Standards of Training Certification and Watch-keeping Convention 1978 (STCW 78)

Proposed Amendments and Reforms in Present Approach to Training and Assessment

1. Mandate minimum ship board training berths in STCW convention. Owners can be incentivised to provide same by deducting a multiple of trainee accommodation volume from Gross Tonnage of the vessel: Ship board training is a necessity to make the seafarers job ready. It is also a STCW convention requirement. However, availability of such slots is a big challenge. Way forward is to mandate shipboard training slots under the convention. This would also improve supply of quality manpower to industry thus improving safety and environment protection.  With adequate supply of trained and qualified seafarers, their wages and in turn cost of operating the ships can also be controlled better. It would also stop poaching of trained manpower and creating a more level playing field. A multiple of trainees’ accommodation volume can be deducted from Gross tonnage of the vessel through suitable amendment in tonnage convention, thus reducing the Gross Tonnage of vessel and consequently port and canal dues of the ship in perpetuity. This would incentivise ship owners to provide more ship board training slots, which are otherwise seen as an added capital and recurring cost in ship operations.

• Place officer trainees as ratings to overcome ship board training slot challenge: If there are insufficient shipboard training slots, after three to four months exposure as officer trainees, deck cadets and engine trainees can be placed on ships in lieu of ratings, with tacit understanding with ratings unions. Conversion of such ratings to officers is possible if they are trained like officer cadets under a structured shipboard training program. 

• Longer shipboard training for marine engineers: 6 months shipboard training for engine trainees is too short. This needs to be augmented to minimum 12 months.

• More facilitative alternative certification regime: Before introduction of autonomous vessel, there is bound to be gradual reduction of manning on board vessel. With unmanned engine room and various control gadgets on bridge, the requirement for dedicated deck or engine officers to meet the safe manning requirements would be dispensed with.  Officers would be required to intervene only when there is malfunction in autonomous system. Officers holding dual certificate would be ideal to reduce manning without compromising the safety of the vessel. Accordingly there is a compelling need to make acquiring and progressing with dual or alternative certificate more facilitative to encourage more seafarers to opt for same.

• Training Record Book (TRB)  for shore training: All structured shipboard trading programs mandate TRB. Such TRB also needs to be mandated for approved shore-based training programs as well. This will help structure and harmonise acquiring the hands-on skills during pre-sea training.  Such training records can also be used by assessors during exit examination. Assessors can ask the candidates to demonstrate skills learnt randomly from claimed acquired skills, as recorded in their TRB.  This will keep the trainees and trainers imparting the hands-on skills on their toes. 

• Mandatory training & experience of trainers and assessors and requisite tools:  Training and assessment needs be conducted by credible trainers and assessors. Ideally, they should have at least some hands-on experiences in the subject being taught or assessed to make the competency training and assessment relevant and contemporary. Further there can be a mandatory structured training and various tools to continuously upgrade their skills. In addition, the trainers and assessors can be graded by students and peers to measure their performance, so that same can be improved upon.  Modern tool of training and assessment also need to be provided to trainers and assessors to make same realistic to their shipboard functions. Shipboard trainers also need to be imparted similar training and assessment related skills and provided with similar tool.

• Structured shipboard training for operational level officers: In most training programs, we do have requirement of structured shipboard training for cadets and junior engineers, before they are considered fit for operational level duties on board. There are no such requirements when an operational level officer is considered for promotion to management level.  Such a structured training and TRB needs to be mandated under convention to better prepare the officers to take on management level responsibilities. Those trained under TRB can also be given some sea time remissions to incentivise them to follow structured training. 

• Command course: There is a compelling need for a mandatory command course before an officer is promoted to take over as master or Chief Engineer. Buck stops at master or chief engineer in any crises. An officer due for command needs to be trained assessed on board the ship and ashore and  made competent to deal with all possible exigencies likely to be encountered at sea.

• Mental health related treatment to be included in first aid courses: In all existing first aid courses, seafarers are trained to handle issues related to visible injuries and illness. Mental health related contingencies amongst seafarers is now a major concern. Identification and dealing with mental health related concerns needs to be included in first aid courses at all levels. Seafarers also need to be trained to identify when they may be impacted by such crises and encouraged to seek help, rather than keep the concern to themselves.

1. Free access to IMO publications on line: This is not directly related to STCW but certainly a related issue to improve quality of training and certification. IMO publications are highly prized documents, be it online or in hard copies. Sale proceeds from IMO publications are used for part funding the technical cooperation for conducting IMO conventions related training for seafarers from developing and undeveloped part of the world. Key objective of IMO is safety security and environment protection.  These objectives and mitigation legislation are detailed in various publications of IMO. If same are made available free online and made readily accessible to all stake holders, IMO and its members are better placed to achieve the intended goals. However IMO can continue to use the collection from sale of hard copies to  part fund the technical cooperation. Shortfall in technical cooperation fund can be made good by slightly higher contribution by member states and through enhanced donations.

