The IMO Sub-Committee on Human Element, Training and Watchkeeping held its 3rd Session (HTW3) from Monday 1 through Friday 5 February 2016 under the Chairmanship of Mrs Mayte Medina (USA), elevated from Vice Chair in the absence of Mr Brad Groves (AUSTRALIA) who has since been promoted to the Chair of the Maritime Safety Committee. Mrs. Medina was subsequently elected as Chair of HTW for 2017 together with her Vice Chair, Ms Farrah Fadil (SINGAPORE). Three Working Groups (WG) and a Drafting Group (DG) were formed and chaired as follows:
|WG1||Training Matters (STCW passenger ship-specific safety training, Enhanced damage stability training, Regulation II-1/19-1 of SOLAS and draft MSC Circular on Guidelines for PSC Officers on seafarers’ rest hours)
Mr H Tunfors (SWEDEN)
|WG2||Training Matters (BAHAMAS’ experience of implementing the 2010 Manila Amendments to the STCW Convention and Code, Information communicated through GISIS to reduce administrative burden and, scope the review of the 1995 STCW-F Convention)
Ms F Fadil (SINGAPORE)
|WG3||Human Element Issues (Guidelines on Fatigue, Revised guidelines on implementation of the ISM Code, and consideration of proposals / comments related to manning)
Captain M De Gracia (BRAZIL)
|DG1||Validation of model courses (Compare scope of the provisions in the STCW Code related to training for 4 draft model courses for validation and prepare draft terms of reference for 8 other model courses)
Captain K Deboo (INDIA)
The meeting was attended by representatives from 86 Member States, 3 Associate Members, 3 Inter-Governmental Organisations and 24 Non-Governmental Organisations.
In his maiden address to the Sub-Committee, the Secretary-General of IMO, Mr K. Lim, welcomed delegates and vowed to build on the work of his predecessors. He said that the core goals can only be achieved when Member States implement standards properly and rule-making, the role of the IMO, focusses on implementation at a global level. Announcing the theme for World Maritime Day to be held on 29 September 2016, “Shipping, indispensable to the world”, he stated that 90% of world trade is carried by sea and sea borne trade continues to expand bringing commensurate benefit to consumers. At present, there are 50,000 merchant ships manned by over a million seafarers of every nationality, registered in 150 nations. However, in order to permit continuing expansion and meet the manning demands of the global pool, seafaring needs to attract the younger generation of manpower by persuading them that it can provide a credible career path. In his view, one of the overwhelming root causes of maritime accidents is that of human factors amongst which fatigue is a major hazard and this is increasingly recognised by the industry. He thus encouraged the Sub-Committee to update the guidelines which would promote a better understanding of fatigue at sea whilst reflecting current research on fatigue and sleep stating that Fatigue risk management (FRM) will improve the lot of seafarers whilst enhancing safety at sea. In conclusion, he mentioned several further items on the agenda, the Revision of Validation of Model Courses, also the development of a framework for a new STCW related GISIS module to reduce the administrative burden. Finally, he referred to the updating of the guidelines for Implementation of the ISM Code by Administrations and revision of the training requirements for personnel serving on board passenger ships which would also be considered by the Sub-Committee.
In addition to this address by the S-G of the IMO, Mr Ban Ki Moon, S-G of the United Nations subsequently paid a flying visit to Plenary during which he gave a tour d’horizon talk to delegates and IMO Secretariat, during which he referred to the outcome of the recent Paris conference.
Items of particular interest to InterManager Members are as follows:
- VALIDATED MODEL TRAINING COURSES. Three revised model courses were validated following work by the Drafting Group and will be uploaded to IMODOCS in due course:
- Advanced Training for Chemical Tanker Cargo Operations;
- Radio Navigation at Operational Level; and
- Personal Safety and Responsibilities.
