Sea time calculation for Dynamically Positioned MODU's

[Capt. Lee]

I have an ongoing problem in regards to sea time calculation for the vessel I work on. It is a Dynamically Positioned Column Stabilized Mobile Offshore Drilling Unit the West Sirius. IMO# 8768402, GT 30,326, NT 9,070, HP 52,224, Panamanian Flagged. We are held on location with the sole use of our thrusters. Even when we are drilling we are officially underway 24 hours a day.

<table border="0" cellpadding="0" cellspacing="0"><tbody><tr><td style="font-family: inherit; font-style: inherit; font-variant: inherit; font-weight: inherit; font-size: inherit; line-height: inherit; font-size-adjust: inherit; font-stretch: inherit;" valign="top"><style> <!-- #yiv420291948 _filtered #yiv420291948 {font-family:"Angsana New";panose-1:2 2 6 3 5 4 5 2 3 4;} _filtered #yiv420291948 {font-family:"Cambria Math";panose-1:2 4 5 3 5 4 6 3 2 4;} #yiv420291948 #yiv420291948 p.MsoNormal, #yiv420291948 li.MsoNormal, #yiv420291948 div.MsoNormal {margin:0in;margin-bottom:.0001pt;font-size:12.0pt;font-family:"serif";} #yiv420291948 .MsoChpDefault {font-size:10.0pt;} _filtered #yiv420291948 {margin:1.0in 1.0in 1.0in 1.0in;} #yiv420291948 div.Section1 {} --> </style>On vessels where a 12 hour working day is authorized and practiced, such as on a six-on, six-off watch schedule, each work day may be creditable as one and one half days of service.</td></tr></tbody></table>
We do work a 2 watch system 12 hours per day. I have read and referenced all CFR's, but there is no differentiation between a normal moored MODU and a Dynamically Positioned MODU. I know in the past that service on these types of vessel was credited for 1.5 days for each day worked. I think that our vessel is being confused with moored MODU's. Any thoughts?

My question is has anyone here experienced this in the past and how was the issue resolved? I wrote an e-mail to NMC West Virginia for verification, but an engineer onboard had his reconsideration for his upgrade to 2AE denied due to not enough sea days, because of the 8 hour calculation versus the 12 hour calculation. The letter was from a Lt. Commander, Deputy Chief of mariner evaluations division. So I am sure he thoroughly investigated the application and it is highly unlikely that he will budge from this decision. From everything I have read, we will only get 8 hour days in the future.

46 CFR 10.227
46 CFR 10.107
46 CFR 11.211

[shippedout]

How does the COI read? My guess is that is has more to do with your tonnage than it does confusion with a moored MODU.

[Capt. Lee]

How does the COI read? My guess is that is has more to do with your tonnage than it does confusion with a moored MODU.

I don't think it is the tonnage because in the Lt. Commander's response the issue is never addressed. It is the MODU definition being generalized because we are on a two watch system. That says one thing and the MODU says a minimum of 4 hours, but not more than 8 hours of sea service per day. I do not think this has been revised and I know this has come up before, because I have heard of people fighting with the Coast Guard about it. I hope to be enlightened.

[rich]

This has helped me in the past: It has been 5 years since I got my UN Master's so I don't know if they still use the manual or allow 1.5 days. It is a quote from the Marine Safety Manual Volume III Chapter 10 par. 5

Service On MODUs.
Service aboard self-propelled, dynamically positioned MODUs which are not anchored or otherwise bottom bearing will be credited without restriction towards all grades of unlimited deck licenses in the same manner as conventional vessels. All other MODU service will be credited in accordance with 46 CFR 10.211(c).

On my sea service letters we used to cite that manual passage and then mention Mr. XXXXXX has a required 12 hour working day as per CFR XXXX and request his service be credited as one and one half days of service.
Then we put the total days as the 12 hour number to leave out any calculations for them.

