Recent changes to federal regulations have resulted in some changes to the renewal requirements for Merchant Mariner Credential (MMC) Towing Officer Endorsements.
46 CFR 10.227 Requirements for renewal paragraph (e)(6) states that:
An applicant for renewal of an endorsement as master or mate (pilot) of towing vessels, in addition to the other requirements in this paragraph, must also submit satisfactory evidence of having completed a practical demonstration of maneuvering and handling a towing vessel to the satisfaction of a designated examiner; OR ongoing participation in training and drills during the validity of the license or MMC being renewed.
46 CFR 11.480 Radar Observer paragraph (g) states that:
The Coast Guard will accept on-board training and experience through acceptable documentary evidence of 1 year of relevant sea service within the last 5 years in a position that routinely uses radar for navigation and collision avoidance purposes on vessels equipped with radar as meeting the refresher or re-certification requirements of paragraph (d) of this section. This also applies to mariners applying for raises of grade or new endorsements under 46 CFR 10.231.
When renewing an MMC Towing Officer Endorsement the sea service letter from the company should document a minimum of 360-days of experience in past five years AND should include the statement that the Towing Officer “participated in ongoing drills and training onboard the towing vessel” AND that the Towing Officer “routinely used radar for navigation and collision avoidance”.
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