A fourth model course, the Engine-Room Simulator was not finalised and will be sent back to the developer in line with newly established procedures for course validation guidelines. Terms of reference developed by the DG for the Engine Room simulator and a further 10 draft model courses, were approved, with a view to validation by HTW4 as follows:
- Ratings as able seafarer engine in a manned engine-room or designated to perform duties in a periodically unmanned engine-room (document HTW 3/3/5);
- Ratings forming part of a watch in a manned engine-room or designated to perform duties in a periodically unmanned engine-room (document HTW 3/3/6);
- Assessment, Examination and Certification of Seafarers (model course 3.12);
- Training course for Instructors (model course 6.09);
- Onboard assessment (model course (1.30);
- Basic training for ships subject to the IGF Code;
- Advanced training for ships subject to the IGF Code;
- Basic training for ships operating in polar waters;
- Advanced training for ships operating in polar waters;
- Ratings as able seafarer deck; and
- The use of Engine-room Simulation for training and assessment of seafarers in the engine department (model course 2.07).
- REPORTS OF UNLAWFUL PRACTICES ASSOCIATED WITH CERTIFICATES OF COMPETENCY. The Sub-Committee took note of information provided by the Secretariat (HTW3/4) detailing the large number of fraudulent Certificates of Competency found on board ships during inspections, or reportedly being used during 2014 and 2015. Member Governments were invited to submit proposals on a strategy to address the issue at the next session. The IMO website certification verification facility was used 12,486 times during 2015. With regard to any follow-up action taken if the information provided was incorrect, it was clarified that Parties are required to have in place electronic databases and proper points of contact after 1 January 2017. In this context, INDIA has already introduced an electronic certificate verification system.
- GUIDANCE FOR THE IMPLEMENTATION OF THE 2010 MANILA AMENDMENTS. The Sub-Committee agreed to draft amendments proposed by WG1 to the STCW Convention and Code regarding passenger ship training, for approval at MSC96. Considerations included emergency familiarisation, effective communication with passengers, crowd management training, also crisis management training and human behaviour training. Agreement was given to paragraph 2 of the draft new SOLAS Regulation 19-1 on Damage Control Drills for passenger ships for submission to MSC96 and additionally, WG2 gave consideration to implementation guidance using the annex to document HTW 2.6.1 (CHINA) as the base document for the framework of the reporting and information requirements under articles IV, VIII and IX of the STCW Convention and Section A-1/7 of the STCW Code. In preparation for the major revision to the STCW Convention and its Code agreed in 2012 and which will be implemented on 1 January 2017, development of a new GISIS module under the existing database for which a framework was agreed and subsequently endorsed for approval by MSC, will hopefully reduce the associated administrative burden.
The Manila Amendments were adopted at a Diplomatic Conference in Manila in June 2010, with a view to ensuring that necessary standards to train and certify seafarers will be in place in order to keep pace with the operation of ever-advancing ship technology. STCW.7/Circ.16 provides details of the provisions relating to the transitional arrangements vis a vis the 2010 Manila Amendments and the STCW Convention plus Code. Envisaged changes will include:
- Measures to prevent fraudulent CoC practices;
- Revised requirements on hours of work and rest, drug and alcohol abuse;
- Improved training in modern technology;
- Leadership training;
- New training and certification for electro-technical officers;
- Updating of competence requirements for tanker personnel;
- New requirements for security training and repulsion of piracy attacks;
- Introduction of distance/web-based learning;
- Guidance for personnel operating ships in Polar waters; and
- Guidance for personnel operating Dynamic Positioning Systems
The Sub-Committee also endorsed a List of Principles and Provisional Scope of the review of the 1995 STCW-F Convention (The ‘Fishing’ Convention).
- MINIMUM MANNING AND SEAFARER FATIGUE.. The Nautical Institute submitted document HTW3/7, co-sponsored by InterManager on Minimum Manning and Seafarer Fatigue. In summary, the paper expressed the global concern felt as to the extent of seafarers fatigue, widely evident throughout the shipping industry. In particular, the Master / Chief Mate two-watch watchkeeping system is perceived to be inherently unsafe and does not permit the officer and master to fulfil all the duties necessary for the safe operation of the ship. Removal of this system would address the concerns of seafarers, minimise the risk of fatigued officers falling asleep while on watch, reduce the risk of harm to the marine environment and, most importantly, reduce the risk to the safety of seafarers.
