APPENDIX B International Marine Certification Roles, Responsibilities, and Standards

National requirements for the licensing of masters and mates of seagoing ships, and professional development to meet these requirements, are based on the Standards for Training, Certification, and Watchkeeping (STCW) guidelines promulgated by the International Maritime Organizational (IMO). The IMO's standards are important in evaluating ship-bridge simulation for marine training and licensing because they form the foundation for applying marine simulation to marine certification.

The IMO's recommendations for pilotage (Inter-government Maritime Consultative Organization Resolution A.485(XII)CH:151 Training, Qualification and Operational Procedures for Maritime Pilots Other than Deep-Sea Pilots) also serve as basic professional standards for simulation applied to certification of marine pilots. Although many of the port-level pilotage systems (administered at the state level) generally parallel the IMO's pilotage recommendations, the IMO's recommendations have not been systematically applied in the United States. The federal government has not required or encouraged state-level pilotage systems to conform to the IMO's pilotage recommendations, nor has it used these recommendations as the basis for either federal or Great Lakes pilotage systems (NRC,1994).

This appendix describes and discusses the roles of IMO and the STCW, the IMO's recommendations for maritime pilot development, and the general adequacy of IMO standards and guidelines.

INTERNATIONAL PROFESSIONAL STANDARDS FOR MARINERS

A number of international efforts have been made to improve the safety of life and property at sea. Many of these efforts were stimulated by major marine



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--> APPENDIX B International Marine Certification Roles, Responsibilities, and Standards National requirements for the licensing of masters and mates of seagoing ships, and professional development to meet these requirements, are based on the Standards for Training, Certification, and Watchkeeping (STCW) guidelines promulgated by the International Maritime Organizational (IMO). The IMO's standards are important in evaluating ship-bridge simulation for marine training and licensing because they form the foundation for applying marine simulation to marine certification. The IMO's recommendations for pilotage (Inter-government Maritime Consultative Organization Resolution A.485(XII)CH:151 Training, Qualification and Operational Procedures for Maritime Pilots Other than Deep-Sea Pilots) also serve as basic professional standards for simulation applied to certification of marine pilots. Although many of the port-level pilotage systems (administered at the state level) generally parallel the IMO's pilotage recommendations, the IMO's recommendations have not been systematically applied in the United States. The federal government has not required or encouraged state-level pilotage systems to conform to the IMO's pilotage recommendations, nor has it used these recommendations as the basis for either federal or Great Lakes pilotage systems (NRC,1994). This appendix describes and discusses the roles of IMO and the STCW, the IMO's recommendations for maritime pilot development, and the general adequacy of IMO standards and guidelines. INTERNATIONAL PROFESSIONAL STANDARDS FOR MARINERS A number of international efforts have been made to improve the safety of life and property at sea. Many of these efforts were stimulated by major marine

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--> disasters. Usually international professional standards for mariners have been preceded by national requirements. The licensing of masters and mates remains a national responsibility of maritime nations that operate a merchant marine (these nations are referred to as flag states). The licensing of marine pilots is typically administered at the port level rather than nationally (NRC, 1994). Because mariners operate across national and international boundaries and must effectively interact with the shipping of other flag states, the qualification of mariners licensed by flag states is of interest to other flag states. Major marine accidents, especially since the Exxon Valdez grounding, have focused attention on improving these standards. The qualification of marine pilots is also an important international issue, especially to the master of each vessel using pilotage services and that vessel's operating company. Most marine pilots, however, do not operate across national boundaries. Their service is highly specific to the locale in which they serve. Although pilotage has been implicated as a contributing factor in a number of marine accidents, corrective action that may be necessary has been viewed by the international maritime community as largely within the purview of the port-state pilotage authorities and has not stimulated review and improvement of international professional standards for pilots. THE INTERNATIONAL MARITIME ORGANIZATION Systematic international efforts to improve marine safety originated with the establishment of the Inter-government Maritime Consultative Organization (IMCO) as a specialized consultative organization of the United Nations. IMCO held its first meeting in 1959. The first Safety of Life at Sea (SOLAS) Convention was held in 1960. The result was the delineation of responsibilities for the safety of vessels during at-sea operations. During the 1970s, IMCO began to develop technical standards. In 1978, IMCO promulgated the STCW guidelines. The STCW established a common standard based on marine certification practices of the traditional maritime nations, including the United States. The objective was to raise standards to a minimum level worldwide. The STCW was amended in 1991 (IMO, 1993). In 1982, IMCO changed its name to the International Maritime Organization (IMO). The IMO is currently revising the STCW guidelines (IMO News, 1994). Much attention has been directed to strengthening STCW guidelines for the development and demonstration of competency, including the use of marine simulation. Considerable attention is being paid to the role of marine simulation in meeting STCW guidelines, and substantial guidance on using simulation is anticipated. In addition to the STCW guidelines, the IMCO also published marine pilot standards in 1981 (IMO, 1981). IMO has relied on member countries to ratify and enforce international guidelines and standards. Generally, member countries are required to conform

