for the kind words. I truly agree that my words and thoughts are not set in stone, especially when it comes to STCW!! As you stated these are my interpretations and not the final word!

    Many times these “policies” are derived when situations with mariners come up and an answer has to be provided by NMC or Coast Guard Headquarters.

    The bottom line is that groups like yours are extremely important and provide a great place for mariners to go and try to stay up on the latest issues that affect them!!

    Regards,

    Andy Hammond

  2. In my recent Communication with an evaluator at NMC, West Virginia. After many email exchanges explaining the changes to my renewal to a Mechant Mariner Credential.

    That there is no longer any tonnage limitation to a Master of Towing Vessel License with proper STCW Endorsements. That is precisely why no tonnage limitation is listed in the language in the Description of that particular license. The old structure had no tonnage limitation in inland waters, now there is no tonnage limitation to licenses for Inland, or Near Coastal. I think there may be a limitation for Oceans Licenses especially if you sail foreign. (I’m not up on this since I have no desire to sail foreign.)

    I previously had an STCW Document that I assumed permitted me to operate Towing Vessels under 300 Tons according to the language on the Document. But West Virginia Informed me that the REC putting the tonnage limitation on that document was an error. I think that with the required STCW documentation that the tonnage limitation has been removed. If a guy doesn’t have the required STCW training then the <200 Ton Near Coastal regulation still applies.

    This is the reason that many domestic ATB and Offshore towing Vessels were documented 500-700 GRT Vessels. But the Tugs have so many cofferdams in them that they get surveyed under their actual class. Is it possible that a great amount of buoyency is compromised in doing so? Possibly Creating a vessel that will sink faster.

    I personally work as an operator of ship assist tugs in Savannah, Ga. Most of our boats are under 200 Tons. But I am assigned to a 275 GRT vessel, and also work occaisionally on an Escort Tug that is 265 GRT. So one can see what my concerns were with the change in language with my STCW Document being incorporated into my MMC, and the ommision of the Tonnage limitation that was previously on my previous document.

    As I said before, after numerous emailings back and forth to the NMC in West Virginia, the Evaluator continuously told my I had no tonnage limitation to be concerned with under the new license structure. I am amazed that this is the position that they are taking.

    But I can say that I won’t be applying for a Captains position on an ATB without first serving for some period of time as a Mate. And I would think that anyone that would give someone like me the Captains position would be making a huge mistake.

    On the other hand there aren’t going to be any ATB Captains coming into my area of operation without proving they can do ship assist work, before being turned lose either.

    Thanks

    Don McGrady


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