Question about MMC credentials for passenger sailing ships

[MariaW]

I know this is a tiny portion of the commercial industry, but perhaps someone here can give me a definitive answer to my question. Are there manning requirements for passenger sailing ships in the U.S. beyond the master? Most schooner crew I've known haven't even had an MMC, nor do they talk about the Coast Guard requiring one. There are plenty of ships taking more than 6 passengers that sail from U.S. locations. I've looked at the Coast Guard rules, and they are a little hard for me to decipher. It seems some sailing ships don't require a minimum crew by regulation? The reason I'm asking, is that I'm getting my MMC, and I am wondering if it is an advantage if I have that all squared away if I go apply as a deckhand on a commercial sailing vessel. Experienced crew (on for-profit vessels) I've talked to think it's not required by the Coast Guard, but that doesn't seem right, or does it? Why would a largish sailing vessel taking on lots of passengers not be required to have deckhands with the Coast Guard credential?

[Flyer69]

I know this is a tiny portion of the commercial industry, but perhaps someone here can give me a definitive answer to my question. Are there manning requirements for passenger sailing ships in the U.S. beyond the master? Most schooner crew I've known haven't even had an MMC, nor do they talk about the Coast Guard requiring one. There are plenty of ships taking more than 6 passengers that sail from U.S. locations. I've looked at the Coast Guard rules, and they are a little hard for me to decipher. It seems some sailing ships don't require a minimum crew by regulation? The reason I'm asking, is that I'm getting my MMC, and I am wondering if it is an advantage if I have that all squared away if I go apply as a deckhand on a commercial sailing vessel. Experienced crew (on for-profit vessels) I've talked to think it's not required by the Coast Guard, but that doesn't seem right, or does it? Why would a largish sailing vessel taking on lots of passengers not be required to have deckhands with the Coast Guard credential?

Maybe because they are on domestic near coastal voyages and the COI does not require it?

[PMC]

A COI is a semi-customized document that is only as good as the person who approved it. I worked on a "sail training" vessel that was required to have "an unlicensed engineer". So, according to the COI, a licensed engineer would not have met the requirement. Instead, one would need to look at a person who had no other certification than a TWIC card and say to them: "you are now an unlicensed engineer".

[cappy208]

I believe the distinction is: Small Passenger Vessels (under 100 tons) fall into a 'less than' category. They have less strict: inspection, manning certification, safety equipment, auxiliary equipment and only need a lesser experienced crew.

Remember that to get ( for instance) 100 ton license requires A LOT less time to het than say a 1600 ton license. So the mariner on a less than 100 ton vessel may (and I use that term not for everyone) not be as experienced as someone with a 1600 ton.

To get on the other part of your question, all employees are supposed to have a TWIC. Heck, even truck drivers who go into marine terminal facilities must have a TWIC!

Not to beat a dead horse, but you keep referring to 'paid deckhands position'. Do you have previous sailing experience? On a vessel as big as these auxsail types? I ask, because the paid deckhands are an integral part of the safety and operation of these vessels. The professional deckhand must not just know what/how to do as far a rigging, but you are in charge of not just the direction, but of the safety of the 'pay for play' deckhands. I would be willing to bet most of the people you have talked to weren't honest in their presentation of their capacity aboard. I bet they were actually 'volunteers', not paid crew.

[c.captain]

if the vessel is inspected under Subchapter K or T (ie. <100grt) then the master and any watchstanding mates must be licensed and they do not need able seaman on their MMC...all other crew require nothing to the best of my knowledge if the vessel is not SOLAS.

if the vessel if inspected under Subchapter H then you need licensed deck and engineering officers and certified seamen on both deck and in the engineroom.

There are vessels of almost 250' that are under 100grt! I have heard that the USCG is not longer interpreting the tonnage rules to allow such use of loopholes to get such vessel under tonnage because that is exactly how the rules were being applied. Tonnage openings everythere!


.

[Shadow]

If the boat is inspected for less than 150 it may not require a security plan and only the people with an mmc will require a twic, not to access a secure area but because they have a mmc. You will find a COI for 149 very popular. Is there an advantage to having an mmc for OS and a twic when its not required? It shows you can pass a drug test and background check. This can be huge advantage when applying for an entry-level position. I ve worked in the small passenger vessel industry for a while now and am always amazed at how many new hire deck hands dont make it because they fail their pre employment drug test. It's the only one you get to study for!

[Captain John]

All the passenger vessels (both Power and Sail/aux) I have worked, the COI only requires Master to carry license.

[MariaW]

I believe the distinction is: Small Passenger Vessels (under 100 tons) fall into a 'less than' category. They have less strict: inspection, manning certification, safety equipment, auxiliary equipment and only need a lesser experienced crew.

I knew I left something out when I formulated this question. I am talking about vessels greater than 100grt.

Not to beat a dead horse, but you keep referring to 'paid deckhands position'. Do you have previous sailing experience? On a vessel as big as these auxsail types? I ask, because the paid deckhands are an integral part of the safety and operation of these vessels. The professional deckhand must not just know what/how to do as far a rigging, but you are in charge of not just the direction, but of the safety of the 'pay for play' deckhands. I would be willing to bet most of the people you have talked to weren't honest in their presentation of their capacity aboard. I bet they were actually 'volunteers', not paid crew.

