AIMPE TUG DELEGATES
CONFERENCE
NOVEMBER 2013
1
STW CONVENTION AND CODE WITH
2010 MANILA AMENDMENTS
• STCW Conference held Manila 21-25 June 2010
• 500 delegates and 85 member States plus 17 NGOs
– AIMPE part of Australian delegation
• Manila Amendments adopted 25 June 2010
• Amendments bring Convention and Code up to date with
new developments since adoption in 1978 and revision in
1995
• In force 1 January 2012
• Transitional arrangements 5 years to 31 December 2016
2
STCW Cont.
Not all of the Conference outcomes and amendments acceptable to all
Parties; some of the changes were:
• Improved measures for fraudulent practices
– Evaluation process strengthened
– Standard format of certificates and endorsements
– Date of expiry of any extension to the validity of certificate
• Propulsion power definition retained
• New requirements for marine environment awareness training and
leadership training
• Updating of competence requirements for personnel on tankers
– Two options for advanced training on tankers for all crew
responsible for loading
– Format of basic tanker courses updates
3
STCW Cont.
• New requirements relating to electronic charts and
information systems (ECDIS)
• New training guidance for personnel on
– Ships operating in polar waters
– Personnel operating dynamic positioning systems
• New security training requirements
– Security Awareness Training Certificate
– Provisions to ensure training if ship comes under pirate attack
• New modern training methodology introduced to include distance
learning and web-based training
4
STCW Cont.
• Transitional arrangement provisions unchanged
– 5 year period for Administrations to get new systems in
order
• New revalidation provisions include:
– Security awareness training (SAT certificate)
• Introduction of refresher training ashore
– AMSA Marine Notice 2013/02 ‘Validity and
Revalidation of Certificates’
– fire fighting and survival craft course
– opposed by AIMPE at STCW
– appropriate training received at sea by engineers
5
STCW Cont.
• Regulation VIII/1 Fitness for duty
• Revised requirements for hours of work and rest
– minimum 10 hours rest in 24 hour period
– 77 hours in any 7 day period
– Administration may allow exception back down to 70
for up to 2 weeks but not continuously
– hours of rest may be divided into no more than 2
periods, one of which shall be at least 6 hours and
intervals
– intervals between consecutive periods of rest not to
exceed 14 hours
6
STCW Cont.
Engineering requirements specified in Chapter III
• For engineer watchkeeper
– Age for issue of certificate 18 years
– Approved 30 months training reduced to 12 months of
combined workshop skills and sea service
– Completion of combined workshop skills training and
approved sea service of not less than 30 months in
engine department
• Lowering of standards vigorously opposed by AIMPE
– AMSA starts to incorporate lower standards into MO3(7)/T2T
• Will cover additional changes and reductions in qualifying
sea service for engineer certificates later
7
INQUIRY INTO COASTAL
SHIPPING 2008
In mid 2008 AIMPE made submissions to House of
Reps Standing Committee on Infrastructure,
Transport, Regional Development and Local
Government
• Amendments to the Navigation Act 1912
• The establishment of a single national system for
maritime safety regulation administered by AMSA
• Tonnage tax
• Address training and skills shortage
8
Rebuilding Australia’s Coastal
Shipping Report Oct 2008
• House of Reps table Report in Parliament
– ‘Rebuilding Australia’s Coastal Shipping Report’
• Reform of Part VI of Nav Act 1912, Navigation
(Coasting Trade) Regs 2007 and the Ministerial
Guidelines for Granting Licences and Permits to
engage in Australian domestic shipping
• Implementation of SNJ
• Optional tonnage tax linked to mandatory training
requirements
• Address training and skills shortage
9
NATIONAL MARITIME TRAINING
AND CERTIFCATION
• Start of new MO3 Review by AMSA and consideration of
the Tinny to Tanker (T2T) system in June 2007 [STCW?]
• AIMPE commenced meetings with AMSA to determine
‘equivalent’ trades for engineer watchkeeper cert and reassessment of trades for EC3 holders
• At AMSA/ASA Shipping conference in September 2007
AMSA announce new Second Engineer (MED1) and Chief
Engineer (EC3) near coastal certificates and lowering of
standards to STCW95
• AIMPE oppose lowering of standards to STCW and
proposal to use NSCV in Marine Orders Part 3 was also
opposed by AIMPE
• AMSA then agree to consult with AIMPE
10
MO3 Review Contd.
