The report doesn’t surprise me at all. The trouble is many ship managers are more likely to consult their legal advisers to ensure that their SMS has the maximum protection against liability rather than do something about it.
And meanwhile, vetters come by twice a year to offer criticism of one’s navigation practices. This last time, our ship was hit for, among other irrelevancies:
… the following relevant alarms and warnings were not set/activated for the previous voyage: Traffic separation zones, traffic crossing, traffic precautionary, deeper water traffic, recommend traffic lane, fairway, fishing grounds, anchorage prohibited, spoil ground, etc.
Excellent observation, we were courting with utter disaster by not having loud warnings jangling every time we crossed a fishing ground or when we entered the fairway we were meaning to enter! And how on Earth did anybody survive going to sea without an alarm for “anchorage prohibited?”
Also:
The passage plan was incomplete, lacking a documented route on the ECDIS from the departure berth to the first waypoint (approximately 1.2 NM); only UKC calculations were performed.
Good heavens, how were we to know where we were going without a waypoint starting on the actual dock itself? Never mind that a leg with any useful amount of cross-track space will include the ground, a leg with narrow enough cross-track will be impossible to keep and dangerous to try keeping, and the conning officer undocking on the bridge wing can’t see the ECDIS from out there anyway…
These are the guys who are supposed to be ensuring we’re doing things safely, and will pay lip service to “alarm fatigue,” and then make comments with real-world consequences like this - one dock refused to take us until these “concerns” were addressed!
How is a navigator supposed to win when we’ve got landlubbers writing the rules and idiots enforcing them?
… and cover up those windows!
There’s too much light and distraction for reading all these screens properly.
How did we manage to safely avoid reefs and find our ways along coasts, before all these wonderful “aids to navigations”?
We used our senses to detect change of ship’s motion, our ear to listen for breakers and most of all, our eyes to look out the window.
But best of all, we didn’t get distracted by alarms going off all the time.
Ooooo I’ve been hit on that one too for the inbound voyage (harbor entrance to dock). On an OSV… and if I recall correctly it was in Fourchon no less (may have been Onne, Nigeria though, but same issue). “Ok Mr Auditor… explain to me how I’m supposed to do that when I don’t know my ‘intended’ berth until I’m tied up at whatever spot was unoccupied?!”
And he absolutely wanted the route to end at my current location.
ECDIS implementation was a huge cockup and remains to be.
The tech is great no argument there
The amount of devices that can sound alarms on a bridge is massive and some you wont know about for years.
What are IMO Class doing about that…
They are introducing with great zeal and passion bridge alarm management systems , which subsequently result in extra chapters in SMS that are auditable, can be updated, improved , expanded and of course very well documented as well as risk ASSessed.
Next they will woŕry once again about rest hours during their meetings in posh hotels , lobster lunches washed with vintage wine.
In post conference meetings and minutes they will conclude that AI and modern bridge technologies justify reductions in safe manning certificates.
Isn’t it beautiful.?
they need to be dealing with hardware manufacturers and make a rule:
No device can have an internal alarm horn.
Hence everything has to get wired out to a panel so you know what the alarm is and can silence it.
I worked AHTS and DP Semi’s, try to count the PC’s, power supplies, ups’s etc and all the other gear on the bridge ahhh
IMO Class??
Sorry missed a bit
IMO/Class
both organisations
Perhaps your right electronics should move into the IMDG code.
Great idea.
That’s very likely correct. According to the report the company has responiblity for closing the gap yet the shipboard audits focus at the shipboard level.
From the report:
Action plan for ship managers and maritime stakeholders
The ETA findings suggest that ECDIS competence should increasingly be treated as an operational risk management issue rather than purely a training compliance matter.
Ship managers and maritime stakeholders should consider the following actions: …
Expecting ship’s crew to fix this problem is misguided to say the least.
I remember when for the 1st time the IMO said
“If a Captain believes his crew are not competent with ECDIS and its got compliant charts etc he can turn it off”
That changed the rules of all aids must be on.
Implementation of ECDIS was a total shambles
Hows the bridge going to be with the next PC that turns up?