In the ensuing discussion, views were expressed that:
- fatigue has a linkage to manning levels on ships;
- flag States understand the implications of fatigue when agreeing manning levels with companies;
- the linkage between fatigue and manning should be taken into account during the revision of the guidelines on fatigue mitigation;
- the proposal lacked proper justification;
- the issue of manning of ships is outside the scope of the assigned output; and
- the Sub-Committee must adhere to the clear instruction of the Committee (MSC) that the principles of safe manning should not be amended.
Thus the proposal to amend Annex 5 of resolution A.1047(27) was not agreed. However despite a withering intervention by the Netherlands and to a lesser extent, DENMARK against the proposal, the UK and GERMANY spoke persuasively for it and the UK might well submit its own proposal at the next session of HTW.
- REVISION OF THE GUIDELINES ON FATIGUE. Following an in-depth discussion, WG3 was established to consider this issue, taking into account comments and decisions made in Plenary, which included:
- the principle of user friendliness;
- whilst the concept of human performance and limitation is interesting, more information is necessary to consider them for revision of the guidelines;
- module 2 of the draft revised guidelines provide a comprehensive risk management approach that can be used by seafarers as appropriate to their circumstances;
- the guidance is not intended to provide a stand-alone fatigue risk management system (FRMS);
- document HTW3/8 (AUSTRALIA) provides a suitable robust basis for the review;
- fatigue at all levels should be taken into account;
- FRMS should not be the only tool for fatigue management;
- administrative workload may have an impact on fatigue;
- guidance should be practical and provide flexibility to manage fatigue for all, be easy to read and not too academic;
- the guidelines should not be mandatory;
- the diversity of ships and shipping companies should be taken into account;
- an holistic view of all factors related to fatigue mitigation must be considered;
- the Committee instructions not to amend principles of manning and SOLAS regulation V/14 must be adhered to;
- managing fatigue is a two-pronged problem requiring both adequate human resources matching the operational workload, and effective management of those resources;
- primary responsibility is placed on the master and seafarers with an FRMS that is subject to the documentation requirements of the ISM Code Safety Management System;
- increased administrative burdens on the master and seafarers may be counterproductive to reducing fatigue;
- fatigue should be managed through company safety management procedures;
- review of MSC/Circ.1014 should take into account the principles in document HTW3.8.2 (ICS); and
- Module 6 should not include issues related to administrative burdens.
Given the size of the task, WG3 made slow progress and due to time constraints, recognised that further intersessional work would be necessary. Thus in approving WG3’s report in general, the Sub-Committee noted the progress made with the revision of the guidelines on fatigue and established a corresponding group co-ordinated by AUSTRALIA under approved terms of reference. It also endorsed the view that future versions of the guidelines on the implementation of the ISM Code by Administrations should be issued as a MSC/MEPC.7 circular whilst also endorsing a draft Assembly Resolution forwarding it to the committees for approval prior to Assembly.
- COMPLETION OF GMDSS DETAILED REVIEW. Having considered the outcome of NCSR2 , MSC94 approved a revised plan of work (i.e. modifying the name of the output) and extended the target completion year to 2016. It also approved a new output on “Draft Modernisation Plan of GMDSS”, target completion year 2017, assigning NCSR as the coordinating organ with HTW as an associate.
- GUIDELINES FOR PORT STATE CONTROL OFFICERS ON CERTIFICATION OF SEAFARERS’ REST HOURS. The Sub-Committee noted that WG1 was unable to complete the work of amending the draft guidelines for port State Control Officers on certification of seafarers hours of rest and manning at this session. However it agreed to the main body of the [revised] guidelines being submitted to III 3, whilst informing them that the annexes to the draft guidelines will be finalised at HTW4 for approval by the Committee. The guidelines will replace the Appendix 11 Minimum manning Standards and certification of the Procedures for Port State Control, 2011.
Captain Paddy McKnight