In discussions with AMSA they agreed to AIMPE request to:
• expand list of approved trades for w/k cert
• Accept post-trade work for w/k cert requirements
• AMSA to issue EC3 and all MED certificates
• AMSA to be comprehensive regulator of all sizes of
commercial vessels
• AMSA to work with AIMPE on new engineer cadetship
program and maintain current standards
• Retain oral exams
• Not reduce sea service requirements
11
MO3 Review Contd.
• Without consultation in November 2008 AMSA,
announce T2T model
– model opposed by AIMPE
• AMSA then agree to
–
–
–
–
–
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separate Marine Order for marine engineers
PEE to make all decisions not manager
Consider national eng knowledge exam papers
maintain full sea service requirements
AMSA to issue all certificates in SNJ
retain oral exams and full oral exams for issue of
Certificates of Recognition
12
MO3(7)
AMSA proposes new proposals in 2009 which are again
opposed by AIMPE:
• AMSA have disregarded all of AIMPE concerns
• career path for engineers and engine drivers cobbled
together with little or no consultation
• T2T model reduces standards of safety training and
certification
• changes are not justified by the rising incidence of injuries
and fatalities on small commercial vessels
• AMSA should not adopt the flawed Part D NSCV;
13
MO3(7) Contd.
After much consultation AMSA agree to:
• Chief Examiner to have discretionary power to make decisions
• amend MO3 to allow EC3 holders to qualify for engineer watchkeeper
certificate
– need to meet Eng Cadet workshop training competencies
– 30 months sea service on ships over 750kW pp holding EC3 if
workshop competencies at EC3 level
– 24 months sea service over 750kW holding EC3 if already
completed Eng Cadet workshop training competencies
– evidence of sea service and maintenance on board for existing EC3
holders
– consideration for EC3 Maritime Training Package (MTP)
Competency Modules to match Engineer Watchkeeper modules
14
MO3(7) Contd.
•
AMSA meets with AIMPE to consider new trades for engineer
watchkeeper certificates
• Certificate III + 18 months fitting, or repairing mechanical or electrical
machinery or engines OR
• Certificate III + 18 months minimum period of workshop
training specified in the MO3 Workshop Service Table
Acceptable trades:
• Certificate III in Engineering – Mechanical Trade
• Certificate III in Automotive – Mechanical – Diesel Fitter
• Certificate III in Automotive – Mechanical – Heavy Vehicle Road
Transport
• Certificate III in Automotive – Mechanical – Heavy Vehicle Mobile
Equipment, Plant/Earthmoving, Agriculture
• Certificate III in ESI Generation - Mechanical
15
MO3(7) Contd.
• New draft MO3(7)(mark 2?) introduced in late 2009 in which AMSA
reneges on all previous agreements and issues
• No discretionary power for Chief Examiner
• MO3(7) riddled with mistakes
• Deletion of 36 months approved education and training from Engineer
Watchkeeper requirements – new STCW?
• Age for W/k certificate reduced from 20 to 18 years (in current and
new STCW)
• No mention of engineer cadets or cadetships, apparently forgotten by
AMSA
• Removal of Eng W/k initial workshop training requirements – to be
placed on AMSA website
16
AMSA ADMITS MISTAKES
• AMSA embarrassed by mistake ridden MO3(7) and
withdraws it
• AMSA agrees to collaborate with AIMPE in development
of new MO3
– here we go again!
• Separate engineering requirements – MO5?
• Chief Examiner to have power to review and approve
decisions
• New process to approve trades for W/k certificate
• New Bridge for EC3 holders to progress to Engineer W/k
system
17
AIMPE WRITES MO PART 5 FOR
ENGINEER OFFICERS
• Discussions with AMSA were then slow and unfruitful
– It appeared that AMSA did not want to talk to AIMPE
• In an effort to hasten proceedings AIMPE produced MO5
“Marine Qualifications Engineer Officers” in June 2012
with all previous agreements with AMSA included
• MO5 a stand alone document for engineers as per previous
MO5 issued in 1983
• Chief Examiner given discretionary powers
• Introduction of agreed trades for engineer watchkeeper
• AMSA did not wish to discuss MO5
18
AIMPE BRIDGE FOR EC3 TO EW/K AND
EC2 – FEDERAL COUNCIL DECISION
• Meetings with AMSA during 2011 still sparse
• Federal Council agreed to the following proposals for MO3 – detailed
in June 2011 On Watch:
• Allow EC3 holder with non-approved trade entry to eng w/k on
completion of 18 months sea service over 750kW while holding EC3
certificate; need to complete Eng Cadet workshop competencies;
• Allow EC3 holder with approved trade direct entry to EC2 on
completion of 24 months sea service over 750kW while holding EC3
certificate;
• EC3 holder without trade to complete 30 months sea service over
750kW including onboard maintenance while holding EC3 certificate
plus engineer cadet workshop competencies and approved course
• If onboard maintenance approved by AMSA no further sea service
required
• Above proposals forwarded to AMSA for their consideration
19
MO3(7)
New draft of MO3(7) (Mark 3?) introduced 2011:
• AMSA ignored most of Federal Council proposals
• Engineer Cadetship – appears to follow new STCW competencies
only
36 of approved education and training deleted
12 months watchkeeper?
