Does it Make Sense for Individual Nations to Have Higher Standards than STCW


#22

This is the kind of question that everybody here knows the answer but nobody knows. Everybody gets to blame what they “know” is wrong with the country.

My answer would be that the government needs to take an active role and unions need to be strengthen. Takes a coordinated effort.

People who are reflexly anti-government, anti-union are going to say that if the government allows the capitalist a free hand and the unions get crushed then the magic of the free markets will prevail and either way, if the maritime industry dies or thrive, or just limps along, that was the proper outcome.

For people who think that political correctness is destroying the country they can drag that horse out and start beating.

None of us here has the chops to show the other is wrong.


#23

They wouldn’t know as they don’t smell.


#24

Another possible way for a coordinated effort is to stop the infighting and undercutting of each other and get on the same page? One union for all officers and unlicensed? One coalition of all the maritime schools? One… well you get the idea.


#25

Ha!


#26

Standards are dead - from today’s Lloyds List

Racing to the bottom
15 Feb 2018
OPINION
Michael Grey
Flag states and registers seem to be competing to attract tonnage by offering incentives for minimum manning

Seafarers on a tanker
THE WORK TO BE DONE ON A SHIP WON’T DISAPPEAR WITH THE PERSONNEL NO LONGER ON THE SHIP’S ARTICLES.
AUTONOMOUS ships will clearly remain a fixation for many people in our industry for a long time yet, or perhaps until people work out that they are unaffordable, but the race to reduce crew numbers from “conventional” ships continues.

Indeed, you would sometimes think that there was some sort of international award being offered for the most adventurous crew reductions. Perhaps this might be thought of as incremental autonomy, with one day some owner revealing that the last human being had been paid off his ship and it was now running on automatic.

The facilitators in this race to the bottom would appear to be the various ship registers, which often seem to be fighting with each other to attract tonnage by offering exciting incentives on manning arrangements.

It is not a competition we ought to be encouraging, especially if you actually speak to those on board ship who are working harder and harder, as the jobs don’t disappear with the personnel no longer on the ship’s articles.

It is sometimes argued that well-designed and highly automated ships really don’t need much human intervention, with the crew assumed to be just sitting around overseeing the equipment and waiting for things to go wrong. It might appear to be quite boring, really. Of course, it never works quite like that.

When a ship is very new, the first voyages are spent putting right all the things the shipyard didn’t and discovering new and exciting faults that require rectification.

With this all done, a well-found ship hopefully enters a sort of brief “golden age”, before things start to wear out, corrode, leak or overheat. People always used to say the Japanese system, which involved selling a ship just around its second Special Survey, had a great deal to recommend it, leaving the new buyer to pick up the accumulation of rising maintenance costs.

But it might be suggested that there are a number of guiding principles that ought to dictate the manning levels.

First, there is a direct correlation between the maintenance state of a ship and the manpower available to keep it all running sweetly.

Second, there should be an assumption that things will go wrong; people, like those ashore, take days off sick and the burden on those left should be reflected in the manning level. It’s not rocket science. Third, there is a social and human aspect to this level, with more to life than work.

Disgraceful flags

But let us get back to our competition between flag states and registers for the most adventurous manning arrangements, as represented by the certificates of minimum manning. There is nothing even remotely new about this.

There have always been thoroughly disgraceful flags that have operated chiefly as revenue earners with no interest whatsoever in the safety of the ship or any other standards. They were the fall-back position for equally disreputable, or perhaps just poverty-stricken, owners who failed dismally to convince more quality-driven registers of their shipmanagement arrangements.

Oblivious to all the indicators of quality or respectability; the “Qualships” and “White Lists”, the useful league tables put out by the International Chamber of Shipping and others, these registers serve the down-at-heel and the ships in the autumn of their days, chiefly sailing in areas where port state control is non-existent or, let’s face it, “revenue-driven”.

But there are other flags, highly respectable ones, which enrage their competitors by their seemingly elastic interpretation of what constitutes reasonable minimum manning.

People operating ships in the UK probably still grind their teeth in rage at the sort of manning that is permitted in Norway, although the Norwegians always point to the role of advanced equipment as they issue certificates which appear to legitimise minuscule manning levels. They cite the role of science and technology. The arguments will continue.

But you sometimes hear of some remarkably rum cases in which flags you thought of as rather more particular have been excessively liberal with their manning certificates.

I have one in front of me as I write; a 20,000 gt general cargo ship, licensed to operate with a minimum crew of 13. This crew comprises a watch-keeping master (which is a disgrace) and two mates, three seamen and a cook, three engineers and three engine room ratings.

This is probably a ship of around 30,000 dwt, operating internationally, and you might think that the register accepted this manning proposal on the grounds of huge levels of technical sophistication.

If you thought that, you would be wrong, for this bog-standard ship doesn’t even a have an unmanned machinery notation. Here is a quite large ship, crewed by people who one might guess will struggle to keep their hours of rest legal, operating with the size of crew and with a system that would have been deemed not unreasonable, a few years ago, in a 2,000 dwt coaster.

If they can convince the administrators of this flag that this is reasonable, what are you complaining about? But this undermanned ship, one might surmise, will be competing in the markets with others that are owned by more particular folk, who man their ships to reasonable levels, but who will end up being thoroughly disadvantaged.

