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USCG- Sea time

Discussion in 'Licensing & Education' started by ychtcptn, Jan 11, 2014.

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  1. ychtcptn

    ychtcptn Senior Member

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    I've always been a stickler on the sea time for my crew members and for myself. I always used 8 hours or more underway as a day at sea, as this is what the CFR's when I got my original license (1990).
    Then at some point they started taking 4-8 hrs, as relayed to me during a renewal when I did not have enough sea time for recency, still "underway"
    Lately I have been doing research on the subject and can not find any where in the CFR''s that say you have to be underway, even under the definition of a day in the CFR's.
    I have many friends in the gulf on the oil boats and they get the sea time from when they get aboard until they get off, regardless of being at sea or the dock.
    I have always been short of days for my renewal, even though I am on a pretty busy boat, but if I went by the definitions of a day in the CFR's I would have no problem.

    46CFR10.107 Defenitions
    Day means, for the purpose of complying with the service requirements of this subchapter, eight hours of watchstanding or day-working not to include overtime. On vessels where a 12-hour working day is authorized and practiced, each work day may be creditable as one and one-half days of service. On vessels of less than 100 gross register tons, a day is considered as eight hours unless the Coast Guard determines that the vessel's operating schedule makes this criteria inappropriate, in no case will this period be less than four hours. When computing service required for MODU endorsements, a day is a minimum of four hours, and no additional credit is received for periods served over eight hours.

    From previous posts I know there are others on here that are really good with the CFR's can you find any where that it says "underway"? It can be found in USCG doc's, but we called the licensing department and they said yes underway, but could not site the CFR.
  2. Pascal

    Pascal Senior Member

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    I believe the above ha to do with maximum allowed sea time per day, not the minimum of what is needed for a day to be counted.

    I don't feel like getting a headache and searching USC but I'm pretty sure that up for OUPV and master up to 200T a day has to be 4 hours underway to be counted. Over 200GT it s 8 hours.

    Obviously this works well in the commercial world but not for yachting where time underway is kept to a minimum so owners and guests can enjoy the destinations....
  3. Capt Bill11

    Capt Bill11 Senior Member

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    You might want to ask this gentleman:

    James D. Cavo
    U.S. Coast Guard
    Mariner Credentialing Program
    Policy Division (CG-5434)
    James.D.Cavo (at) uscg (dot) mil (Admin edit: address modified)
  4. Capt Bill11

    Capt Bill11 Senior Member

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    My question:

    "I'm sure you get this question all the time. But what is the current CG definition of sea time in regards to renewing my captains license? How many hours underway defines a day of sea time? Can any time on board but not underway say at the dock or at anchor be counted toward sea time? Etc."



    His answer:

    "Four hours. Time at the dock as part of normal operations is OK. Time when the vessel is not underway for extended periods is not.

    James D. Cavo
    U.S. Coast Guard
    Mariner Credentialing Program
    Policy Division (CG-CVC-4)"
  5. Pascal

    Pascal Senior Member

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    Interesting, I wonder how they define "as part of normal operation"... Looking at this from a commercial operation, they probably consider a 15 minute dock time between tours or water taxi pick up part of normal operation, but from a pleasure boat perspective, if you spend a couple of hours anchored out, does it still count. I wonder.
  6. Capt Bill11

    Capt Bill11 Senior Member

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    My guess is they don't have the time or people to over think it. And since they are looking at it in a commercial prospective, if your at the dock loading/unloading cargo, passengers or say bunkering I guess it would count. At anchor while not carrying out similar work other than normal day to day duties would not.

    But on a charter boat I would guess you could argue that at anchor tending to guests coming and going in a tender might qualify as "work" other than day to day duties.

    Again, I think you just have to use your best judgement. It's all on the honor system, at least in the noncommercial world, anyway.
  7. Capt J

    Capt J Senior Member

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    Normal operations, would be getting the boat ready to depart, letting the engines warm up and leaving the dock to go somewhere. Anchoring as part of your trip would be ok as it's temporary anchoring. As for days at anchoring, I don't think they count but then again I don't know.....and it's subjective. If you have guests on board, you're working and I think that would count even while at anchor for days.
  8. Wally

    Wally New Member

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    This a great thread as I have struggled with this same issue since working on private yachts. I can never get consistent guidance from sea schools, Coast Guard or other captains. Originally I only submitted to the Coast Guard time that has been acquired on voyages that lasted 4 hours or more. My last renewal was voyages over 4 hours and 24 hour voyages as 1 1/2 days. This has worked for others that I know as well. Now I hear talk of others who are starting to count days at anchor as a half day underway. Reading these posts is starting to make me wonder, if while away from homeport, could an 8 hour work day at the dock doing boat maintenance and voyage ready be counted as a day at sea? I know of a few people who do. If all my voyages are 3 hour lunch cruises can I also add the 5 other hours spent preparing the vessel to count as 1 day underway? Or do I get nothing?
    Its unfortunate that a lot of people abuse the honor system or else I've missed out on a lot of sea time.
  9. Marmot

    Marmot Senior Member

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    You guys really are "overthinking" the issue.