• Does not specify 36 weeks approved practical training ashore
Engineer Trainee
• Approved trades similar to those previously agreed with AMSA plus
approved program as per A-III/1 of STCW Code
• Does not include agreed additional workshop service and maintenance
onboard for trades not originally approved in MO3,
• No oral examination specified for any certificates
– Final assessment only
20
MO3(7) Contd.
AMSA introduces bridge for EC3 into engineer watchkeeper
•
Must hold State or AMSA EC3 certificate
•
Approved training course that meets A-III/1 of STCW
Code
•
Approved workshop skills and training in STCW
competencies
•
Only 26 weeks sea service over 750kW
–
•
•
not as per previous agreement with AMSA
Complete Training Record Book
No oral examination specified
•
final assessment only
21
ENGINEER W/K CERTIFICATE –
BRIDGE FOR RATINGS
MO3(7) proposes new path proposed by AMSA for ratings
• Most hold Able Seafarer, IR or CIR Certificate of
Proficiency
• Approved training course that meets A-III/1 of STCW
Code
• Approved workshop skills and training in STCW
competencies
• Only 26 weeks of qualifying sea service required while
holding certificate on ships over 750 kW
• Complete Training Record Book
• No oral examination
– Final assessment only
22
AMSA’s LATEST BACKFLIP
• On 25 October 2011 AMSA sent AIMPE their latest draft
of the engineering requirements to be specified in new
MO3 – only 4.5 pages
– AMSA influenced by Shipping Reform Committees?
• AMSA reneged again on most if not all of previous
agreements with AIMPE over the last few years
• MO3 again riddled with mistakes and appears to have been
written by a non-engineer trying to harmonise the engineer
requirements with the deck requirements and STCW
minimum
• Principal Examiner of Engineers not given the appropriate
discretionary powers, final decision made by Manager who
may not be a marine engineer
23
MO3(7) Contd.
• Mistake ridden MO3(7) withdrawn by AMSA in
May 2012
– New draft MO3(7) (mark 4?) introduced early 2013 and
superseded in July 2013
• Marine Engineers Qualification Bill 2013
presented to Federal Parliament in March 2013
– Bill introduced by Andrew Wilkie
– Bill to secure standard of engineer qualifications in
Australia
24
MARINE ORDERS PART 3(7) 2013
• MO3(6) updated to include relevant provisions of MO4(Transitional
Modifications)
– same requirements as current MO3(6)
– brings in new transitional provisions for revalidation specified in
Marine Notice 2013/02
• New draft MO3(Seafarer Certification) 2013 posted by AMSA in July
2013
– draft almost the same as previous MO3(7)(mark 4) posted a few
months before and withdrawn by AMSA
– new MO3(7) omits decisions previously agreed to by AMSA
– Here we go again!
• AIMPE oppose lowering of standards to STCW minimums
25
MO3(7)(2013) Contd.
• New draft MO3(2013) introduced July 2013
• Engineering requirements not what was agreed to by
AMSA
• Draft MO3 50% longer and difficult to read
– written in legal terms
• No mention of Principal Examiner of Engineers
• Approved means approved by AMSA
– not principal examiner
– approved could mean anyone in AMSA
26
MO3(2013)
• Final assessment by AMSA, no mention of
Principal Examiner, a part of which is by oral
exam
• 6 month time penalty introduced for failure in oral
exam
• No definition of steamship and motorship
certificates or endorsements
• No definition of propulsion power
• No State certificates issued
27
ENGINEER WATCHKEEPER
CERTIFICATE
•
•
•
•
Age for issue reduced from 20 to 18 years (STCW)
36 months of approved education and training back
No approved cadetship specified
36 weeks practical training ashore amended to allow training
elsewhere
– AMSA states training ashore may place restraints on completion of
training using CBT
– Industry concerned at decreasing quality of training for cadets
• Engineer trainee workshop skills introduced again
not as per previous AMSA agreement
• Only 26 weeks sea service over 705 kW for EC3 holders
• New endorsement as chief engineer less than 3000 kW NCV
– For EC3 holders?
