Despite the fact that the new STCW has been accepted by a diplomatic conference in Manila back in June 2010, unfortunately many industry stakeholders are not aware of the implications of the new requirements and as a result they have not addressed their safeguards properly.
What we will do is to assess the implications of the new STCW from the ship manager side. The area that need to be properly addressed are the following:
1. Onboard Familiarization
The new STCW has certain provisions for more extensive familiarization. It's not only basic safety. It's safety, security, environment, emergency and equipment specific training. If you go to previous STCW you might have generic equipment training requirements. Now there are specific requirements plus responsibilities for both the seafarer and the ship captain.
2. Ship Specific Familiarisation
Many people read the new STCW and cannot find the requirement about the ECDIS type specific training. Believe me it's there. It is B-I/14 regarding Guidance to Companies contains EXTENSIVE responsibilities for master, officers and crew to get familiarization and more effort (liability) to be addressed e.g. in way of :
- Free Fall Life Boats
- Oil Water Separator & Systems
- Ballast Water Treatment Systems
This is the requirement. You need to have extensive ship specific familiarization. It applies to ECDIS as in any sort of equipment like the incinerator or the oily water separator or any other vessel specific system. Anyone can board the vessel and ask for ship specific familiarization. You need to also account for relevant Training material provision, either from maker or any other reliable provider.
3. Work & Rest Hours
The new STCW provides for 77 hours of rest in any 7-day period or to make it more practical for 91 hours of work per week. This is the remaining balance of 24 x 7 minus 77. It will be 91 hours of work per week. Are you sure that a person is productive working 80, 90 or 100 hours per week ? Are you working so many hours per week ?. The rest hours are very difficult to implement. You need to accommodate for drills and there is no generic default exemption rule incorporated in the new STCW regarding the 70 hours per week, each flag need to specify her own requirements People don't know what to do with the new STCW. A flag specific application of an exemption is needed. If a flag says 77 hours, that's it. There is no room for an exemption. To the best of my knowledge there are NO flags so far allowing the exemption of 70 hours per week.
4. Fatigue management
Also, there is need for fatigue management. Fatigue management needs to be done for the rest hours. As a minimum you need to have a poster regarding fatigue management and implement the practices identified over there in line with MSC circ. 1014.
5. Mandatory D&A guidelines
Then there are mandatory drugs and alcohol requirements. This is now mandatory for all operators, both those operating tankers and those operating dry bulk. There is need for policy, training, crisis management, employee education, counseling, treatment, rehabilitation, alcohol testing and of course program review and evaluation.
6. ECDIS Training
ECDIS training is type specific. There is a new model course and you need to have additional bridge checklist "familiarization with ECDIS". Because you don't have any sort of documentation on board, if you have an accident with ECDIS - which I don't recommend - you will have a huge mess. If you have a real life navigational problem with an ECDIS fitted vessel - even if it is an ECDIS certified vessel - you need an additional "bridge checklist familiarization with ECDIS" to help you solve it.
7. Free Fall Lifeboat Training
Many vessels are being fitted with free-fall lifeboats. B-I/14.2 states specifically "prior to joining a ship, seafarers assigned as operating crew of free-fall lifeboats should have undergone appropriate training in boarding, launching and recovering of such lifeboats, including participation on at least one occasion in a free-fall launch". There is no such training available. No maritime academy or training establishment provides such course. Reality says if you have a free-fall lifeboat, most probably you will have an accident rather sooner than later. If you don't have training ashore or makers' training material onboard such as a DVD most probably you will be involved in a difficult situation.
8. Security & Anti Piracy
Now we have, besides the Ship Security Officer course and the security related familiarization, basic security awareness for persons without designated security duties. Also we have advanced security awareness for persons with designated security duties. If you go to a passenger's ship, that would make sense. If you go to an ocean going ship with 20-25 crew, that does not make sense. Of course we have anti piracy training as well. The industry misses at the moment that the deadline for all the security training is January 1, 2014, which is only 15 months away. This means that if somebody is sent on board on March 2013 or on June 2013 and stays till the 1st of January 2014, this person needs to have security awareness plus anti-piracy training. You need to speed up in order not to miss the deadline.
9. Manning Agent Control
Manning agent control is required and Manning agent auditing is a must in these days, especially with the new ILO MLC. Manning agent is doing a crucial fraction of the job. He has responsibility and he needs to be audited. There is need for records as well. For example, if the agent familiarizes crews. How is he doing this? Is he aware of the company's SMS? How many people are responsible? How is the manning agent implementing the requirements that you have posted to him? Proper safeguards need to be added as necessary.
10. Other real life issues
Finally there are many real life issues not addressed in the new STCW. There is no training for Safety Officer, Training Officer, Environmental Officer, Ship Safety representative, Cooks, Enclosed Space Entry, rescue from Enclosed Space and how to carry out drills training. But these officers and these requirements and tasks do exist onboard vessels.
Overall the above are not of a limited scope as you do understand. What needs to be done however is there. STCW is along with the forthcoming ILO MLC the two regulations dealing with the human element. It remains to be seen if the issues involved are properly addressed onboard vessels, especially during third party inspections.
Principal Consultant & CEO, SQE Marine Group
Managing Editor, Safety4Sea.com