Coast Guard wont give me 1.5 days time on a crew boat under 100 tons

[orangejulius]

So today I think I was thrown a new curve ball! The coast guard is saying that they will not issue a day and a half sea time for service on a vessel under a 100 tons now. I am going to be protesting this as my COI clearly states 1 master and 1 mate is required. My sea time clearly states the days are 12 hours underway. My evaluator quoted that they are not allowed to give 1.5 days of sea time for vessels UNDER 100 tons? He said that I will have to write a letter of protest. anyone have any info on this would be much appreciated.

[anchorman]

So today I think I was thrown a new curve ball! The coast guard is saying that they will not issue a day and a half sea time for service on a vessel under a 100 tons now. I am going to be protesting this as my COI clearly states 1 master and 1 mate is required. My sea time clearly states the days are 12 hours underway. My evaluator quoted that they are not allowed to give 1.5 days of sea time for vessels UNDER 100 tons? He said that I will have to write a letter of protest. anyone have any info on this would be much appreciated.

What position?

[cappy208]

I think your most logical way to debate this is in your statement. The CoastGuard states the minimum manning requirements for the vessel you worked on. They then can't say, they won't allow the use of 12 hour days on the same vessel that is authorized to have a two man watch.

[anchorman]

I think your most logical way to debate this is in your statement. The CoastGuard states the minimum manning requirements for the vessel you worked on. They then can't say, they won't allow the use of 12 hour days on the same vessel that is authorized to have a two man watch.

They can if you're an oiler, but since he keyed on the Master / Mate, I assume he is one or the other. That should be 12 hours - 1.5 days; there are exception to vessels below 100 tons, but I do not believe that includes OSV's.

[orangejulius]

Yes I run as Captain/Mate. I am looking at a copy of our COI right now this vessel MUST be manned with the following licensed 1 Master and 1 licensed Mate plus 2 deckhands. The service on the COI States passenger (Inspected). Gross ton 93. The only place it states 1 master and 2 deckhands is on voyages under 12 hours on ocean. This is just kinda thrown me for a curve ball last months I submitted the same time from the same vessel and was given 1.5 days for each day. Now 2 weeks ago I submitted more time to my evaluator with the original time on there plus my time that I needed to qualify for my 500 ton master. Now he is counting that time as 1 for 1 saying that if I want the 1.5 I will have to go for a review because of it being under 100 gross tons.
Thanks for the help everyone!

[Capt. Phoenix]

Follow cappy's advice. Send then a copy of your coi and say that according to the uscg your vessel is approved for 12 hour days, you were working 12 hour days, and thus deserve the 1.5 credit. I would like to see the cfr or usc citation for not allowing the 1.5 days on vessels under 100 grt.

To the person who mentioned oilers, the rules specifically say oilers cannot work more than 8 hours. They cannot get 1.5 day credit because they are not allowed to work 12 hour days, even if they actually do. Oilers might want to make an anonymous phone call to their local cotp and say the company is violating the cfr's if they are being told to work 12 hour days. Maybe then the companies will work to get that rule overturned or modernized.

[orangejulius]

Well I just got off the phone with someone at the Coast guard and it wasnt my evaluator now im getting something slightly different. He is quoting the Marine safety manual volume three 2-9G regarding manning on time and one half sea service credit ( http://www.uscg.mil/directives/cim/1...M_16000_8B.pdf ). Basically stating that my vessel isnt running six on six off watch I wont be getting it? I dont see how they can do that when I hold a 12 hour watch as a Officer? I am just trying to get everything in order before I fire off a protest I dont want to give them any loop hole to get out of giving me what I have earned.

[KPEngineer]

Do you do a 6 and 6? A literal reading says it must be six and six and not just 12 hr of watch.

I would just get a new sea time letter that states you do 6x6 assuming that is what you do.

[orangejulius]

I Do a 12 midnight to 12 noon in the bridge so the Master can sleep He relieves me at noon to midnight. It is the same thing it is the same amount of time on watch per day. the CFR says 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.
qouted from ( http://edocket.access.gpo.gov/cfr_20...6cfr10.107.pdf )
I guess I am going to have to prove to the Coast guard that I am on watch for 12 hours and my boat is only required a 2 system watch? Would my COI suffice or will i need more?

[Capt. Phoenix]

Your sea service letter needs to say that your vessel operates 24 hours a day and you are on watch 12 hours each day. If you work 12 hours then go home for the night you do not get 1.5 days and I think they are more critical of smaller vessels because they are more likely to be day boats. Try having the letter rewritten to reflect that your vessel runs 24 hours a day.