28
ENGINEER CLASS 2
• Total sea service reduced from 15 months to 12 months
while holding engineer w/k cert
• Allows EC3 holder into engineer w/k on completion of 24
weeks sea service over 750 kW
• Completion of full EC2 course of study
• For EC3 holder - completion of engineering training
program in accordance with STCW A-III/1
includes program of workshop skills and
competencies
• Final assessment
29
SECTION A-III/1 OF STCW CODE
An approved training program that meets the requirements of
A-III/1 of the STCW Code and includes a program of
workshop skills training in the following competencies
from STCW code:
• maintenance and repair of electrical and electronic
equipment;
• appropriate use of hand tools, machine tools and
measuring
• instruments for fabrication and repair on board;
• maintenance and repair of shipboard machinery and
equipment
• No details of time taken, skills to be achieved – can be
used for the STCW 12 months engineer watchkeeper
30
ENGINEER CLASS 1
• Total sea service reduced from 39 months to 36
months
• Allows combination of sea service while holding
engineer class 2 and EC3 certificates to count for
EC1
• EC3 holders must still complete the full EC1
course
• Final assessment
31
ELECTRO-TECHNICAL OFFICER
• Electro-technical officer introduced as specified in
STCW
– not a mandatory qualification
– Electro-technical rating also introduced
• Requirements for issue of ETO certificate do not
require an electrical trade
- AIMPE lobbied AMSA for change as this is a
-
safety issue
AMSA does not agree
32
STCW ENDORSEMENT
• New MO3(7) 2013 does not contain provision for issue of STCW
Endorsement
– AMSA ceased issue of endorsements on 1 January 2013
– without industry consultation
• AIMPE met with AMSA last month to discuss and get them to re-start
issue of endorsements
– EC3 holders disadvantaged as AMSA believe EC3 certs not suitable on
foreign flag ships
• AMSA concedes there may be a problem and will get back to AIMPE
to discuss any future changes – if any!
• Situation not improved by new National Standard for Commercial
Vessels (NSCV)
NSCV Part D causing problems
33
NATIONAL STANDARD FOR
COMMERCIAL VESSELS
• NSCV is the standard prescribed in the Marine Safety
(Domestic Commercial Vessel) National Law Act 2012
– developed as an upgrade and amendment to the USL Code
• Marine Order 505 prescribes NSCV Part D ‘Crew
competencies’
• Marine Order 504 prescribes NSCV Part E ‘Operations’
• Marine Order 503 prescribes NSCV Part C
– Part C is the prescribed standard for vessels which are brand new,
and existing vessels in commercial survey/registration in the two
years prior to commencement of the National System
34
NSCV Part D
‘Crew Competencies’
•
•
•
•
NSCV Part D ‘Crew Competencies’ downgrades
engineer qualifications and reduces safety standards
Raises the propulsion power/complexity of vessels that
can be put under the command of the holder of a lowercapacity engineering certificate
Extends the operational limits for lower-capacity
engineering certificates
In contravention of STCW, counts only half the
propulsion power (i.e. one engine’s propulsion power on
a multi-engined ship) to determine the
engineering/safety qualification required.
35
AIMPE/TEEKAY-SPONSORED
CADET PROGRAM
• Selection panel includes AIMPE Director professional standards
• Self funded cadets
• Company pays accommodation, college fees, travel, victualling on
board etc
• Cadet must attend Hunter IT
• Cadet paid bursary in seven instalments
– at 6 monthly intervals
– each payment conditional on cadet successfully completing each
stage of program
• Cadet must complete full program
– involves at least 60 weeks sea service
– Companies requested additional service
36
CADET PROGRAM Contd.
• Must have completed HSC year 12 in maths,
English and science (physics)
• Successful cadet to undergo supernumerary presea training of 2 – 3 weeks
• AMSA medical
• Hunter IT Part A eng w/k and EC2 course
• 6-8 weeks fitting and machining
• Remaining workshop service training ashore
integrated with sea service
37
CADET PROGRAM Contd.
• Completion of 50% of sea service and Training
Record Book
• Completion of eng w/k Part B
• Completion of remaining sea service and TRB
• All approved AMSA short courses
• AEE course
• Qualify for Diploma in Marine Engineering
• Complete AMSA oral exam and gain engineer w/k
certificate
38