[rich]

http://www.uscg.mil/directives/cim/1...M_16000_8B.pdf

[Capt. Lee]

This has helped me in the past: It has been 5 years since I got my UN Master's so I don't know if they still use the manual or allow 1.5 days. It is a quote from the Marine Safety Manual Volume III Chapter 10 par. 5

Service On MODUs.
Service aboard self-propelled, dynamically positioned MODUs which are not anchored or otherwise bottom bearing will be credited without restriction towards all grades of unlimited deck licenses in the same manner as conventional vessels. All other MODU service will be credited in accordance with 46 CFR 10.211(c).

The Lt. Commander's letter actually quoted this also. Where the misinterpretation is in the last sentence. He gives credit for the unlimited service. Then uses the all other MODU service will be creditied in accordance....

That is the problem. This is making an exception for dynamically positioned MODU's. SO he uses part of it for the unlimited credit, but then uses the sea service CFR for ALL OTHER MODU service to calculate sea days at 8 hours. He does not see the delineation between the two. I am going to try to get him on the phone Monday. Hopefully he will be receptive to another perspective.

[anchorman]

http://www.uscg.mil/directives/cim/1...M_16000_8B.pdf

Everyone seems to forget that one. I know of a few things in the MSM that the Coast Guard has decided not to honor.

* I think John said he had problem when getting his Master license a few years back....same problem.

Lee,
Just apply as though you have enough time @ 240 days and have it written as 12 hour days as appropriate. Type of vessel, designate that as generic. Such as "drilling vessel", without using the CFR term "MODU". I don't think you will have a problem.
Most of those guy don't know the difference between a traction winch and a CPP....because it's not in the CFR, so stay out of the lingo if you can..(red flag)
It's worth a shot.

[Capt. Lee]

I will, but I have not had this problem. It is several 3AE's on here trying to get their 2AE. Also, we have a couple of AB's going for their 3rd Mate's license. I would like to get everyone on the same page with this. Their applications are pending or have been denied. Just doing a little homework.

[JBPA]

I will, but I have not had this problem. It is several 3AE's on here trying to get their 2AE. Also, we have a couple of AB's going for their 3rd Mate's license. I would like to get everyone on the same page with this. Their applications are pending or have been denied. Just doing a little homework.

Thank you for doing this. I was recently shot down when I applied to take my Chief Mate's license luckily I was able to dig up some sea time letters from my last company. Also a 3rd Mate on my ship was just denied time and a half. It's really pretty wrong not to give us the sea time credit we deserve, we work 12 hours we deserve time a half. Let us know what you find out. Thanks again.

[Capt. Lee]

I got this response today. Hopefully I will hear something soon.

Mr. Freeman,
This is to acknowledge receipt of your email regarding sea service on dynamically positioned MODUs. I've forwarded your request to my technical staff, who will provide a direct response to you.

Regards,
Dave

Captain David C. Stalfort
Commanding Officer
U.S. Coast Guard National Maritime Center
100 Forbes Drive,

I was surprised to get a response. I hope this can be resolved. There are several guys that may miss opportunities, because they did not get this credit.

[anchorman]

Regardless of his response, you already know what you're going to do. He always sent an immediate response to my emails, but the actual answers took much longer than going through iasknmc@uscg.mil - he will always get back with you.

[Capt. Lee]

Regardless of his response, you already know what you're going to do. He always sent an immediate response to my emails, but the actual answers took much longer than going through iasknmc@uscg.mil - he will always get back with you.

I was afraid of that. The delay could cost some guys missed opportunities, that could cost them thousands. What I hope to achieve from this is to prevent this from happening in the future and have a reference to provide to a stubborn evaluator.

[Shellback]

I was afraid of that. The delay could cost some guys missed opportunities, that could cost them thousands. What I hope to achieve from this is to prevent this from happening in the future and have a reference to provide to a stubborn evaluator.

Capt lee, what you are doing is commendable, instead of just thinking of your self, you are leading by example and making a difference for those who come after you...Just like when you bought Anchorman that 350.00 dinner, always putting others ahead of yourself.....Well done..

[anchorman]

I was afraid of that. The delay could cost some guys missed opportunities, that could cost them thousands. What I hope to achieve from this is to prevent this from happening in the future and have a reference to provide to a stubborn evaluator.

It's not just the stubborn evaluator based on that letter I reviewed. I think you should post that reconsideration response in this thread. Take the guys personal information out, of course.