1. Member states like India and others similarly placed, can offer large number maritime trainers under IMO technical cooperation program: Member states need  to be more proactive in facilitating technical cooperation by offering the trainers to rest of the world under technical co-operation. This is not directly related to STCW amendments but would certainly help improve quality of training across the world. It would also attract better and younger seafarers to opt for teaching profession as the trainer would get an opportunity to reach out to the whole world.

1. Hands on skills mandated for some of the shore training programs may be allowed to be imparted on board ship in certain circumstances: For acquiring certain ship operations related competencies, seafarers need to acquire hands on skills, which are mainly obtained in work shops or in full mission simulators. For this the physical presence of trainees and trainers is required in right environment with appropriate equipment. When same is not practical due to unforeseen circumstances eg Covid like crises, same may be permitted to be imparted during shipboard training or using innovative digital training tools. Such flexibility needs to be built in the convention provisions.

1. Underpinning knowledge and related contact teaching may be imparted in  hybrid or online mode: Certain aspect of competency related   training for acquiring underpinning knowledge on different aspects of ship operations and equipment is traditionally imparted in chalk and talk class rooms. This aspect of training and most parts of revalidation and upgradation training can easily be imparted in hybrid or online mode to have better reach and reduce the cost of training.

1. Endorsement for vessels other than tankers: STCW convention prescribes minimum standards of competency. Such training and assessment is generic in nature. Incidents on oil/ chemical and gas tankers can cause serious loss of life, loss of property and may result in major environmental damage. That is why tanker endorsements are mandated in the convention for different categories of tankers.  There are major concerns wrt operational safety of other category of vessels as well due to the fact that seafarers otherwise certified may not be competent to discharge specialised functions required to be performed on ships other than tankers. Hence it is recommended that tankers like endorsement i.e. minimum service, short shore training and related simulator training followed by desired endorsement can be mandated in convention to safeguard operations of containers, bulk carriers, dredgers and offshore vessels etc.

1. Digital locker for certificate and document for seafarers: A soft copy of all relevant document required to be carried by seafarers’ need be maintained in digital data base, maintained by flag state, accessible to seafarer as well as to flag state and Port State for instant online verification purposes.

1. Personal Safety and Social responsibility (PSSR) course to include following: Environment, Social Responsibility, Governance (ESG), gender inclusion & sensitivity and mental health etc. need to be included in PSSR course.

1. More responsibility for companies to impart training and familiarise seafarers before placing them on board: STCW prescribes only minimum standards. Over a period, new design of vessels, equipment and regulations are likely to be introduced. Requirements to perform shipboard operation competently may warrant that the gap in the training requirements need to be identified and bridged.  This can be facilitated by familiarisation training ashore and on board. Employers may be held accountable if gaps are identified during ISM audit, PSC inspection or post a casualty investigation report.

1. Meeting of IMO convention obligations and related training: National legislation needs to be amended in line IMO mandate  to give it teeth. Maritime administration needs to consult all related Govt departments and other concerned agencies during various deliberation while development of IMO instruments. However, once an IMO member state has acceded to promulgations of IMO, mandated obligations need to be complied with by all concerned, by incorporating same in the statute of concerned agencies.  Responsibility of compliance should not be limited to maritime administration alone. Where required suitable training for compliance of relevant provisions may be imparted to officials of departments related to convention mandate. More often than not, agencies other than maritime administration are either not aware of such obligations or do not take the commitment given by the member state under conventions seriously.  Restricting shore leave of seafarers by immigration, not creating shore reception facilities by ports, inadequate International Maritime Dangerous Goods (IMDG)  code compliance by ports, wrong declaration of IMDG cargo by shippers /consignees and lack of emergency response preparedness and place of refuge by coastal states are few such examples, which can be mentioned.