The flag that issued this certificate is engaged in this race to the bottom and ultimately does nobody — the more particular registers, the competing ship operators and of course, the suffering overworked crew — any good whatsoever.


#27

So Lloyds list sees it now?

Renault: Everybody is to leave here immediately! This cafe is closed until further notice. Clear the room, at once!
Rick: How can you close me up? On what grounds?
Renault: I am shocked- shocked- to find that gambling is going on in here!
Croupier: [hands Renault money] Your winnings, sir.
Renault: Oh, thank you very much. Everybody out at once!

We seemed to have passed this way before…T-ball thread

To which I replied:

To which I can finally add it is NOW known to Lloyds List as well.


#28

Recently, a US pilot that brings in lots of ships told me that the Norwegian NIS, their international ship Register (likely with no Norwegian crew) has gone downhill to become a low quality flag of convenience with a lot of junk ships.

Considering that US Flag Transatlantic Lines had junk ships operating under DNV class, that goes to show that DNV is an active participant in the race to the bottom, and isn’t what it use to be.

So much for supposedly high Norwegian standards. Maybe they use to be, but now that’s just an ancient myth.

When a 20,000 GT ship arrives in the US with only 13 required crew, it should be detained. The USCG should subject the ship to PSC inspection at the microscopic level. It should not be allowed to sail again until it is crewed to US standards.

If another ship flying that flag shows up with only 13 crew, the same thing should happen, plus, for the next year, all ships flying that flag should have a thorough PSC inspection at sea before they are allowed entry into US ports. If a third ship of that flag arrives off a US port seeking entry with inadequate Safe Manning, all ships of that flag should be flat out banned from US ports for five years.


#29

What is the minimum safe manning requirements for a US flag ATB pushing a large tank barge on a voyage involving passage in open water, or in other countries territorial waters?? (I.e. USWC-Alaska etc.)


#30

I agree with you. The ATB loophole should be shutdown.


#31

Well who set up the Liberian Register and where is it administered?
The Liberian Safe Manning Certificate states that the Master is ultimately responsible for the safe manning of the vessel and the number of the crew. Good luck with that!
A crew of 13 would be unable to conduct cargo operations concurrently with storing the vessel and bunkering operations according to USCG requirements, never mind Security of that sized vessel.
Michael Grey has been the voice of reason for many many years in FairPlay Magazine but the publication was rarely made available to sea staff.


#32

American citizens should not be allowed to create, own, or manage flags of convenience or foreign class societies. Flags of convenience and class societies should not be allowed to have offices or employees in the US.

Neither US citizens, nor publicly traded companies listed on a US stock exchange, should be allowed to own, manage, or operate ships under a flag of convenience or a class society of convenience.

It’s long past time to stop this flag of convenience scam.


#33

Minimum safe manning is purely the requirement to handle the vessel while transiting from A to B, not to do maintenance, or to conduct cargo operation while in port.

Most offshore vessels has small MSM requirement, but the actual marine crew on board usually exceed that, because operational requirements demandes more.

Here is a MSM Cert. from a typical AHTS under Singapore flag:
.BAT_SG_ MSM_MPA.pdf (367.9 KB)
Actual manning was 13:


#34

What happened to Capitalism and the land of the free??


#35

I’m all in favor of capitalism and freedom. But that does not mean to allow anarchy, or blantant tax evasion and regulatory evasion through a total scam of pretending to be a third world village in some monkey flag country m, where the only purpose is evasion of all the rules that every other American has to live by.


#36

Not according to IMO Resolution A.1047(27).


#37

Also not according to the 46 CFR 15.705(a):

“The minimum safe manning levels specified in a vessel’s COI or other safe manning document take into consideration routine maintenance requirements and ability of the crew to perform all operational evolutions, including emergencies, as well as those functions which may be assigned to persons in watches.”


#38

I must have missed that one. (Senior moment)
How will the U.S. Coast Guard, as the administration for U.S.-flag ships, conform U.S. regulations to implement this new international requirements?

Edit: It appears they have, at least for “inspected vessels”.


#39

I understand you may be making a technical correction to Ombugge’s statement but surely you personally don’t believe because the regulations are written that way the numbers of officers and ratings entered on the Manning Certificate are sufficient to properly maintain the ship? One would have to have a pretty limited understanding of “routine maintenance requirements” to believe that. To use the engine department as an example - if you count draining the settlers, cleaning strainers, changing filters as the universe of maintenance maybe, maybe you could get by with those ridiculous numbers. A ship getting by with that sort of “routine” maintenance is doomed.

I wonder if the estimated manhours for PM (readily available from a ship’s CMMS) if dumped out and add in a corrective maint allowance also made and THEN compare to manhours available with the stated minimum manning. After deducting hours for watchkeeping / operations type activities I’m sure there will be a discrepancy. I know it does not add up on a drillship. This is why material readiness / reliability / availability slowly declines. Leading to ever more (mis)management from town.

So if it’s a joke why do they (and this includes MI, Panama, Liberia, Cyprus) issue these phoney requirements? This is what I mean by the myth of minimum manning.


#40

I agree with what you have said . I have seen unbelievable manning levels for mega container ships. The engine room crane may lift the lid of a strainer box but given the size of the lid it is not done by one person or even two.


#41

Another thought, many companies also have computerised planned maintenance systems. Bring back those time and motion “experts” and see if the manning levels can achieve it.