Why the NMC returns a CG-719S

Sea service is the single most returned part of a mariner credential application. A return is not a rejection of your sea time — it is usually one field. But it costs you another trip through the queue, and the queue is measured in months. The harder problem is that not every defect comes back: some quietly cost you days or a whole route, and you only find out when the credential arrives wrong.

How to read the tags

Every item below is tagged with the authority that actually backs it. This matters because NMC administrative practice can change without a rulemaking, and where NMC guidance and the form face disagree this page shows both rather than picking one.

• [46 CFR] — a rule in the Code of Federal Regulations.
• [Form] — printed on the CG-719S (04/17) itself.
• [NMC] — NMC administrative practice, cited to document, date and page. Most of this list is NMC practice. NMC's own guidance carries a disclaimer that it is not a formal evaluation or a guarantee of credit.

These do not all fail the same way. Some come back for correction, some quietly cost you days or a route without telling you, and one is an eligibility bar rather than a paperwork problem.

Form rejected

NMC: “Failure to complete the required information will result in rejection of the form and the sea service credit sought on that form” (Sea Service, 8/12/2024, p.5).

1. Official number or state registration number left blank. [Form + NMC] NMC requires an official number or a state registration number — a state-registered vessel supplies the latter. Do not improvise one: NMC warns “do not try to make up a number from identifying information on a document pertaining to the vessel that you hold. This practice will result in your form being rejected” (p.5). If the vessel is not documented you must supply a name, and the form must then be attested to by someone other than you.
2. Gross tons left blank without all three of length, width and depth filled in. [NMC] NMC: if you are unsure of the vessel's GRT, “please be sure to provide the width, length, and depth of the vessel on this form. All three measurements are required” (p.6). This bites when claiming credit toward an endorsement with a tonnage limitation above 25 GRT. Note the trap: the form labels Width and Depth “(if known),” but NMC treats all three as required whenever gross tons is blank. Stating gross tonnage is regulatory (46 CFR 10.232(a)(2)(ii)); the dimensions substitute is NMC practice only and appears nowhere on the form.
3. Service on a vessel of more than 200 GRT documented on this form. [Form + NMC] Service above 200 GRT is not inadmissible — it just cannot ride on this form. NMC directs you to a certificate of discharge, a letter on official letterhead giving vessel details, dates and waters of service and positions served, or other official company records such as service logs or discharge books (pp.4, 6). Two cautions the sources force: the form header says “Less Than 200 Gross Register Tons Only” while NMC's guidance says “200 GRT and less” — they do not agree about a vessel of exactly 200 GRT, so treat 200 as a grey zone, not a safe harbour. And the threshold is gross register tons, not ITC gross tonnage: 46 CFR 10.232(i) treats 200 GRT as equivalent to 500 GT.
4. Capacity entered as “Owner” instead of a position served. [NMC] Owner is not a served capacity. State the position you actually filled.
5. Engineer capacity claimed on a vessel with no engine room. [NMC]
6. More days claimed in a month than that month actually has. [NMC] NMC checks the monthly grid against the calendar — February is the usual casualty.
7. The same month claimed on two vessels, adding up to more days than the month has. [NMC] NMC calls this Coast Guard policy: you cannot be credited for more days in a month than the month contains, however many vessels you served on. A static form or template cannot catch this, because it needs both forms at once.
8. Total days not equal to the sum of the monthly grid. [NMC]
9. Total does not equal the Great Lakes box plus the shoreward box plus the seaward box. [NMC] NMC requires box 1 to equal both the sum of the monthly grid and the sum of the three route boxes. On the form these are labelled by the boundary line defined in 46 CFR part 7: shoreward is inland, seaward is near coastal.
10. A single form covering more than 5 years. [NMC]
11. More than one vessel listed on a single form. [Form] The form is printed “Complete One Form Per Vessel.”
12. Applicant signature missing. [Form]
13. Attestation signature missing. [Form + NMC] The form calls this the “Person Attesting to Experience,” not a witness, and it needs no notary. Only an owner, operator, or another master may sign it.
14. Address or phone number of the person attesting left blank, or illegible. [NMC] NMC lists both “not providing an address and/or phone contact for the person attesting” and “not providing legible required contact information” as common errors. Email is the only optional field in that block.
15. The applicant signed the attestation block. [NMC] NMC: “If you do not own the vessel, you cannot attest to your own service — even if you are serving as master.” The exception: if you do own the vessel you may sign both blocks, but you must attach proof of ownership (46 CFR 10.232(a)(4)).
16. You attested to your own service as owner, but proof of ownership is missing or is only a photograph of the boat. [NMC] There is no owner checkbox on the form — ownership is established by who signs the Section III attestation plus the proof you attach. NMC states outright that “photographs or imagery of vessels are not acceptable as proof of ownership” and lists what is: title, state registration, Certificate of Documentation, proof of insurance clearly identifying the vessel, or bills of sale. If a company owns the vessel, add proof you own the company, such as articles of incorporation (p.3).

Days not credited

Nothing comes back. The days simply do not count.

