Certification Expirations

[Rusty]

I have been working in the Gulf for the past 7 years and will be applying for a raise in grade to a 500 Ton Master. I took BST and Advanced Firefighting more than five years ago. Do I have to retake them or are they still valid ? Thanks for any input.

[danzante]

Your Advanced FF is good forever. Your BST (all of it, not just FF) is a bit different.
BST requires a 3-day refresher if you have less than 12 months of sea service beyond the boundary line in the past 5 years. Essentially, that means that if you only sailed in the GOM, you need to take the 3 day BST refresher.

As a post script, if you don't take the BST, your license will be restricted to less than 200 tons, domestic only.

[jdcavo]

Your Advanced FF is good forever...

Not really. See 46 CFR 10.205(g). It has to be within five years of your application for your first license greater than 200 GRT.

[Capt. Fran]

Not really. See 46 CFR 10.205(g). It has to be within five years of your application for your first license greater than 200 GRT.

I gotta say, this is the kind of thing that NMC just casually tosses out to mariners that absolutely drives me crazy. Inaccurate and incomplete "requirements" that most mariners have never heard about.

First off, Mr. Cavo, you're a little out of date. 46 CFR 10.205(g) is now about validity of MMCs.

Did you meant to quote this?

46 CFR 11.401(g): In order to obtain a master or mate endorsement with a tonnage limit above 200 gross tons, or an endorsement for 200 gross tons or less with an ocean route, whether an original, raise in grade, or increase in the scope of the endorsement authority to a higher tonnage category, the applicant must successfully complete the following training and examination requirements:
(1) Approved firefighting course;

But I see no mention of any time limit. I've checked the NVICs (01-02) and Policy Letters and can't find any mention of 5 years associated with Advanced FF. But, I will admit that I did not do an exhaustive search and do not have all of the cfrs, nvics and policy letters memorized. Final disclaimer, I did not look in the USCG MSM.

Can you accurately clarify, cite and quote the regulation / policy that requires Advanced FF to be within 5 years of your first license greater than 200 GRT?

[Capt. Fran]

1. Is it the new cfr's that NMC is going to cite when they tell a mariner that they have to meet a certain requirement? Then how about putting the new cfr's in parenthesis next to the old ones in your posts?

2. It doesn't really matter if you are posting from home or your office, sir, because your signature always says "Merchant Mariner Credentialing", ergo, you represent the USCG. If you want to just be someone with an opinion, that is totally fine and I recommend getting an anonymous avatar.

3. I'm still fuzzy on why you say his advanced FF has to be within five years of his application for his first license greater than 200 GRT.

Here is the new cfr that you cited:

46 CFR 11.205 (d) Firefighting certificate. Applicants for officer endorsements in the following categories must present a certificate of completion from a firefighting course of instruction which has been approved by the Commandant. The course must have been completed within five years before the date of application for the officer endorsement requested.
(1) Officer endorsement as master on vessels of 200 GRT or less in ocean service.
(2) Officer endorsements as master or mate on vessels of more than 200 GRT.
(3) All officer endorsements for master or mate (pilot) of towing vessels, except apprentice mate (steersman) of the vessels, on oceans.

But, if we look at the title of 46 cfr 11.205, we see that it is titled thusly:
11.205 Requirements for original officer endorsements and STCW endorsements.

If he already has an STCW certificate, and a license (using the old terms on purpose here), then he is not applying for an original officer endorsement.

If he took the Adv. FF for an officer endorsement as <200 Master in Ocean Service, then why wouldn't the Adv. FF still be good for an upgrade?

If I am correct, then my thought is that since we don't actually know what license he holds, perhaps a less casual interpretation of the regs would be in order before the poor sailor thinks he has to spend another thousand bucks on training that he might not need. That is what I mean by "casually" tossing out regulations.

If I am incorrect (and I am not afraid to say that I might very well be), then at the very least I hope to inspire other mariners to not be afraid of digging through the cfrs to make sure they know exactly how the regs relate to their particular situation.