Yes I do have experience. Not enough for an AB, but I have experience as crew on long voyages on sail trainging ships. However, for this question, I was talking about big schooners that take passengers on day sails. The people I've talked to worked on day sailing excursions. I guess I'm wondering why the requirement is waived for these near coastal passenger ships?

[MariaW]

If the boat is inspected for less than 150 it may not require a security plan and only the people with an mmc will require a twic, not to access a secure area but because they have a mmc. You will find a COI for 149 very popular. Is there an advantage to having an mmc for OS and a twic when its not required? It shows you can pass a drug test and background check. This can be huge advantage when applying for an entry-level position. I ve worked in the small passenger vessel industry for a while now and am always amazed at how many new hire deck hands dont make it because they fail their pre employment drug test. It's the only one you get to study for!

The coast guard rules I looked at don't mention 150 grt, just > 100 grt.

[MariaW]

All the passenger vessels (both Power and Sail/aux) I have worked, the COI only requires Master to carry license.

How big were they, Captain John, any over 100 grt? I thought the reason for the MMC requirement is to ensure compliance with the rule that says a large percentage of crew on the ships need to be U.S. citizens, etc.

[MariaW]

Let me go with a concrete example. Let's say the "America" replicas that are out there and take paying passengers on cruises. I think there are at least two, but I might be mistaken. I'm pretty sure they are over 100 grt. Also, a TWIC by itself is not required if you're departing from an unsecured public dock.

[cappy208]

I believe there are a couple around who 'pretend' to be sail training vessels. This puts them in a different category. research and training vessels are exempt from even more regs. I seem to recall a couple of old 12 meters sailing around that were billed as Historical Sail Experience non profit companies. Have you looked up the particular vessels by name on google. There is a National Vessel Registry. All these vessels that have a DOI would be public knowledge. Find out the actual tonnage and vessel classification first, then you can make better assumptions. I believe these type vessels are mainly subchapter R. Sail training Vessels. There is one operating in NY harbor, Hudson River. They word their advertising as: Take a scenic history tour of the harbor and river. While on our trip we will be sampling water to show the diversity of fish, and other sealife. You will come on a educational trip. or some similar other worded cliche. Your post does make me wonder about the majority of these sailing vessels. I can't imagine how they pay the bills, when they only operate about 3 months a year, and I know they don't pay squat to the crew. the Captains seem to be 'cut from a different cloth' so to speak.

[Shadow]

The coast guard rules I looked at don't mention 150 grt, just > 100 grt.

Not 150 GRT, 150 passengers on the COI is the cut off for required vessel security plan and twic cards for crew other than those with an mmc. Over 100 GRT will require everyone on the crew to have an mmd (and therefore a twic) unless the vessel only sails on inland waters. There may be some larger sailing vessels with COIs for lakes, bays, and sounds that just do harbor tours and so can hire deck hands without a mmd or twic.

[cappy208]

Copied directly from the CFR 46 part 169.

This may let you know why all ( not all, but most) these sailing vessels always have some class or another going on.

"Sailing School Vessel means a vessel of less than 500 gross tons, carrying six or more individuals who are sailing school students or sailing school instructors, principally equipped for propulsion by sail even if the vessel has an auxiliary means of propulsion, and owned or demise chartered and operated by a qualified organization during such times as the vessel is operated exclusively for the purposes of sailing instruction."

"Sailing instruction means teaching, research, and practical experience in operating vessels propelled primarily by sail, and may include any subject related to that operation and the sea, including seamanship, navigation, oceanography, other nautical and marine sciences, and maritime history and literature. In conjunction with any of those subjects, “sailing instruction” also includes instruction in mathematics and language arts skills to a sailing school student with a learning disability."

I would love to see what your receipt for one of these 'sailing instruction' trips says. Probably something like, 'good for admittance aboard the XXX for educational sailing experience.'

Note the tonnage allowed under this section alone. Find the names of the boats you are thinking about. If you can't locate the info, PM me, so I can look them up 'tonnage wise' I know you don't want to 'out' them, and I wouldn't either.

Sailing School Student means any person who is aboard a sailing school vessel for the purpose of receiving sailing instruction.

[MariaW]

My question is not about Sailing school vessels or research vessels. Those are not considered commercial. The vessels I am asking about are clearly for profit, and can be seen in any tourist location on the water. Here are some links to my examples. http://www.nextlevelsailing.com/ http://www.sail-nyc.com/html/private_charters.html They don't pretend to be non-profit vessels. There are lots of these out there. Do they require MMDs/MMCs on their crew beyond master or not? If not, why not? What makes them exempt? They are over 100 tons. I am not asking about the TWIC or STCW or security training or anything like that. I'm just asking why they wouldn't need crew with Coast Guard documents because I can't see that in the regulations anywhere.

[Flyer69]

None of those boats are over 100 tons.

[Flyer69]

Here is one of your "America" replicas ... built by Scarano.
http://www.st.nmfs.noaa.gov/pls/webp..._id_in=1034337

[c.captain]

All training vessels whether public or private, profit or nonprofit, sail or motor must be inspected and manned under the same standards of an equivalent tonnage passenger vessel.

[MariaW]

All training vessels whether public or private, profit or nonprofit, sail or motor must be inspected and manned under the same standards of an equivalent tonnage passenger vessel.

Apparently that doesn't apply to sailing vessels.

[Flyer69]

Apparently that doesn't apply to sailing vessels.

Come again?