    If you are on the boat with passengers or the owner and underway or at anchor or stopped for a period, you can claim a day.

    If you are tinkeriing on the boat at your home dock with no passengers onboard and no intention of getting underway then you are not underway and can not claim a day.

    There is nothing in the regs about "intent" but since we are not writing regs, it should be obvious to those who are not just looking for justification to falsify their small boat sea service form, that what most yacht crew do most of the time is not underway time.

    Just because you sit on a boat doesn't mean it is underway.
  10. Capt Bill11

    Capt Bill11 Senior Member

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    Exactly. That is how I have always logged my seatime.
  11. NYCAP123

    NYCAP123 Senior Member

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    Lots of over-thinking going on. I've worked mostly small boats for the past 25 years. If I step on a boat I'm working. Now I can't say much about serving drinks, etc., but what's all this "underway" stuff about? like going for a boat ride makes you a better seaman? Even at anchor you're monitoring your anchor, gen, sanitation system, lights, weather, bilge pumps, safety of crew and passengers, making repairs, etc. That's gaining experience, which is what they're measuring by asking for sea time. They're not even asking if you were a conscientious worker or a slug who laid around all day soaking in the sun. It's an honor system that they have a few guidelines set up for to keep us fairly honest. Most small boat captains don't even get their time signed off on. I keep a personal log and use that. I could cheat in all sorts of ways, but I'd be hurting myself.

    Bottom line is that if you've got a good worker who has bothered to learn his craft, I wouldn't be a stickler about what constitutes a day other than more than 4 hours (for 100GTboats). The CG isn't.
  12. Ken Bracewell

    Ken Bracewell Senior Member

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    My rule of thumb has been to give the crew a "day" if we are in-service and we move the boat.
  13. Marmot

    Marmot Senior Member

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    If you have to ask.

    So for all those renewals you talk about, you just submit your "log" instead of a sea service form? "If I step on a boat I'm working" seems to go along with
    "but what's all this "underway" stuff about?"

    That's an interesting take on how you fill out the sea service form.

    Is that 4 hours underway or is it 4 hours after stepping aboard regardless of leaving the dock or not? It's a reasonable question since you are not a "stickler" about that sort of thing?
  14. NYCAP123

    NYCAP123 Senior Member

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    That log acts as verification of the time stated on the sea service form which I submit as my sworn statement. It's been accepted by the CG for 5 renewals.

    My job is such that I don't come aboard to serve drinks or lay on a sun pad. When I step on board I'm working on the boat. Some of that time will be spent cruising, some will be spent preparing the boat to cruise or plotting courses, etc. It's all time gaining experience. Where you may be getting confused is part of the reason I chose not to work the larger boats, i.e. they spend a lot of time sitting on the dock generating no experience beyond how to wash a boat.

    I believe the regulations for under 100 GT are intentionally vague because the job is often very different than on the big boats. Most or at least many of us are not working one boat full-time that may cruise or may sit. We're hired to move the boats.
  15. olderboater

    olderboater Senior Member

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    That statement does resonate some truth I believe. They could have certainly written the rules very specific. They could have spelled out exactly the tasks and hours, when the day starts and when it ends. It makes no sense to think they were somehow made "accidentally vague." Those gaining sea time are doing it many different ways. I suspect it started with them thinking of one type of person gaining time on one specific type boat. That's the easy one. Boat is on the water for days at a time. Each day this person is on watch 8 hours. They do that 30 days and have 30 days sea time. But then they realized that doesn't fit all.

    So they next thought of the person who is on six off six on six off six. Well, that person should somehow geet more sea time credit than the one who is just on 8 hours or even just six. So they decided a day and a half. They didn't say just anytime one worked 12 hours. They said when it was a regular part of how the boat scheduled time. Then you have the smaller boat where those on duty fulfill multiple duties. The captain of a 60 foot yacht doesn't just work during a specific watch period or duty period. They work before, after. They work while someone else is at the helm. Their responsibility extends. And on these boats, the typical day underway isn't 10 hours or 12 or 24. It may be two. It may be 10 hours. But if they're actually moving on the water 3 hours they may anchor another three. They may have worked preparing 2 and work another hour when anchored in the evening. So they decided this doesn't fit as neatly as the charge or duty time on a larger boat. Still they decided they had to say some number of hours minimum and they chose four. They also decided days is the measurement so no hours or part days. Either you get four or more hours and it counts a day or you don't.

