We are an industry where bigger is better and appearances set the standard. With that ever-increasing desire by owners to push the envelope for a yacht’s overall length, we have seen that the safety regulations that dictate how a yacht is constructed and operated have not necessarily kept pace.
In a long-awaited document, the UK’s Maritime and Coastguard Agency (MCA) published a Marine Information Note (MIN) in January. Titled MIN 498 (M), this note finally addresses the sea time needed for a license holder to cross over from the restricted “yachting” system and into the unlimited merchant navy licenses.
The MIN outlines the requirements for deck officers or ratings using yacht service as qualifying seagoing service toward the issue of an unlimited Certificate of Competency. The MIN also contains the new seagoing service testimonials for those working on yachts.
First, let’s review how the MCA will require the sea service to be documented and the types of sea service that will be accepted.
The MCA requires that all yacht service be documented in the form of either (a) yacht service testimonials supported by a discharge book or (b) an MCA-approved logbook. Both of these documents must include an exact breakdown of the actual sea service, stand-by service, and yard time. For the purposes of the MIN, the MCA service definitions are:
The MCA states that seagoing service on yachts will be counted as a combination of actual sea-service, standby service and yard service. There are a few restrictions:
As a result of the above definitions, under no circumstance can stand-by service exceed actual sea service.
Now that the MCA has defined what type of sea service is required, let us review the requirements for the three levels of unlimited tonnage licenses.
To qualify for the issue of an OOW unlimited Certificate of Competency, the candidate must, from the age of 16, have completed 36 months seagoing service. Of that total, it must include at least six months engaged in bridge watchkeeping duties on vessels (including yachts) of more than 24m in length or more than 80 GT.
To qualify for the issue of a Chief Mate unlimited Certificate of Competency, one must have completed 18 months seagoing service as a deck officer while holding an OOW unlimited license. Sea service must be attained on vessels (including yachts) of more than 24m in length or more than 80 GT.
To qualify for the issue of a Master unlimited Certificate of Competency, the candidate must have completed 18 months seagoing service as a deck officer while holding a Chief Mate unlimited license. The sea service must be attained on vessels (including yachts) of more than 24m in length or more than 80 GT.
If an officer already possesses an OOW unlimited or a Chief Mate unlimited Certificate of Competency, and is serving on a yacht, there are additional stipulations to complete before raising to a higher Certificate of Competency. The license holder’s seagoing service requirements listed above must include the completion of:
If a candidate has sea service on a yacht of over 3,000 GT that has spent more than 2/3 of its time proceeding to sea, then that sea service can be counted as per MGN 92 (M), i.e. at the full rate. A breakdown of the vessel’s movements must be provided with the application. This will be assessed by the MCA on a case-by-case basis.
If an officer already holds an MCA OOW for yachts less than 3,000 GT and the officer is applying for an OOW unlimited Certificate of Competency, it is not required to show evidence for six months of watchkeeping duties. If the candidate does not hold an MCA OOW for yachts less than 3,000 GT, one will need a letter from the captain stating that the candidate has been engaged in watchkeeping duties under the supervision of a qualified officer for at least six months.
If one holds an OOW, Chief Mate, or Masters Certificate of Competency limited to yachts of less than 3,000 GT, the officer must first obtain an OOW unlimited license before progressing to a Chief Mate unlimited Certificate of Competency. It is not possible to skip over any of the unlimited licenses.
And finally, the MCA clearly states in the MIN that completing more than four hours watchkeeping within a 24-hour period cannot be counted as more than one day watchkeeping time. For example, if an officer completes a 12-hour watch within a 24-hour period, the officer can only count this as one day of watchkeeping service. Additionally, if the same officer completes two separate six-hour watches within a 24-hour period, the officer can only count this as one day of watchkeeping service.
Capt. Jake DesVergers is chief surveyor for International Yacht Bureau (IYB), an organization that provides flag-state inspection services to yachts on behalf of several administrations. A deck officer graduate of the U.S. Merchant Marine Academy at Kings Point, he previously sailed as master on merchant ships, acted as designated person for a shipping company, and served as regional manager for an international classification society. Contact him at +1 954-596-2728 or www.yachtbureau.org. Comments on this column are welcome at email@example.com.