| MGN 156 (M) Annex A (Motor) A common misunderstanding As a result of handling the placement of many engineers on a whole range of yachts we have developed a full working knowledge of the MCA requirements. On the face of it the manning scale shown in MGN 156 (M) Annex A (motor), appears to be quite straightforward. However there are some confusions and the most common concerns motor yachts that fit the category of 200-500grt and 3000-6000kws.
Because the yachts in this category are over 3000 Kw the tendency is look at the requirements in column 4 of the manning table. This is not correct. For yachts in this category column 2 applies. If you look at column 2 carefully there is a reference (No. 2) against the chief engineer requirement for yachts operating up to 150 miles and over 150 miles from a safe haven. The notes for this reference are on page 19, and I quote. Over 3000 Kw and less than 6000 Kw propulsion power: certificate holder is required to have attended an approved engine manufacturer’s course appropriate to the engine type and range. This requirement for “an approved engine manufacturer’s course” only applies if the chief engineer holds a Y3 or a Y2. It does not apply if the Chief Engineer holds a Y1 or the appropriate merchant license. So in other words column 2 could have been headed 200-500grt and 3000-6000 Kw. The same note No.2 would apply but supplemented with “except for yachts under 3000kws. It should also be noted that if a yacht in this category were operating up to 60 miles from a safe haven the requirement in column 2 would change from a Y4 to a Y3 but subject to the same note No.2 on page 19. The MCA have confirmed what I have stated above is correct and are fully aware that the drafting of MGN 156 (M) can lead to misinterpretation. If you are in any doubt about the manning requirement or license limitations, the best course of action is to e-mail the MCA stating the relevant details of the yacht and they should give you a definitive response. Some Flag States can also get it wrong Recently one Flag state who have adopted the MCA manning requirements had themselves misinterpreted the engineer requirement for a yacht of 490grt and 3250 Kw that was operating up to 150 miles from a safe haven. The Flag state stipulated that the yacht required a Y3 for the second engineer, where in fact they did not require a second engineer at all. As we had already supplied an unqualified second engineer and the yacht was picking up its first charter 5 days later, panic set in. Fortunately we were able to convince the senior marine officer of the flag state concerned of their error and a corrected safe manning requirement was subsequently issued. If you have difficulty getting through to the MCA to discuss your manning requirement please feel free to call us. |