Scope and limits
Governing: 2021 Regulations, reg 1 definitions, reg 2(10), reg 92. Builds on: L1.2.
Before you count a day of sea service, ask two questions: what kind of ship was it, and where did it go? SAMSA's answer shapes the certificate you get.
Voyage limits
| Term | Meaning in the 2021 Regulations |
|---|---|
| Unlimited voyage | Anything that is not near-coastal or port operations |
| Near-coastal voyage | Exclusively within the South African EEZ (200 nautical miles); "limited waters" means the same for fishing |
| Port operations area | Within 15 nautical miles of a defined point for each port |
The ranking in regulation 2(10) is simple: an unlimited certificate works anywhere; a near-coastal certificate works near-coastal and in port operations but not on unlimited voyages; a port operations certificate works only in port operations. Tonnage and power limits are hard ceilings.
CAUTION — Near-coastal is someone else's coast too Sea service on foreign coasts counts only towards near-coastal certification unless the ship's papers show unlimited voyages (reg 11(9)), and voyages under 150 NM are treated as near-coastal. A season shuttling between Antibes and Monaco is not unlimited service.
Trading, non-trading and pleasure
This is the definition yacht crew need to learn by heart.
- A trading ship is a seagoing ship on regular seagoing voyages, excluding warships, fishing vessels, ships used solely for sport or recreation, and traditional sailing ships.
- A pleasure vessel is one used solely for sport or recreation.
- The STCW Convention itself, as the Regulations define it, does not apply to ships used solely for sport or recreation.
Almost every sea-service requirement for an officer CoC is written as "on trading ships of X GT or more". Regulation 22 then adds a twist: if more than half your qualifying service is on vessels not engaged in trading, the certificate is limited to non-trading vessels. MN 20 of 2016 applies a commercial-gain test to decide borderline cases; Lesson 4.2 covers what that means for yachts.
Which ships the manning rules cover
Regulation 92(4) excludes from the manning parts:
- vessels under 25 GT;
- vessels under 100 GT used solely for sport or recreation;
- naval vessels.
A 100 GT class XII vessel must still conform "as closely as possible". Small commercial craft under 25 GT, such as Cape Town charter boats and Durban dive boats, are manned under the small vessel regime instead: see SAMSA Skipper Categories R–B.
Merchant, fishing and port operations streams
The Regulations run parallel ladders: merchant (Division 1 deck, Division 5 engine), port operations (Divisions 2 and 6) and fishing (Divisions 3 and 7, under STCW-F). Regulation 2(10) is explicit that a merchant certificate does not work on a fishing vessel, and vice versa, without the appropriate endorsement.
Worked check
A candidate's record shows 20 months on a 45 m private motor yacht, never chartered, and 14 months on a 2 400 GT offshore supply vessel. Total 34 months.
- Yacht share: 20 / 34 = 59%, more than half.
- On a straight reading of reg 22(2), any certificate from this record risks a non-trading limitation, and the yacht months are not "trading ship" service anyway.
- The 14 supply-ship months are trading service, but fall short of the 36 months needed for unlimited OOW by the non-accelerated route.
TIP — Keep the charter paperwork Evidence that a yacht was commercially operated (charter agreements, commercial registration, MLC documents) is what lets an examiner apply the commercial-gain test in your favour.