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--> to the standards of the appropriate, competent international organizations. Because of accidents involving substandard ships and crews, suggesting that the actions of some flag states has been deficient, the IMO has been actively promoting port-state enforcement of IMO standards (IMO News, 1994). The IMO continues to move toward measures that would enable it to make better assessments of member states' compliance with the various international conventions. IMO STANDARDS FOR TRAINING, CERTIFICATION, AND WATCHKEEPING The STCW guidelines contain certification, watchkeeping, experience, and knowledge requirements for masters, chief mates, and deck officers. It also includes standards for engineering department officers and radio officers. Experience is relied on as the means by which mariners acquire practical knowledge and become capable of effectively applying theoretical and practical knowledge, skills, and abilities. A demonstration of knowledge of how to perform various functions and tasks, rather than a demonstration of ability to perform them, is the basis for basic competency determinations. The principal exceptions with respect to determining minimum competency are contained in a resolution adopted by the 1978 International Conference on Training and Certification of Seafarers. This resolution encourages its members to require radar simulation training and training in the use of collision-avoidance aids (IMO, 1993). Experience and knowledge requirements are categorized by vessel tonnage and mariner category—master, chief mate, and officers in charge of a navigational watch. There are also mandatory minimum requirements intended to ensure the continued proficiency and updating of the knowledge of masters and all deck officers (IMO, 1993; Muirhead, 1994). Applicability of Standards to Seagoing Ships Tonnage categories that apply to certification and experience requirements for seagoing for seagoing ships are: ships under 200 gross register tons, ships between 200 and 1,600 gross register tons, and ships over 1,600 gross register tons. Marine licenses issued for operation of vessels over 1,600 gross register tons are referred to as ''unlimited". For seagoing ships that are under 200 gross register tons and not engaged in near-coastal voyage, there are slightly higher requirements than for ships engaged in near-coastal voyage. The tonnage categories that apply to knowledge requirements for seagoing ships are ships of less than 200 gross register tons and tankers and chemical ships with respect to onboard safety and pollution prevention. There are also

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--> recommendations for special training regarding vessel maneuverability by type of seagoing ship to reflect differences in handling among small ships, large ships, and vessels with unusual maneuvering characteristics (IMO, 1993). Watchkeeping Requirements STCW watchkeeping requirements apply to ship owners, ship operators, masters, and watchkeeping personnel—all of whom are charged to observe navigational watchkeeping procedures contained in STCW Regulation II/1. Shipmasters are specifically charged "to ensure that watchkeeping arrangements are adequate for maintaining a safe navigational watch" (IMO, 1993). Officers are responsible for the safe navigation of the vessel while on watch, under the general direction of the ship's master (IMO, 1993). Regulation II/1 provides specific guidance on: watch arrangements; fitness for duty; navigation, including passage planning and frequent position fixing; navigational equipment; navigational duties and responsibilities,including watch assumption, relief, and notifications to the master; lookout; navigation with a pilot embarked; and protection of the marine environment. The provisions of the regulation include areas of responsibility overarching guidance for conducting these responsibilities. More-specific guidance on relief and conduct of the navigational watch is provided in resolutions that accompany the STCW guidelines (IMO, 1993). Experience Requirements There are specific service requirements for officers in charge of a navigational watch, as well as masters, and chief mates. These requirements vary by tonnage requirements and the position for which an individual is seeking certification. Regulation II/4 specifically requires a minimum of three years of seagoing service for officers in charge of a navigational watch on ships of 200 gross register tons or more. Every candidate for such certification is required to "have seagoing service in the deck department of not less than three years which shall include at least six months of bridge watchkeeping duties under the supervision of a qualified officer" (IMO, 1993). The regulation further states that "an Administration may allow the substitution of a period of special training for not more than two years of this approved seagoing service, provided the Administration is satisfied that such training is at least equivalent in the value to the period