Did he not ask for reconsideration, and that was rejected? Regarding that guy, you are afforded that opportunity with NMC. I you disagree with that decision, you can appeal that decision to USCG Head Quarters. Not saying that will do any good. This is an old problem that's been around for a while.

[devdrill]

I ran into this problem two months ago. The coast guard will need documentation that your vessel is indeed a dp vessel. Your licensing division with (Seadrill?) should help you with thhis. It is confusing becuase the coast guard wont come out and say that you need documentation to proved that it is a DP vessel

[devdrill]

again just to clarify. You will need to proved that your vessel is a DP MODU and not just a MODU

[seadawg]

might consider requesting specifics from the NMC as to what part of a 12 hour DP mode watch on a DP MODU is not "considered" as "underway" time..further request they cite the appropriate CFR, NVIC, "policy letter", "internal" memorandum, etc.??

[Capt. Lee]

This is not good news.

Mr. Freeman,

In response to your below email to CAPT Stalfort, below is clarification on sea time calculation for dynamically positioned MODUs.

Please understand that the NMC refers to 46 CFR 10.107 (b), specifically the definition of a day. A portion of this definition specifies service in regards to MODUs. This portion reads that when computing service required for MODU endorsements, a day is a minimum of four hours, and no additional credit is received for periods served over eight hours.

Time and one half credit for service is permitted for 12 hour days served, however 46 CFR 10.107(b) excludes MODUs from this allowance. 46 CFR 10.107 has been challenged that the correct interpretation should be service toward a MODU endorsement, meaning Offshore Installation Manager (OIM), Barge Supervisor (BS), Ballast Control Operator (BCO), Chief Engineer MODU and/or Assistant Engineer MODU. Due to the fact that the regulation does not specify this definition any further, this definition has been interpreted to mean any endorsement regarding MODUs, whether it is the service submitted or the credential applied for. MSM Vol. III, Ch. 2 (G) details the policy behind the allowance of time and one half sea service credit for a 12 hour day.

In addition, MSM Vol. III Ch. 10 (B) (5) states that service on self-propelled dynamically positioned MODUs which are not anchored or otherwise bottom bearing will be credited without restriction towards all grades of unlimited deck license in the same manner as conventional vessels. The NMC has upheld this policy by crediting service on MODU's toward raises of grade in the same manner as conventional vessels. In accordance with MSM Vol. III Ch. 2 (G) (1) on vessels upon which the six on/six off watch schedule may be used, time and one half will be credited for each 12 hour day in that capacity, meaning that not all conventional vessels can be credited time and one half. Per 46 CFR 10.107(b) time and one half credit is not permitted for MODUs, therefore the NMC has upheld both regulations.

This portion of the MSM also states that all other MODU service will be credited in accordance with 46 CFR 11.211(c). 46 CFR 11.211(c) states that service on MODUs is creditable for raise of grade of a license. Evidence of one year's service as engineering officer of the watch or equivalent while holding an officer endorsement or license as third assistant engineer is acceptable for a raise of grade to second assistant engineer. The NMC has also upheld this regulation in our evaluations by placing applications in pending status while we await submission of one year of service.

A letter from Captain Boothe of the NMC, dated May 2, 2000, has been presented to support time and one half credit for 12 hour days. The letter does not address time and one half credit for 12 hour days on MODUs, and therefore cannot be a means of obtaining time and one half credit on MODUs. It states that Captain Boothe considers service on a self-propelled, dynamically positioned MODU, maintaining station by means of dynamic positioning, to be "underway" even if connected to the seabed by drill pipe or marine drilling riser. Such service shall be credited without restriction toward license upgrade for both deck and engineering licenses. This letter addresses what type of MODU service shall be considered "underway" service, further clarifying MSM Volume III(10)(B)(5).

Regards,
LT Braker

[Jeffrox]

That clears it up!! It seems that one paragraph reads NO and the next paragraph reads YES, then NO, then YES, then NO then YES. WTF-over? All these conflicting sources of regulaions and interpetation of same is madness. Good luck to the guys on the MODUs