    It's confusing. In some ways makes no sense and in others makes perfect sense. I think they should have included more examples of what counts and what doesn't in different situations. But I think they accepted it's not a perfect system. They don't know the quality of training one gets while on duty. They don't know whether the hours recorded are truly helping the potential or existing captain learn more. It's really a system of "we just have to hope that if one is spending the time on duty then they are learning." And for those things that coursework can be provided or tests can be given they address that as well. Funny how other things came into play and had to be provided some credit, things such as time on board while in a training school and time in a simulation module.

    There is nothing about this that evaluates the captain or prospective captain as to whether they're becoming good at their job. No one is attesting that they believe this person has the skills and judgement that they'd hire them to fill the next level job. In fact, where one is running their own boat, they're self attesting to the hours. Are they learning? They don't have a teacher. But then they're certainly gaining experience.

    Then what the Coast Guard expects is that one will check with their credentialing department as Captain Bill did. I am not sure that means they'll always get the same answer. But that is where I would and have taken my questions.

    I intentionally did not bring the answers I'd received into this discussion because they were limited answers to very specific questions and to attempt to apply them to a broader range of questions could be misleading and even corrupting the answer given if it wasn't coupled to the specific question and circumstance. I'd also encourage, just as Capt Bill did, submitting questions in writing and receiving answers back in that way. I would have asked an additional follow up question to the sequence and that is "When you say not underway for extended periods what would you consider an extended period."

    In one way we're over-complicating this because we're trying to figure it out sometimes on our own when we can simply inquire and get an answer to any specific question we have.

    The hope is that if you spend enough time on the job, if you train enough, and if you learn enough information, then you will have the potential to be a Captain at the level granted. Same approach to other jobs. Engineering is just as complicated because there they had to make rules for those totally working land based jobs for periods.

    And whatever rules they set up, half the people are going to be below average and half will be above average. That is for the marketplace to sort out as the credentialing authorities have no way of determining who fits where in that regard. It's no different than other professions. A Lawyer passes the bar and gets some practice time. That says only that they meet the minimum qualification. There are still good lawyers and bad ones. I'm sure many here would say there is an excess of bad ones.
  16. Marmot

    Marmot Senior Member

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    Aside from data collection purposes, the CG doesn't care about the size of the boat named on a Small Vessel Sea Service Form but it defines a small vessel as <200tons (which might be a very large boat) so you can forget the 100T fantasy.

    I suggest you read the sea service form and this document:

    http://www.uscg.mil/nmc/professional_qualifications/pdfs/SVSS_presentation.pdf

    They don't have a block for stepping aboard, just underway ... and there isn't much that can be considered "vague."

    I should add that the Marine Safety manual does a pretty good job of clarifying the issues that some might consider "vague." There is no reason for anyone holding a license to claim the right to exercise vagueries.
  17. olderboater

    olderboater Senior Member

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    The 100 Tons isn't a fantasy. Yes, it does define a small vessel as <200, But then it does also provide an exception to the 8 hour day for vessels under 100 Tons.

    There are other areas that the manual doesn't specifically address, but other guidelines help and then, when in doubt, ask the CG the question.

    Like many who apply for their first ticket, Belle and I had years of experience to document and we did ask several specific questions to confirm that what we were entering was correct and acceptable. We were then prepared if they had any questions, but they didn't as we attached supporting documentation.
  18. ychtcptn

    ychtcptn Senior Member

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    I did notice that the SBSS form is the only place that mentions underway, as my vessel is over 200 tons I do not use it. I have gone online and used the USCG. Sea time calculator and when asked for type of service it does not say underway.
    I revert back to the Defenitions of a day in the CFR's and accordingly count all days that an eight hour day is worked, whether underway or at the dock as a day towards sea time.
    In my opinion the ambiguity is with the USCG not following the CFR's and leaving the individual inspector to determine tha viability of ones sea time.
  19. HTMO9

    HTMO9 Senior Member

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    Seatime

    We have a pretty simple rule as far as seatime and working hours are concerned (both for yachts and commercial ships and I believe our Navy has the same rule).

    When a crew member is showing up for work and is logged on the record of attendance, he is concidered being on board and working. This counts for his duty hour, watch, payment and vacation time calculation.

    When the ship / boat is concidered being "at sea", determined by the entry in the ships log book, the sea time for all crew members starts. And this redardless whether the ship moves from A to B, relocating within the harbour, driving in circles or being on the hook.

    The sea times ends, when the ship is tied to the pier and the engine is called off. Easy as that. The above times will be signed and stamped by the skipper or first officer in the individual seamans record book, regardless of rank.