Entry & progression
Somebody decides how many engineers a vessel must carry, and it is not the owner, the manager, or the captain. This lesson tells you who, and which piece of paper carries the answer.
Inspected vessel — the Certificate of Inspection
For an inspected vessel the manning is on the Certificate of Inspection (COI). The COI is the operative document: it names the crew the vessel must carry, and it is issued by the Coast Guard.
46 CFR 15.825(d) says who sets the number: "the OCMI determines the minimum number of credentialed engineers required for the safe operation of inspected vessels." A human being at a Coast Guard Sector, exercising judgment about this vessel, this plant and this trade. Not a table.
WARNING — The COI complements the statute — it does not override it 46 CFR 15.105(c): the Certificate of Inspection "complements the statutory requirements but does not supersede them."
Read that as the sentence it is. If the statute requires a licensed engineer, a COI that is silent does not excuse you. The COI can add to the statutory floor; it cannot dig beneath it. "It's not on the COI" is not a defence to a statutory manning requirement.
Uninspected vessel on an international voyage — the safe manning certificate
An uninspected vessel has no COI. 46 CFR 15.105(d) provides that an uninspected vessel on an international voyage may be issued a safe manning certificate. That is the document that carries the manning determination where no COI exists — and it is the one that matters to a great many yachts, which are uninspected and cross borders constantly.
Foreign flag — the Minimum Safe Manning Document
If the yacht is not US-documented, none of the above applies. Manning is set by the flag state, and the document is the flag's Minimum Safe Manning Document (MSMD). A Cayman, Marshall Islands or Maltese yacht carries an MSMD issued by that administration, and it is the MSMD — not 46 CFR — that says how many engineers she must carry and what they must hold.
The three-question test
| If the vessel is… | The manning number lives on… | Set by… |
|---|---|---|
| US-documented and inspected | the Certificate of Inspection | the OCMI (15.825(d)) |
| US-documented, uninspected, international voyage | a safe manning certificate | the Coast Guard (15.105(d)) |
| Foreign-flag | the Minimum Safe Manning Document | the flag state |
Three columns, three documents, three authorities. Before you argue about how many engineers a boat needs, establish which row she is in. Most arguments in this industry are two people standing in different rows.
CAUTION — The document on the bulkhead is the answer for that vessel — and only that vessel Manning determinations are vessel-specific and they change with trade, route and plant. Read the actual COI, safe manning certificate or MSMD for the hull in front of you. Where a US-flagged vessel's position is unclear — particularly an uninspected yacht — the cognizant OCMI is the authority, and the NMC governs what the individual engineer must hold.