That is patently incorrect. He is running an operation and vessel which takes passengers for hire, that makes him a professional mariner and subject to being held to the standards of his license testing. The OUPV witten is from the exact same book as the 100 and 200 ton masters exam. When they hand you the test book at the USCG REC all three are listed on the cover. The difference in which license is issued as the result of that test is one of time on tonnage and what you ask for on your application. The standards of performance you are liable for are the same whether you hold an OUPV or an Unlimited Level license. The test he took is meant to be taken using the CFR as a direct reference when answering the Deck General module of questions. When studying for the test happens the proper way, the candidate will have spent at least 10-12 hrs doing research in the CFRs and will be well versed at it. The CFRs are actually very well laid out and indexed. When I learned all this, we didn't have computers for it. You studied using a paper copy of the CFRs and physically looking up answers to the test bank questions. As I said earlier, I'm betting Capt Ryan used a "Learn the Test" based licensing program. This is actually an issue I have been dealing with and battling as a captain, especially when, as I frequently do, serve a company as their training captain get the new guys up to speed. The problem is really with the training system more so than the candidates. As you know, there are basically two ways to come up with an entry USCG license. You either have recreationally been on/ around/ owned boats for a few years or you have been working in an unlicensed capacity on them. For those who come up the recreational side direct to ticket, typically will go to a school, either on line or brick and mortar. What I see is that the people who went to a "learn the test" program, unless they came from working with a strong captain who likes to train, were much poorer in their knowledge base than those who attended class in a program that taught you and actually filled in the knowledge gaps required to answer the questions by figuring out the problem posed. You think I'm being mean but I'm not. I'm just being blunt and letting a new guy know that he is lacking knowledge and pick up the slack.