[DVanNevel]

Well I just got off the phone with someone at the Coast guard and it wasnt my evaluator now im getting something slightly different. He is quoting the Marine safety manual volume three 2-9G regarding manning on time and one half sea service credit ( http://www.uscg.mil/directives/cim/1...M_16000_8B.pdf ). Basically stating that my vessel isnt running six on six off watch I wont be getting it? I dont see how they can do that when I hold a 12 hour watch as a Officer? I am just trying to get everything in order before I fire off a protest I dont want to give them any loop hole to get out of giving me what I have earned.

But, the MSM page 2-9, paragraph 2.G.3 says "Some inland vessels not subject to the 2 or 3 watch system have in place a 12 hour watch rotation. If the REC can verify that such a schedule is practiced and legal, day and a half credit may be granted."

[Jemplayer]

EXACTLY what did you sea time letter say? Leave out your name, SS number, and boats on. Just the legal sounding stuff.

I just upgraded to a 500 ton with about a years worth of sea time on a crew boat, so there has to be something that they didn't put that they are looking for but don't want to tell you.

[orangejulius]

Dear sir,
Please be advised that blah blah ssn is employed by blah blah as captain. The following is an accumulation of blah blah sea time.
Vessel name. Official number. Type gross tonnage hp position from to days underway
Mv blah. 1222122112. Crew boat 92 7200 01/06/10 10/06/11 466.50

Total days underway 466.50
This listed sea time consist of 12 hour days underway on near coastal.

Also I have another from a private boat that I run on my off time a couple days a month as captain. I know I will only recieve eight hour days for that vessel. Those 466.50 days are split up into four different crew boats but they are all the same tonnage and coi. Looking at this I guess where it list "seatime consist of 12 hour days underway on near coastal." I am guessing that needs to read 12 hours a day of watch standing while under way on near coastal? I really appreciate all the help people just trying to not get set back another six or more months. If need be I can blank out my sea time letter and scan it but I'd rather it not be out there.

[Capt. Phoenix]

Correct, the way the letter is worded makes it sound like the vessel is only underway for 12 hours a day, then you go home. Try having it worded "12 hours of watchstanding while underway 24 hours a day on near coastal voyages" for the utmost clarity, though your wording should be sufficient.

[orangejulius]

I think the way I am going to approach this is get the head of our human resources to write out that for each day I spend on board the vessels is serving a 12 hour watch in the bridge and that the vessel is operational under a 2 man watch system with the vessel operating 24 hours a day. I read in the cfrs under the appeal process that I have to write out the problem and such correct?

[Capt. Phoenix]

Is it too late to just have your sea service letter rewritten and resubmit it?

[orangejulius]

The coast guard official handling my applications says he is not authorized to give me 1.5 days. That I will have to go thought a appeal to get my 1.5 time. I find this absurd that he does not have the power to see that I serve twelve hours a day on watch under a two man system and qualify for 1.5 days. He continues to read the cfr and refuses to listen to the parameters that the coast guard requires that my vessel operate under.

[Capt. Phoenix]

Have the sea time letter rewritten and submit it, and if he sticks with his current story then I guess you have to appeal. It should be an ready appeal though. Good luck.

[Louis]

To count your days of seagoing service accurately,you must understand that a "day" is defined in the regulations as eight hours of watch-standing or day-working not to include overtime. For vessels under 100 GRT, however the OCMI may give a day's credit for less than eight hours,but in no case will the acceptable period be less than four hours. Thirty days are considered to be one month,and 12 of those thirty day months add up to be one 360-day year on the coast guard's calender. If you work on a vessel where a 12-hour day is authorized and practiced ( crewboats,supply boats, towboats, and some commercial fishing boats), you can claim one-and-a-half days for each 12 hour day worked. To claim this time,your documentation of service must specifically state that you worked 12 hours per day. remember sea service time means time on the vessel - not time of employment.

[Capt. Phoenix]

Louis, just serving a 12 hour day on a boat does not entitle you to 1.5 days sea time. If you are on a tug and work a 12 hour day, them tour the boat up and go home, you are not supposed to get the 1.5 day credit. His sea time letter covered everything you mentioned but that is not enough to satisfy the requirements. It needs to indicate that he was on watch 12 hours a day and that the vessel was operational 24 hours a day.