I know an Offshore fleet that removed them from the bridges as 2999t so not mandatory fit.
After all you only need one chart on a rig supply boat right?
The auditors are looking for simple compliance with written documents, if compliance doesn’t make sense change the documents, perhaps using the Ship Specific Instructions and/or the passage plan.
This has worked for me a couple times.
The master writes a set of instructions for creating the voyage plan, for example: "Passage Plans shall be prepared berth to berth in accordance with"SOLAS V/34 etc… and Company SMS section…etc and than some instructions “When the arrival berth is not assigned” and so forth.
Might also work for irrelevant alarm settings, Add it to the passage plan, " To avoid irrelevant alarms the following alarms are disabled" etc
This shifts the discussion away from simple compliance and the issue will likely get dropped or, worse case become about proper documentation rather than crew compliance.
“How will you know if you’re going into a TSS if you don’t have that item selected as part of your route check function!!?” I wanted to tell the inspector because I don’t have my head up my ass.
Asking where the auditors head is seems like an obvious question.
It might be worth while looking at the exact language and terms used in the requirements.
Here’s the GUIDELINES FOR VOYAGE PLANNING.
I didn’t spend a lot of time with this but for one the term “Guideline” is used and the word “shall” does not appear but “should” does 20 times.
Also found this: ECDIS – GUIDANCE FOR GOOD PRACTICE
From the document:
6 Unnecessary alarms and indications – feedback from mariners shows that ECDIS can produce excessive and distracting alarms. This is due to a combination of the interpretation of the requirements of the ECDIS Performance Standards and the ENC encoding. Some control over the number of alarms and indications is available to the mariner in ECDIS built to the revised Performance Standards (resolution MSC.232(82)), but this is not always recognized. Workaround – the methods available to minimize alarms are included n the syllabus of IMO model course 1.27 on Operational Use of Electronic Chart Display and Information Systems (ECDIS)
Depends on the company SMS as well but it might be worth while asking what the requirements are for a track-line (not just an appraisal and a plan) to the berth in situations when the specific berth is not known.
Is the vessel required to wait outside the port in this case?
You’re right and I once tried to die on the “shall vs should” hill during a SIRE vetting in regards to some sort of GMDSS testing and another time for AIS CPA alarms on the ECDIS. Still got written up. for tankers at least, might as well have SIRE writing the SMS. All of this has become an absolute farce.
The wheelhouse during a audit is not the time or place for resolving ambiguity in IMO’s written guidance. It should instead be done in advance somewhere within the SMS.
There are several levels of SMS (voyage plan, master’s instructions, ship specific, company SMS etc) between IMO guidance and how the ship’s navigation equipment is configured. That’s where the question should be resolved,
From here: 2023 GUIDELINES ON IMPLEMENTATION OF THE INTERNATIONAL SAFETY MANAGEMENT (ISM) CODE BY ADMINISTRATIONS (section 313)
Therefore, particular operations should be ship-specific and fully reflected in manuals, procedures and instructions.
If the ship has a solid SMS, a ship’s officer, in this case the 2nd mate, should be able show compliance with instructions at the shipboard level.
Wonder if some notation in the Standing Orders regarding “when arrival berths are unknown during voyage planning…” would make any difference to an auditor.
This still doesn’t solve the issue that the request to have a waypoint at the dock, even if it’s known beforehand, stands to provide the navigator nothing but nuisance alarms in exchange for zero useful information. Similarly, the request to have AIS CPA alarms on the ECDIS (in addition to ARPA alarms for concerning traffic on the RADAR) for things like pilot boats and tugboats will give us nothing but constant alarms while telling us absolutely nothing of value.
If what we need is SMS guidance that clearly states that all these alarms shall be at the discretion of the master, or something like that, maybe that would satisfy? But I’d be afraid even then that these vetters would tell the captain that now he’s wrong for not requiring every !@#$% nuisance alarm to be blaring at all times.
Did any of these guys ever sail? How did they even make it off the bridge alive in the days of paper charts, if all these electronic noisemakers are so important?