3rd Marex feature to build consensus on making new STCW post HTW subcommittee meeting at IMO London that has just concluded in February
Name or Organisation – Academic Council
Mobile No – 9823158057
Email Id xceoitccsa@gmail.com Individual
Residential status – Resident
Occupational status – Seafarer, ashore,
No of years since 1978 – 50 years
Q 1. Should there be new STCW or only comprehensive revision to Manila Amendments?
A. New STCW
Q 2. Has STCW been helpful in maintaining or increasing global seafarer standards of competence?
A. Less than 40% success
Q 3 Is STCW uniformly interpreted or implemented across the globe?
A. No
Q 4. Are seafarers inducted and passed out from all the parties to desired outcomes?
A. No
Q 5. Will revisiting Articles e.g. Article II and VI help?
A. Old Articles need revisiting
Q 6 Is there need to clarify definitions or introduce new
A. Extremely important to redo definitioons or introduce new ones e.g. industrial persons, SID
Q 7. Should STCW prescribe national provisions re-entry level education, e.g. 12 years of science education for trainee as first nautical officer engineer and lesser for NCV, rating etc. A. Yes
Q 8. Is qualifying sea service adequately described e.g Reg II/1, III/1
A. No
Q 9. Should there be any remission for simulator high-tech training going forward
A. Limited simulation remission
Q 10. Is there a need to revisit GT, kW thresholds
A. Yes
Q 11. Are medical fitness standards adequate
A. No
Q 12. Is there need to include seafarer wellbeing in basic courses
A. Yes
Q 13. Should polar code, IGF code etc be extra modular courses for endorsement or included in competency tables of Ch II, III, V, VI
A. Should be endorsement route
Q 14. Watch keeping chapter needs a new para in view of Autonomous shipping
A. Yes
Q 15. The alternative certification chapter has not really been of any use
A. Yes
Q16. Elements of Code B need to be transferred to Code A
A. Yes
Q17. Code B should be deleted or new text included regarding guidance on career progression, mental health, yoga, MLC,
A. Yes
Q18. Should there be a mandate to let STCW be corrected in real-time as technology is progressing very fast?
A. Yes
Q19. Is there a need to evaluate Reg I/7 re recommunication of information to reflect how parties are giving full and final effect to STCW
A. Strengthen regulation I/7
Q 20. Is recognition of CoC CoP an issue such as in exporting approvals to outside the party / Aministration limits
A. Yes, it is an issue
Q 21. Is CPD a better option than revalidation
A. CPD is n better option
Q 22. Are model courses only guidance to those who wish to use them yes or no, comment if any…..
A. Yes
Q 23. Is training approval uniform in all parties’ Administration jurisdiction
A. No
Q 24. Should there be provision for cancellation of training approval that is universally accepted based on violation prescribed in Code A
A. Use of cancellation subject to violation analysis will be good to go
Q 25 Should there be a new three part technology course for ratings, officers engineers, and Master chief engineer
A. Yes
Q 26. Is there need to include private Yachts greater than 24m into STCW requirements
A. Yes
Q 27. How to deal with small vessel engineers’ qualification
A. By way of chapter III/3,3 &5
Q 28. Besides NCV is there need for categorisation of waters
A. Yes
Q29. Is there a demand for revisiting certificate of service or recognising naval, fishing service for STCW CERTIFICATION
A. Yes
Q 30. Is high cost of training seafarer a concern for owner operator or individual
A. Yes
Q 31. Link between STCW and SMD needs to be established
A. Yes
Q 32. Are trainee berths for mandatory minimum sea service an issue to resolve
A. Yes
Q. 33 Should Recognition of certificate as prescribed be Mutual?
A. Yes
ANALYSIS suggests:
Out of 527 responses suggests significant number of saling staff & 100 Masters, including NRI, general average and experience 35 years,
59% favour new STCW, 63 change of Articles will help, 45% replied asking to revisit definitions, including GT kW thresholds; 31 say STCW is not being implemented uniformly, 93% have mixed feeling in success of present STCW, 47% observe require change in entry level education qualifications for first CoC CoP FG, NCV, however 76% believe qualifying seaservice is adequately defined, 55% favour limited sea time remission for simulator training, 20% find STCW medical standards inadequate; 93% favour inclusion of instructions in well being like Yoga in PSSR, 51% wish Polar code, IGF code etc training to take endorsement route, 86% wish new provision in watch keep for autonomous shipping, 39% think STCW SMD should be linked, 89% believe trainee berths is an issue,. Many observe Ch VII has not been useful re Alternative certification. Significant number of respondants want Code B to beco0me smaller crisper and some elements transferred to Code A, Also, that STCW needs provision for real time changes due to galloping technology such as alternative fuel safety, 52% believe CPD is better optiuon to revalidation, 58% believe IMO model courses are not mandatory, 46% believe STCW training is not uniform globally, 76 % would like cancellation of approved training for repeated violations, 73% want new tech course added in Ch VI for all levels, 57% observe that large private yachts should be included in STCW, while small engine course should be included in CHIII/3,4 &5, 52% answer that there is demand for Certificate ofr service, 49% observe high cost of STCW training;. Almost all have responded that certificate recognition should be mutual.
Marex Media
The Author
Capt SV Subhedar
Former President, ICCSA