1. Separate competency related examination  for Masters and  Chief Engineer from Chief Mate or Class 2 competency exams: Traditionally this was always so. However while drafting STCW 95 amendments, it was felt by experts that second in command should know everything what the master or Chief Engineer knows.   This was borrowed from aviation which requires that a co-pilot needs to be equally competent as pilot. It was argued that if Master or Chief Engineer is incapacitated at sea, second in command should bring the vessel back to port safely.  Member states played along and approved this line of thinking. However, in practice, over the centuries there has never been any reported incident when the vessel could not brought ashore safely by no 2 in command in such circumstances. Challenge with co-pilot approach is that a candidate after one year of sea service gets his Second Mates. After 18 months he / she appears for Mates. In other words after 2.5 years of service he or she is expected to learn everything, a person in command needs to know. The examiners are also expected to assess and certify such officers for command, albeit after 18 months of further sea service. It is obviously not a realistic expectation, either from examiners or from candidates. This approach has also resulted in longer post sea training (6 months) and two examinations for chief officers and second engineers (phase 1 and phase2).  This has also severally restricted the flow of Chief Officers and Second Engineers to the industry, causing serious manning challenges at management level.   This needs to be reversed.

• Competency requirements to remain contemporary: The STCW convention is amended after 15 to 20 years i.e. 1978 convention was amended in 1995 and then in 2010 and now probably in 2025. However, shipboard competency requirements change incrementally continuously.   The time for training and assessment is limited. Hence dated requirements need to give way to contemporary needs. Also, those who in system after passing their competency requirements need to be updated regularly. 5 yearly upgradation and revalidation is too long a gap. Hence a structured mechanism of continuous upgrading needs to be included in convention text to meet such compelling needs. 

• Use assessment as a tool to achieve relevant competency for seafarers: Typically, the training institutes teach what is asked in examination. Classic example is stress on celestial navigation in Mates examination in Indian Certificate of Competency (COC). Since the pass marks are also high, this shifts the whole focus of trainees as well institutes on navigation rather than stress on cargo work, which is the core function of Chief Officer. Hence, it is essential to ensure that due weightage is given to core contemporary competency related topics and relevant questions are asked in written and oral examinations so that trainers impart relevant training and seafarers passing the competency exams are fit for job.

• Application of acquired knowledge in real ship board environment is the key to achieving competency: Questions in written and oral assessment mostly ask the candidates to explain or describe.  Answers to such questions mainly expect candidates to reproduce the theory. What is more relevant is to achieve competency is application of acquired under pinning knowledge. Hence the questions need to be tweaked to pose real life problem solving and decision making required on ship. Questions should force the students to apply their mind, think standing on their feet and answer the questions.

• Fundamentals of convention and ship board practices need to imparted in training institute and tested in assessment:  Load line convention is nothing but assigning reserve buoyancy (freeboard) to a ship. Higher the risk of sinking, more is the reserve buoyancy. Hence in winter North Atlantic, where the weather is very bad, maximum freeboard is assigned i.e. the ship can load the least. Similarly, a ship having more compartments is less likely to sink as compared ship with lesser number of compartments. Hence tankers are permitted lesser reserve buoyancy or freeboard and can load more as compared to similar size dry cargo ships. Rather than stressing on details of the text, the genesis of the convention need to be explained so that comprehension is easier, and knowledge remains with students for ever. Also, application of knowledge on board becomes easier. Another example of imparting the basics of convention is limitation of liability convention, which limits the third-party liability of a ship owner. It essential for ship owner to insure his liabilities so in case of any untoward incident, the insurance company covers the liability and business goes on. This is possible only the if the liability is limited. If the liability is unlimited then such liability cannot be insured. Further larger the ship, more the damage it can cause and hence larger the liability limit. This is OK as large ships also earn more. In addition, over a period of time, due to inflation, costs related to mitigating the liabilities eg clean up and Wreck removal etc do go up and hence limits mentioned in the convention need to be revised periodically. Hence it is essential for seafarers to understand the underpinning reason behind each convention, code, resolution, performance standard and Govt order. Once the same is understood, it would never be forgotten.

• Imparting knowledge through case studies: Rather than just telling what to do and what not to do, it’s more useful if case studies related to various incidents covering all aspects of competency are shared in the classroom. Same can be discussed in detail with seafarers. The consequences,  such as loss of life, injuries, pollution, damage, delays, suspension and cancellation of certificates, criminal liabilities, loss of reputation etc all need to be discussed and debated thread bare in classroom so that seafarers are conveyed a clear impactful message regarding the importance of not only knowing their job but also being alert at all time and doing it well, failing which the consequences can be serious.

• Implementing proposed reforms: Some of the proposed reforms can be implemented only through the amendments in STCW convention provisions, whereas others can be initiated by member states themselves.  In any case, nothing stops a member state to go beyond convention requirements, if minimum prescribed convention provisions are met. There may be added cost for such enhanced requirements to the member state and ships under its flag. However, the dividends in terms larger trained quality manpower, more employment opportunities for member state seafarers, safer ships, better environment protection, less port state detentions and consequently much larger share of ships under its flag and bigger share in the global supply of seafarers, far outweigh the incurred costs.

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