1. Average hours underway per day below the minimum for the vessel's tonnage. [46 CFR + NMC] The regulatory day is 8 hours of watchstanding or day-working, not including overtime (46 CFR 10.107(b), 10.232(h)). Only on vessels of less than 100 GRT may the Coast Guard credit a shorter day, and never below 4 hours. On a vessel of 100 GRT or more — still inside this form's range — the minimum is 8 hours; NMC states a 4-hour day “is never acceptable on a vessel over 100 GRT” (12 Hour Day/Time-and-a-Half Credit, 7/16/2025). A flat “4 hours” claim is the single most costly error on this page.
2. Serving in a position for which the Coast Guard requires manning, without the corresponding endorsement. [NMC] An applicant “must not serve in a position for which manning is required by the Coast Guard without the corresponding endorsement or they will not receive credit for the service” (p.6).

Silently downgraded

The most expensive category, because nothing is returned and nothing is flagged. You find out when the credential arrives with the wrong route or short time.

1. Great Lakes or near-coastal days claimed with no matching description of the specific waters. [NMC] NMC does not bounce this — it credits the days as inland instead: “All descriptions of waters which do not qualify as Great Lakes or near coastal are considered inland for the purposes of evaluation” (p.6). That costs real time: toward an oceans, near-coastal or STCW endorsement, Great Lakes service counts day-for-day up to 100% of the requirement, but other inland service counts for at most 50% (46 CFR 10.232(b)).
2. Time-and-a-half claimed for 12-hour days without a two-watch system that was authorized and practiced. [46 CFR + NMC] The days are credited at 1.0× instead of 1.5×. Authority comes from 46 U.S.C. 8104 and 46 CFR 15.705 — chiefly towing vessels, offshore supply vessels and barges on voyages of less than 600 miles — not from the COI as such. NMC's 8/12/2024 guidance (p.11) says the letter must attest the two-watch system was authorized by the vessel's COI; the more recent FAQ (7/16/2025) says only that the letter “should state a two-watch system is authorized and practiced,” and allows time-and-a-half on some vessels with no COI at all. As a standard NMC does not credit time-and-a-half on vessels under 100 GRT, because they normally have no COI, and never on a recreational vessel under 100 GRT.
3. Two departments claimed with no day breakdown. [NMC] Split 50/50 between them, and credited only as an 8-hour day.
4. A water description that does not match your Great Lakes / shoreward / seaward day breakdown. [NMC] A general description such as “Atlantic Ocean” is acceptable to NMC — it just has to correspond to the boxes (p.6).

Eligibility, not paperwork

1. Recency for a national officer endorsement. [46 CFR] You need at least 3 months of the required service — 90 days, since 46 CFR 10.107(b) defines a month as 30 days — on vessels of appropriate tonnage or horsepower for the endorsement sought, within the 3 years immediately preceding the date of application. Two alternatives exist: 3 months on vessels of the uniformed services within the preceding 7 years, or a combination of the two (46 CFR 11.201(c)(1)). Missing this is a denial, not a return. Do not confuse it with renewal, where one of five alternative routes is evidence of at least 1 year of sea service during the past 5 years (46 CFR 10.227(e)(1)).

What a sea service letter must carry

The information is set out in 46 CFR 10.232(a)(2): vessel name and official number, gross tonnage, propulsion power and mode of propulsion, the amount and nature of the position served, the applicable dates of service, and the routes on which the experience was acquired.

Two requirements mariners are routinely told are regulations are not in the regulation at all. Letterhead and the letter's own date come from NMC's Sea Service guidance (8/12/2024, p.11), which says the letter “must be on letterhead from either the company that employed you or the vessel on which you served” and to “include the date the letter was written.” Note that NMC accepts vessel letterhead, not only company letterhead.

On who signs: 46 CFR 10.232(a)(1) names the owner, operator, Master or Chief Engineer for a marine company service letter, and that list is illustrative rather than exhaustive. For service on vessels of less than 200 GRT, 10.232(a)(4) also accepts letters or other evidence “from credentialed personnel or the owners of the vessels listed.” The constraint that actually matters is narrower and firmer than any of these: the signer cannot be you, unless you own the vessel and attach proof of ownership.

Should this be a checker?

We are considering building a checker that flags every item above against your own numbers before you file — including the same month double-counted across two vessels, which a static form or template cannot catch because it needs both forms at once.

If you would use it, say so. That is the whole signal we are going on: if not enough mariners want it, we will not build it.

Notify me when the checker ships

Sources

Verified against CG-719S (04/17); 46 CFR parts 10, 11 and 15 (2025 annual edition, revised as of October 1, 2025); NMC Sea Service guidance dated 8/12/2024; and NMC “12 Hour Day / Time-and-a-Half Credit” dated 7/16/2025. Where the 8/12/2024 guidance and the 7/16/2025 FAQ conflict, the newer FAQ governs. Reviewed 2026-07-26. Next review 2027-01-26. A revised CG-719S is pending in PRA docket USCG-2025-0344 under OMB 1625-0040 and is not yet in force; field names may change. This page describes the 04/17 edition, whose printed OMB expiration of 03/31/2021 has lapsed on the copy NMC serves.

Related

Not affiliated with or endorsed by the USCG, the National Maritime Center, or the TSA. The accuracy of what you file is the responsibility of the applicant and the signer. This page does not certify anything to the USCG, submit anything on your behalf, or provide legal advice. NMC's own guidance carries a disclaimer that it is not a formal evaluation or a guarantee of credit.