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Sea time documentation over the 100 and 200GT

Discussion in 'Licensing & Education' started by Pascal, Apr 15, 2022.

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  1. Pascal, Apr 15, 2022
    #1
    Pascal

    Pascal Senior Member

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    The more I try to read the CFRs and various forms, the more confused I get…

    From this USCG document
    https://www.dco.uscg.mil/Portals/9/NMC/pdfs/professional_qualifications/crediting_sea_service.pdf

    ———
    What counts as a “day”?
    • A “day,” as defined by the regulations, is 8 hours of watch-standing or day-working, not to include overtime.
    • Only on vessels of less than 100 gross registered tons (GRT): Credit for a full day will only be given for service of 4 hours or more (See 46 CFR 10.107, definition of “Day”). No credit will ever be given for days in which less than 4 hours were served.
    ——-

    So reading this, when running boats over 100GT, a day needs to be 8 hours not 4. Clearly challenging on yachts where we rarely spend 8 hours under way…

    BUT.. it uses the words “watch standing or day working” which means that if anchored after a 3 hour run, the day would count. This is first official document i see that uses these words. Every other USCG document referred to being under way. To make this even more confusing, page 10 of the same document shows a sample letter which says “consist of 8 hour days UNDERWAY”?

    Confusing…

    To those of you running boats between 100 and 200GT, and over 200GT, how do you document your time?
  2. Capt J, Apr 15, 2022
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    Capt J

    Capt J Senior Member

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    8 hours of watch standing OR day working. Anytime the boat is away from the dock is seatime as you are working.
    rocdiver likes this.
  3. Capt Ralph, Apr 16, 2022
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    Capt Ralph

    Capt Ralph Senior Member

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    It was explained to me, wile onboard a floating vessel. I do not recall any " untied from the dock" or "not anchored" .
    While on board a vessel included tending to the vessels needs, as watch standing, other ship duties or carrying out maintenance.
    Cooking for guest, varnishing trim, tending to waterfront activities, maintenance on water toys onboard, stew, ect, ect,,

    Sadly, you can not collect more than 1 day per day when your preforming guest charters weeks long. Even when you try to sleep, you wake up and check the anchor.

    But I'm only 100GT, I assumed the same when I was going for 200GT.
  4. olderboater, Apr 16, 2022
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    olderboater

    olderboater Senior Member

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    What Capt J says. Underway does not mean it's moving under propulsion. It means it has left one location and is on it's way to another. It includes watch standing and day working and they don't require it to be moving. As to anchoring, it can't be anchored for the night, but if it anchors during the day on it's way, perhaps for some maintenance or other reasons, then that still counts. Example, anchors off a shore awaiting permission from customs to proceed.

    Here is the official definition of underway: The word underway means that a vessel is not at anchor, or made fast to the shore, or aground. A further interpretation says that it may be temporarily at anchor is only part of furthering it's day of movement and not part of an overnight stoppage. Now, that interpretation is not written in the rules anywhere but is widely used. It just doesn't come into play very often.

    Don't overlook the possibility on tenders or center consoles or other boats either. Example: You're anchored in the Exumas, towed a center console with you. You take the guests out on the center console for about 4 hours. That counts. Under 100 tons.
  5. Pascal, Apr 16, 2022
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    Pascal

    Pascal Senior Member

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    That makes sense obviously… i guess it comes down to the definition of “underway”. For some reason the USCG has a way to confuse issues using different wording in various documents
  6. olderboater, Apr 16, 2022
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    olderboater

    olderboater Senior Member

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    You think that is confusing, look at other licensing organizations mixed in, then add in other licenses and endorsements, and shipyard time for engineers and service on boats that don't get underway and port captains and engineers and instructors. Then toss in that with the rules as they are, some are subject then to the interpretation of the person reviewing them. Then you get into things like dual licenses, captain and engineer, which with changes will become things of the past but some still do have.
  7. Pascal, Apr 16, 2022
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    Pascal

    Pascal Senior Member

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    I m sure it is. It’s just a bit silly when within the same document they give you two different definition of what a day is.

    i also noticed that they have changed the tonnage requirement for licenses up to 100 GT For instance in the past you d get 1.5 times the tonnage you have most time of your time on. 15 years ago, most of my time was of my 53 which is 39gt. Times 1.5 was 58 and good enough for 100.

    nowadays, the rules state you need to have most of your time on 51 GT or more to get 100.
  8. rtrafford, Apr 17, 2022
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    rtrafford

    rtrafford Senior Member

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    Are you renewing? Is this where you're getting these updates?
  9. Pascal, Apr 17, 2022
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    Pascal

    Pascal Senior Member

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    Not yet. Just wondering about the recent changes for the smaller licenses as well as sea time requirements on bigger boats after reading posts somewhere else.
  10. Pascal, Jan 26, 2023
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    Pascal

    Pascal Senior Member

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    Well yes now I am renewing and have another question…

    the USCG small vessel sea service form is good for vessels under 200GT. Above that, the form and monthly detail is no longer required and instead a sea time letter from maritime employer needs to be submitted on company letter head with the total number of days.

    I am assuming that such a letter from the LLC which owns the boat is satisfactory. Right?
  11. Capt Ralph, Jan 26, 2023
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    Capt Ralph

    Capt Ralph Senior Member

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    I have over-viewed my partners letters he receives from his employer.
    The one page letter states times of full time employment (Jan 1, Dec 31) and rough picture of his days on board. More or less just a day count.
    His travel to and dust-off from, is included in the day count.
    A very minimal description off the ship and seas covered thru the years.
    He works 4weeks on, 4 weeks off. Unlimited, all seas.

    Your personal company secretary (wife and your company name) can also include your other charter work. I remember you used to do northern coastal runs.

    I remember the kids at the license office in the Claude Pepper Federal Building were most helpful face to face,,, many years ago.
    My last query, I called direct up north, a very nice lady helped me greatly by phone, just a couple of years ago.
    Last edited: Jan 26, 2023
  12. Pascal, Jan 26, 2023
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    Pascal

    Pascal Senior Member

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    This is for the 110 I run, owned by the owner’s LLC so I ll get the company manager to sign like I did last time for the 84. I got plenty of sea time incl on our personal 53 which I can sign for.

    it s all submitted on line electronically nowadays, no need to go to the federal building
  13. Capt Ralph, Jan 26, 2023
    #13
    Capt Ralph

    Capt Ralph Senior Member

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    [QUOTE="Pascal, post: 338790, member: 13724"
    it s all submitted on line electronically nowadays, no need to go to the federal building[/QUOTE]
    But it is so cool they will spend time with you and are (to me) really helpful when questions come up.

    We all learned "Government" is a foreign language. Our training was mostly to understand the lingo. Then answer the questions correctly.
    The forms are the same way. But it is not a test filling out the forms.
    What I'm trying to say, as for me on my phone call a couple of years ago, she went went thru the form line by line with me.
    Zero issues when submitted.

    I'm good that I had a good answer for you.
    Just repeating, they can give you an official answer and help very well if needed.
    When in doubt, ask the kids than make the rules.
  14. Norseman, Jan 26, 2023
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    Norseman

    Norseman Senior Member

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    It says not Anchored or Moored (Over 100 gross tons)

    The above from a school however, not the CG..
  15. Capt J, Jan 26, 2023
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    Capt J

    Capt J Senior Member

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    Yes, but look up a sample letter. I would also make sure you break it up and list amount of days seaward of that boundary line (which most of yours should be).