WHAT A DAY!: Coast Guard "Sea Service" Rules Decoded
Licensing and Documentation expert Andy Hammond explores Title 46 Code of Federal Regulations (CFR), Part 10.103 (Definitions) and, specifically, how a DAY is used to calculate the amount of experience a mariner has on a particular vessel. Such a simple word with so many complex and historical meanings! In its most basic scientific explanation, a DAY is a unit of time equivalent to 24 hours. Historically this also represented the time it takes the earth to spin once on its axis. Since going to Atomic time in 1955 and standardized by the United States Naval Observatory, time and thus a DAY, is quite an exact science. Without getting too technical, time is now measured by atomic resonance frequencies. So much for a simpler time when a Day meant from Sunrise to Sunset! What does a DAY have to do with mariners and licensing? In conducting several thousand evaluations for the Coast Guard over the years, this question arises almost daily! (No pun intended) How many hours does it take to make a "DAY" of sea service? What if I'm underway for 24 hours? What if I sleep on my boat? All valid questions. The definition of a "DAY", as it pertains to Coast Guard licensing, can be found in Title 46 Code of Federal Regulations (CFR), Part 10.103 (Definitions). In short, a DAY is used to calculate the amount of experience a mariner has on a particular vessel. The Coast Guard does not use hours or nautical miles, it uses a "DAY". There have been many discussions on what a DAY is. Many will tell you that to be credited with one day of service, anything over 4 hours is fine. While this may be the new norm in licensing circles, the Coast Guard's definition is not that clear nor is it that liberal. A DAY is defined in the regulations as "8 hours of watch standing or day working, not to include overtime". I am not sure why the Coast Guard is concerned with the contractual arrangements of a mariner and his or her employer, but for some reason, OT is clearly stated. Historically it may have stemmed from some specific incident in which a mariner was trying to gain as much experience as possible in the shortest period of time and some casualty, caused by fatigue may have occurred. One way to combat that may have been to add this provision into the definition to take away that incentive. Although speaking from experience, when a mariner is at sea and OT is made available, you take it! We all called on the sea as a profession for different reasons, but if you're out on a ship, you worked as hard and as long as you could to make as much money as possible. The definition goes on to state that "where a 12-hour workday is authorized and practiced, such as a six on-six off watch schedule, each workday MAY be creditable as one and a one half days of service". The Coast Guard has traditionally reserved this credit for segments of the maritime industry that it knows stand this type of watch rotation. Mariners employed on Tug Boats, Dredges, and Offshore Supply Vessels have traditionally been granted this extra time without question. However, this too has begun to change with challenges by mariners and Coast Guard personnel alike. There are many segments of the maritime community that often "work" more than 8 hours in a 24-hour period. Commercial Fisherman, Ferry Boat Crew, Small Passenger Vessels, and others have clearly documented that this credit should be granted. Even in the traditional "deep draft" world where mariners work a three-watch system, a "Day" is not simply standing 8 hours of watch. It never has been. Getting back to the 4-hour issue and where that came from. The last line in the definitions is the source of this confusion. The regulations states "On vessels of less than 100 gross tons, a day is considered as eight hours unless the Officer in Charge, Marine Inspection determines that the vessel's operating schedule makes this criteria inappropriate, in no case will this period be less than four hours". It is clear to me that the intent of this line was to allow mariners who worked on vessels in which an 8-hour day was not practical to seek a waiver, by the OCMI on a case-by-case basis. In other words, the evaluator (who represents the OCMI) would determine that this criterion was met before crediting a "DAY" for anything less than 8 hours. In no case should they credit anything less than 4 hours. I don't interpret this definition as a blanket approval for all mariners, on all vessels getting a day of credit for 4 hours of service. IF that was the true intent, then why only a day and a half for a 12 hour day? Why not 3 days credit? While there are many things to lose sleep on these days, this certainly isn't one of them. However, when calculating your time, in DAYS, be careful how you document your experience and know that the U. S. Coast Guard's definition of a DAY is not such a simple and clearly defined amount of time! Unlike the Naval Observatories Atomic Clock! • About (Captain) Andrew Hammond Andy Hammond graduated from Massachusetts Maritime Academy in 1986 and sailed as an Officer in Charge of a Navigation Watch on various merchant ships until 1994. He then took a position with the U. S. Coast Guard as a Marine Inspector in the Port of Boston. In 1998, he took over as the Senior Inspector of the Regional Examination Center (REC) in Boston until he retired in 2006. Today, he serves the Boston Harbor Pilot Association as their Executive Director and continues to assist mariners as a licensing and documentation consultant through his firm, Maritime Consulting LLC (http://hammondmaritime.com). Additionally, Hammond is qualified as a Coast Guard approved instructor at two approved training institutions.
Link to newsletter archive