Entry & progression
This is the most important lesson in the course. Whether AMSA will accept superyacht sea service toward an MO72 engineer certificate is not stated by AMSA anywhere - not on a web page, not in an instrument. Do not assume, in either direction. Get it confirmed in writing before you spend three years accruing it.
Start with the text, because the text does not shut you out. MO72 never says "merchant ship". It says "vessels" and "ships". Schedule 3 cl 3.1 requires service "as an engineer, trainee engineer or engineer cadet, or in an equivalent capacity regularly engaged in engine-room watchkeeping". Nothing there excludes a yacht. On the words alone, a superyacht is a vessel and its engine room is an engine room.
But the words are not the whole test
- Propulsion power. >=750 kW for the watch months; >=3000 kW for the top-up months. Read the engine nameplate, not the brochure.
- Kind of propulsion. Motor, Steam, or Steam and Motor - and the specified portions must be served on propulsion of the kind.
- The role. In charge of an engine room watch. Not merely aboard, and not merely in the engine room.
- Supervision and paperwork. On the entry ladder there must be a certificated EWK, EC2 or EC1 holder aboard to supervise you and sign the Training Record Book.
- AMSA's discretion. The one below.
WARNING — MO70 s18 - AMSA may discount your service Verbatim: "If AMSA considers that a period of qualifying seagoing service was completed at a time that is, or in circumstances that are, of little or no relevance to the seafarer certificate being applied for, AMSA may discount all or part of the service."
And AMSA, on yachting qualifications, verbatim: *"Service on vessels that spend considerable time in port will not be accepted."* A yacht that lies alongside for eight months and cruises for four is precisely what that sentence is aimed at.
MO70 s19 runs the other way. AMSA "may recognise qualifying seagoing service, in capacities or trades or on kinds of vessels, that is not recognised by this Order", judged on the duration and frequency of voyages, the kind of duties and their duration and frequency, the level of responsibility, and the relevance of the service to the certificate. Section 20 adds that service qualifies "to the extent that AMSA considers appropriate". The door is open. It is a discretionary door, not a textual right.
What AMSA says - and what it does not
For near-coastal certificates AMSA says it in terms: it may accept commercial sea service accrued on luxury yachts if you are being paid and the duties relate directly to the certificate applied for, and that service need not be in Australian waters. That is documented. For international certificates - the MO72 engineer ladder - AMSA is silent.
CAUTION — Nobody can tell you the answer. Ask AMSA. There is no primary source either way. Anyone who tells you "yacht time doesn't count for MO72" cannot point to a provision. Anyone who tells you it does cannot point to an AMSA statement. Write to AMSA before you commit. Describe the vessel - kilowatts, kind of propulsion, trading pattern, days at sea - your rank, and who supervises and signs for you. Get the answer in writing and keep it.
The letter that will cost you everything
For international certificates: "Qualifying sea service must be confirmed by a letter issued by the company. Letters issued on board a vessel by a master will not be accepted." For domestic near-coastal, a letter from the master, owner, operator or chief engineer is accepted. The two regimes are opposite, and yacht crew routinely collect a captain's letter and file it away for years. It will be refused. Get it from the company, on company letterhead, from day one.