Question for Mr. Cavo\Recency

[Marlowe]

Mr. Cavo,

I'm going to beat this topic to death: I qualify for a 3rd Mate's Unlimited Oceans license based on graduation from one of the academy's listed in 46 CFR 11.407. I have never held a license. According to a fairly recent evaluation I meet all the requirements aside from 90 days recency. The question: Must 50% of the recency be served on vessels >1600 tons. What would happen if I submitted 90 days of time on vessels > 200 tons but < 1600 tons? Could I be approved to test and issued some kind of limited license or..?

[New3M]

Your bigger problem might be getting the academy to release your records. Most of them won't let you use your time there to gain a license after the fact, because the seatime is significantly less than it would be if you went the hawespipe route.

[Marlowe]

Your bigger problem might be getting the academy to release your records. Most of them won't let you use your time there to gain a license after the fact, because the seatime is significantly less than it would be if you went the hawespipe route.

I have already been evaluated and meet the service requirements for an unlimited license aside from recency. The actual sea time received while in school doesn't really come into play because it's graduation from the approved program that is what qualifies the academy applicant. Incidentally all of the time I do have is aboard unlimited tonnage vessels greater than 9,000 tons and most of it is on vessels greater than 10,000 tons.


The issue is that I graduated more than 3 years ago and didn't sit for my license because of a medical issue. Now I have a shore side job that I don’t want to jeopardize (in this economy) in order to go to sea to get the recency. I can however get loads of time locally on vessels greater 200 tons but less than 1600 tons (in my spare time) and I want the license. The standard interpretation for recency toward an unlimited license is that all time must be aboard vessels greater 200 tons and 50% of the time must be aboard vessels greater than 1600 tons.

My question is whether I can sit for the test and receive a limitation according to this…

46 CFR 11.202

“(b) If the applicant for an endorsement as master or mate does not have the service on vessels over 1600 gross tons required by paragraph (a) of this section, or is qualifying for third mate under the provisions of §11.407(c) of this subpart, a tonnage limitation is placed on the endorsement based on the applicant's qualifying experience. The endorsement is limited to the maximum tonnage on which at least 25 percent of the required experience was obtained, or 150 percent of the maximum tonnage on which at least 50 percent of the service was obtained, whichever is higher. Limitations are in multiples of 1000 gross tons, using the next higher figure when an intermediate tonnage is calculated. When the calculated limitation equals or exceeds 10,000 gross tons, the applicant is issued an unlimited tonnage endorsement.”

Let’s assume I send in a sea service letter documenting 90 days service in the last 3 years on vessels greater than 200 tons but less than 1600 tons. Does the paragraph above mean I can sit and get a limitation? Let’s be optimistic and assume yes! Given that limitation either rule lands me beyond 10,000 tons and an unlimited license anyway. But who knows if it even matters since I’m an academy grad and am not qualifying based on the time alone. Frankly the difference in tonnage isn’t going to make a whole lot of difference and I’ll be just as qualified (or unqualified depending on your perspective) as I was the day I graduated.

[jdcavo]

I'll try to answer next week. I'm out of the office this week at a "Maritime eLearning Conference" and have limited opportunty to respond. If you can get back to me with details like when you graduated, which academy, etc. it will help. Send to James.D.Cavo@uscg.mil if you don't want to put them here.

[Marlowe]

I'll try to answer next week. I'm out of the office this week at a "Maritime eLearning Conference" and have limited opportunty to respond. If you can get back to me with details like when you graduated, which academy, etc. it will help. Send to James.D.Cavo@uscg.mil if you don't want to put them here.

Tks - I sent you a PM.