Entry & progression
Yacht time counts. Yacht time also gets rejected — and it is almost always for one of two reasons. Both are avoidable. Both are avoidable only before you leave the vessel.
Trap one — the walk-in engine room test
46 CFR 11.504 puts a condition on engineer service claimed on vessels of under 100 GRT: the vessel must have "a 'walk in' engine room with an engineering plant comparable to vessels over 100 gross tons."
That is a physical test, and it is asking a real question. Can a person stand in the machinery space and work on the plant, or is it a hatch you reach into? On a 90-foot sportfisher with lazarette access to a pair of mains, the answer is very often no — and the service is not engineer service.
WARNING — The NMC's own list of common rejections includes this one Among the most common reasons the National Maritime Center rejects an application is "claiming engineer service on a vessel without an engine room." It is not an obscure technicality. It is a top-of-the-list failure, and every month it costs somebody a year of what they thought was qualifying time.
Note the scope carefully. The walk-in test bites on vessels under 100 GRT. Above that line it is not the question being asked. If your engineer time is on small boats, it is the first thing to be honest with yourself about — before an evaluator is honest with you.
Trap two — who is allowed to sign
46 CFR 10.232(a)(4) governs attestation. The rule is short and it catches people who have done nothing wrong: owners may attest to their own service. Everybody else needs a letter from the owner or from a credentialed officer.
The NMC states the consequence without softening it: "If you do not own the vessel, you cannot attest to your own service — even if you are serving as master." Not even the master of the vessel can sign for himself. A sole engineer on a private yacht certainly cannot.
What that means on a yacht, in practice
- You need the owner or a credentialed officer to sign. On many yachts the captain holds a credential and is the obvious signatory — but confirm it, do not assume it.
- If the captain holds no credential and the owner will not sign, your service has no attestor. That is a problem you solve while you are still aboard, not two years later.
- Get the letter when you leave, not when you apply. Boats are sold. Owners die. Management companies change. Captains stop returning emails.
- Keep your own record as you go — vessel, official number, tonnage, propulsion power, route, dates, capacity, hours per day. The letter is easier to obtain when you hand someone the numbers to sign.
CAUTION — Use the current NMC checklist, not this lesson The NMC publishes a checklist for each endorsement, and the sea service forms and attestation requirements are set out on it. Those documents are updated and this course is not the controlling authority. Pull the current checklist for the endorsement you are chasing, and if the attestation position on your vessel is unusual, ask the NMC before you collect three years of time you cannot evidence.