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--> of seagoing service it replaces" (IMO, 1993). This latter provision has been interpreted by the United States and other countries as permitting the substitution of maritime education and training received by cadets at maritime academies for the required two years of seagoing service. The STCW guidelines do not specifically provide for substitution of specialized training for the required one year of seagoing service (IMO, 1993). The IMO is reviewing the adequacy of these provisions. The STCW guidelines do not explicitly define seagoing service as service on board an actual ship. A few countries, including the United States, have interpreted seagoing service to include appropriately structured and approved marine simulator-based courses. These countries grant remission of sea service for such courses to satisfy some portions of the one-year minimum requirement for officers in charge of a navigational watch aboard ships of unlimited tonnage or seagoing service requirements for advancement. These countries generally remit a higher ratio of sea service for simulator courses than for actual service, with the ratio varying from 2 to 1 to 8 to 1 (the U.S. Coast Guard grants a 6 to 1 ratio for marine simulator-based courses that it approves for sea-time equivalency). These ratios have been arbitrarily determined based subjective determinations of value to professional development (Muirhead, 1994). Knowledge Requirements The STCW and its supporting regulations and resolutions contain detailed knowledge requirements. The knowledge categories for masters of unlimited tonnage vessels are outlined in Chapter 1. The knowledge categories for officers in charge of a navigation watch aboard unlimited tonnage vessels (required by an appendix to Regulation II/4) are: celestial navigation, terrestrial and coastal navigation, radar navigation, watchkeeping, electronic position fixing and navigation systems, radio direction finders and echo sounders, meteorology, magnetic and gyro compasses, automatic pilot, radio communications and visual signaling, fire prevention and fire-fighting appliances, life saving, emergency procedures, ship maneuvering and handling, ship stability,

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--> English language, ship construction, cargo handling and stowage, medical aid, search and rescue, and prevention of pollution of the marine environment. There are additional, special knowledge requirements with respect to masters and officers serving aboard tankers and chemical carriers (IMO, 1993). Recency Requirements Regulation II/5 establishes minimum requirements to ensure the recency and updating of knowledge of masters and deck officers. At intervals not greater than five years, each ratifying members' licensing or certification authority (i.e., member administration) is required to ensure medical fitness and professional competence. The alternatives for establishing professional competence include: at least one year of approved seagoing service as master or deck officer within the preceding five years; performance of functions relevant to the duties of the certificate held, which are considered equivalent to the required seagoing service; or completion of one of the following: (1) passing an approved test, (2) successfully completing a prescribed course or courses, or (3) serving as a deck officer in a supernumerary capacity for a period of three months immediately prior to serving in the rank of the certificate held. The responsible IMO administrators are also charged to: … formulate or promote the formulation of a structure of refresher and updating courses, either voluntary or mandatory, as appropriate, for masters and deck officers who are serving at sea, especially for re-entrants to seagoing service. The administration shall ensure that arrangements are made to enable all persons concerned to attend such courses as appropriate to their experience and duties. Such courses shall be approved by the administration and include changes in marine technology and relevant international regulations and recommendations concerning the safety of life at sea and the protection of the marine environment (IMO, 1993). Simulation Training Simulation training is strongly recommended by the STCW guidelines for all masters and deck officers, but is not required. There are no provisions to guide the specific use of marine simulation in satisfying seagoing requirements. Resolution 17 of the 1978 International Conference on Training and Certification of Seafarers, recommends "additional training for masters and chief mates

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--> of large ships and of ships with unusual maneuvering characteristics" that includes simulation training (IMO, 1993). In addition to stating that a prospective master should have suitable, general experience as master or chief mate, the resolution states that this individual "have sufficient and appropriate maneuvering experience as chief mate or supernumerary on the same ship or as master, chief mate or supernumerary on a ship having similar maneuvering characteristics …" or, as an alternative, "have attended an approved shiphandling simulator course on an installation capable of simulating the maneuvering characteristics of such a ship…" ( IMO, 1993). Updates to the STCW The IMO is currently updating the STCW guidelines. The forthcoming revisions are expected to include a new, more definitive requirement to demonstrate a range of skills and specific performance standards. The equivalency articles with respect to seagoing services are expected to remain in place. The one-year minimum seagoing service requirement may be redefined as one year of actual onboard experience, although there may not be an actual prohibition against using simulation to satisfy a portion of the one-year requirement. Extensive policy and technical guidance is being developed for the application of marine simulation. IMO RECOMMENDATIONS FOR MARITIME PILOTS IMCO Resolution A.485 (XII)—Training, Qualification and Operational Procedures for Maritime Pilots Other than Deep-Sea Pilots—provides recommended standards for the certification and qualification of maritime pilots who are: not deep-sea pilots (pilots providing pilotage services outside of a local pilotage area); ship's masters; or members of a ship's crew who are authorized by license or certificate to perform pilotage duties in specific areas by a competent authority (that is, the responsible administration within an IMO member country or another entity that by law or tradition provides a pilotage service). The competent authority may exempt from the provisions of the resolution any individual who carries out only berthing duties. The resolution calls for each maritime pilot to: be medically fit; meet STCW standards for certification of masters, chief mates, and officers in charge of a navigational watch; be appropriately certificated or licensed; and meet the additional standards of the resolution.

