Licenses of less than 500 GT, how does STCW affect me

16 Oct 2017 by Captain Ted Morley

We’ve had a fair amountof focus lately on the larger yachts in our industry and the specific needs of the crew aboard. A segment we haven’t addressed in detail, and one that we have been fielding a lot of reader inquiries about, is the smaller yachts that are less than 500 GT with smaller crew sizes. Typical yachts in this trade include large sportfish, passenger yachts in the 80-100’ (25-30m) range, dive boats, etc. There has been some confusion as to what size vessel the STCW Code applies to and if it applies to licenses under the 200GRT/500 GT level licenses.

 Assuming you have a US issued license and the vessel you are working on never goes out of the US all you have to comply with is the US Domestic Regulations. However, if your vessel travels to a foreign country you are no longer operating domestically and must comply with the International Regulations that pertain to vessels of less than 500 GT. These requirements can include additional training, assessments, and sea service under the authority of the license. Remember, if you are serving on a foreign flag vessel operating in US waters you are in fact on an international voyage. For U.S. mariners, information can be found in CFR 46 11.201 and in NVIC 13-14; and for international mariners information can be found in the STCW Code Table A-II/2 and A-II/3 as well as in the MCA MSN 1858. Port State enforcement is becoming more and more commonplace and many of the questions we are hearing originate after a mariner is confronted by a Port State Officer.  The MCA guidance also has recommendations for STCW PSCRB instead of the Advanced Sea Survival for Yachtsmen, due to the potential problems of Port State Control Officers outside the UK not accepting non-STCW training. Also, the ISPS Code may apply as well if you are serving on vessels that fall under that regulation; these would require you to comply with STCW A-VI/6-4, and STCW A-VI/6-6 to 8.   

 Here’s the link for the official USCG checklist for Master, less than 500 GT.

www.dco.uscg.mil/Portals/9/NMC/pdfs/checklists/mcp_fm_nmc5_208_web.pdf

 Here’s the link for the MCA MSN 1858

https://www.gov.uk/government/publications/msn-1858-mf-uk-requirements-for-deck-officers-on-large-yachts-over-24m.

  

-          I am serving as Master on a “red ensign” 26m yacht that is less than 200 GT that travels from the U.S. to the Bahamas and around the Caribbean, will a Yachtmaster or equivalent credential be enough? The answer is yes, assuming it is commercially endorsed and you have all the requisite certificates such as your ENG1, SRC, and the minimum BST certificates. However, you may want to apply to upgrade to a Master CoC to avoid any issues with overseas administrations.  With that you would be fully compliant with STCW and fully recognized by overseas administrations.

 

-          How about if I am an American serving on a 95 ton U.S. flag yacht that is chartering in the Bahamas and the BVIs? Will my 100 ton license be enough? Again, assuming it is not restricted as a “National Endorsement Only” and you have complied with all the STCW requirements to serve as Master on vessels of less than 500 GT, then yes. If you have not, than the local Port State may detain your vessel for insufficient manning.  

 

Both of these scenarios assume that all other certifications, charter arrangements, cruising permits, and local requirements have been complied with. Consult with your yacht management firm or agent to ensure that your vessel complies with all the pertinent rules and regulations.

  Domestic and Recreational licenses are not sufficient for mariners that are engaged in commercial trade on international voyages.  Well what is considered commercial trade? The simple explanation is if the vessel is being paid or if you are being paid to be there, that would be considered “engaged in commercial trade”.

A clear understanding of the requirements will help prevent issues in foreign ports.

 Captain Morley is the Chief Operations Officer at MPT in Ft Lauderdale Fl. He holds several licenses, including a USCG Master Unlimited Tonnage and is an Associate Fellow of the Nautical Institute as well as a Member of the Royal Institute of Navigation in London. For more information, or questions, please email him at Training@mptusa.com or call 1-954-525-1014.