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USCG-OUPV-L1.4

Sea service and recency: what the CFR says, and what the NMC applies

Every school will tell you the OUPV needs 360 days. The CFR does not contain the number 360 anywhere. Both statements are true, and understanding why is the difference between an application that is accepted and one that comes back.

Entry & progression

Builds on: L1.2. Read this one twice. The published figures conflict, and the conflict is not an error in this lesson.

What the regulation says

46 CFR 11.467 states the requirement in months, not days:

  • Near coastal — 12 months' experience in the operation of vessels, including at least 3 months on ocean or near-coastal waters (11.467(c)).
  • Great Lakes and inland — 12 months on Great Lakes or inland waters, including 3 months operating on the Great Lakes (11.467(d)).
  • Inland — 12 months' experience in the operation of vessels (11.467(e)).

What the NMC checklist applies

NMC checklist MCP-FM-NMC5-31, dated 15 September 2025, operationalises those months as 360 days and 90 days. That is a 30-day month, applied consistently. It is the figure your evaluator will actually count against.

Neither figure is wrong. The CFR sets the requirement; the NMC converts it into something countable. Quote the CFR at a Regional Exam Centre and you will be counted in days regardless.

The recency conflict — genuinely unresolved

Source Recency requirement
46 CFR 11.201(c)(1)(i) 3 months of qualifying service within the 3 years before application
NMC checklist (Sept 2025), citing Policy Letter 02-25 90 days within the past 7 years

These do not reconcile. The NMC checklists carry a standing disclaimer that where the checklist and the CFR conflict, the CFR is the overriding factor — yet the checklists themselves print 7 years. Build your application to satisfy the stricter 3-year rule if you possibly can, and if you cannot, go to the NMC before you file rather than after.

What counts as a day

46 CFR 10.232(h)(1) sets a day at 8 hours of watchstanding or day-working, excluding overtime. For vessels under 100 GRT, 10.232(h)(3) allows the Coast Guard to shorten that where the vessel's operating schedule makes 8 hours inappropriate — but never below 4 hours.

WARNING — The 4-hour day is discretionary, not automatic 10.232(h)(3) makes 8 hours the default even under 100 GRT. The 4-hour floor applies only if the Coast Guard determines the operating schedule warrants it. Anyone who tells you "on small boats a day is 4 hours" is describing a discretion as though it were a rule. Build your service record on 8-hour days and treat anything shorter as a request, not a right.

Proving it

Sea service is documented under 46 CFR 10.232(a), most conveniently on the CG-719S small vessel form — one form per vessel. If you own the vessel, 10.232(a)(4) lets you attest to your own service provided you supply proof of ownership. If you do not own it, you need letters from the owner or from credentialed personnel. Self-attesting to time on someone else's boat is not a thing, whatever you have been told.

Practice questions

5 questions
recallcore

recall · core

46 CFR 11.467 states the OUPV near-coastal service requirement as: (a) 360 days, of which 90 on ocean or near-coastal waters (b) 12 months, of which 3 months on ocean or near-coastal waters (c) 2 years in the deck department (d) 180 days on any waters

recallcore

recall · core

On the recency requirement, the CFR and the NMC checklist: (a) Agree exactly — 90 days in 3 years (b) Conflict: the CFR says 3 months within 3 years; the checklist says 90 days within 7 years (c) Agree exactly — 90 days in 7 years (d) Are silent on recency

recallcore

recall · core

Under 46 CFR 10.232(h), on a vessel of less than 100 GRT a day of sea service is: (a) Always 4 hours (b) 8 hours, unless the Coast Guard determines the operating schedule makes that inappropriate — never less than 4 (c) Always 12 hours (d) Any period the mariner was aboard

recallcore

recall · core

A mariner may attest to their own sea service: (a) Always, for vessels under 200 GRT (b) Only if they own the vessel and supply proof of ownership (c) Never (d) Only with a notary's seal

recallcore

recall · core

The CG-719S form should be completed: (a) Once per application (b) Once per vessel (c) Once per year of service (d) Once per route

AI-drafted catalogue content pending SME review. USCG requirements change; verify every figure against the National Maritime Center and the current CFR before relying on it for an application.

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