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--> It also encourages the certificate or license to indicate the extent of a pilot's authority to provide services, such as maximum size, draft, or tonnage. With respect to continued proficiency and the updating of knowledge, the resolution states that the competent authority must satisfy itself that, at not greater than five-year intervals and after extended absences from service, all pilots for which it exercises jurisdiction: continue to possess recent navigational knowledge of the local area to which the certificate or license applies; continue to meet the medical fitness standards [prescribed in the resolution]; possess knowledge of the current international, national, and local laws, regulations, and other requirements and provisions relevant to the pilotage area or duties (IMO, 1981). The resolution also recommends that each competent authority have control over the training and certification of pilots, including: the development of standards; administration of prerequisites for training, examination, and the issuance of certificates or licenses; and the investigation of incidents involving the service of pilots (IMO, 1981). Recommended knowledge requirements for maritime pilots include: boundaries of local pilotage service areas; the International Rules for the Preventing of Collisions at Sea and applicable national and local safety and pollution prevention rules; systems of buoyage in use in the pilotage service area; characteristics of local lighted aids to navigation, fog signals, and beacons; all relevant information about other aids to navigation in the pilotage service area; pertinent channel, geographic, and topographic data; proper courses and distances; traffic separation and routing schemes, ships' services, and traffic management systems (i.e., vessel traffic services); hydrographic data, including tidal and current effects; anchorages; ship-bridge equipment and other navigational aids; radar and automatic radar plotting aids; communications and available navigational information; radio navigational warning broadcast systems; maneuvering characteristics for all vessels piloted, including any limitations associated with various propulsion and steering systems; hydrodynamic and other physical factors affecting ship performance; assist tugs;

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--> English language skills, with sufficient fluency to express communications clearly; and other knowledge considered necessary by the competent authority (IMO,1981). ADEQUACY OF INTERNATIONAL STANDARDS To obtain the support of IMO member states for their acceptance and implementation, the STCW standards reflect a middle ground among all the existing national requirements. The STCW forms modest baseline standards. Its requirements with respect to knowledge, skills, and abilities are based on long-standing traditional practices known to work if effectively applied. The adequacy of these standards with respect to modern navigation technology has not been assessed. Furthermore, there are no content or quality control requirements to guide the development of knowledge, skills, and abilities through sea service, nor have sea-time requirements been validated through a program of research to determine their relevancy and adequacy. Flag-state licensing authorities had few motivations to exceed STCW requirements, although forward-looking shipping companies and unions often have programs that exceed both applicable license criteria and STCW provisions. That the STCW is undergoing considerable updating reflects increased interest in improving marine safety as a result of major marine accidents with extensive pollution, beginning with the grounding of the Exxon Valdez in 1989. Action to update the STCW guidelines also reflects flag-state and marine industry concerns about industry trends to reduce crew sizes and operating costs, and the safety implications of resulting practices, such as one-man watchkeeping at night. REFERENCES IMO (International Maritime Organization). 1981. Training, Qualification and Operational Procedures for Maritime Pilots Other than Deep-Sea Pilots. IMCO Resolution A.485(XII) adopted on 19 November 1981. London, England: IMO. IMO (International Maritime Organization). 1993. STCW 1978: International Convention on Standards of Training, Certification, and Watchkeeping, 1978. London, England: IMO. IMO News. 1994. World maritime day 1994: better standards, training and certification—IMO's response to human error. IMO News (3):i-xii. Muirhead, P. 1994. World Maritime University, personal communication to Wayne Young, Marine Board, National Research Council, September 20. NRC (National Research Council). 1994. Minding the Helm: Marine Navigation and Piloting. Committee on Advances in Navigation and Piloting, Marine Board. Washington, D.C.: National Academy Press.