A high priority issue at IMO is workload, fatigue and manning levels. The Nautilus strategy has been two pronged. A top down approach to establish manning levels that match operational requirements and a bottom up approach that regulates the hours of work and rest. We have been successful over a number of years in revising the IMO Principles of Minimum Safe Manning as well as the SOLAS Convention, and the ISM Code to adopt a transparent methodology for establishing manning levels that includes a task analysis that takes into account the workload required to operate a specific ship in a specific trade as a condition for the issuance of a Safe Manning Document. On the hours of work and rest the STCW Code now requires an average of 11 hours’ rest per day. But, poor implementation of good regulations is a persistent problem at IMO. The new regulations have only recently come into force, and our task now shifts to the means of implementing and enforcing the new requirements.
The key to effective implementation of IMO regulations by member governments are transparency and port State control. We will be working at IMO to provide a system to check that manning levels are established in a transparent manner including documentation that can be monitored and enforced by port State control. Members of the Nautilus Federation should foster relations with their port State control and work closely with them on issues of manning and fatigue of seafarers.
The ship owners are now trying to shift the focus from addressing the fatigue issue through appropriate manning levels to one of education and training in the management of limited human resources in order to avoid fatigue. This shifts the responsibility for fatigue from the ship owner to the master or seafarer for the consequences of fatigue related accidents. IMO is now engaged in a two-year program to revise the guidelines on fatigue to one that has its primary focus on fatigue as a management problem rather than a resource problem. Nautilus will be intervening and submitting position papers to IMO through the ITF and IFSMA to maintain the obvious linkage between workload, fatigue and manning levels.
Another issue of importance at IMO is e-navigation and the effect of advanced technology on the future role of seafarers. E-navigation has the potential to change the role of the master and officers aboard ships as port and coastal States implement shore based monitoring and control systems that are envisioned as being port, coastal and transoceanic in scope. Technology is not good or bad. It can have both positive and negative consequences for our profession and society as a whole. But, it does create change and uncertainty as it destabilizes existing systems.
The questions facing the Nautilus Federation are:
• Is E Navigation an aid to seafarers or a replacement of them?
• Will advanced technology deskill and diminish the role of traditional maritime professionals? Or will it upgrade our professional role as tasks take on more technical complexity?
• Will it replace conventional seafarers with minimally manned ships crewed with only a few technicians monitoring systems? Or will it eventually lead to unmanned drone ships?
These scenarios are now on the table and currently being discussed. There are both advocates for drastic change and sceptics as to the reliability and risks in a technology driven system. The eventual role of e-navigation technology and the future role of seafarers aboard ships will be determined by policies made at the IMO.
The IMO is currently developing a strategic implementation plan for e-navigation. At this stage in the debate it is primarily aspirational and conceptual, and defining the problems rather than defining the architecture and regulations for a proposed system. The future role of seafarers within a technology driven system is consciously being avoided to steer clear of controversy. At some point regulating the systems operating parameters and defining the relative role of shipboard and shore based personnel, their responsibilities and training requirements, will become the subject of debate at IMO. At that point the Nautilus Federation will need to work with ITF and IFSMA to protect its member’s interests.
A similar possible threat to the traditional role of seafarers is the proposal to introduce a new designation into SOLAS of Industrial Personnel. This position originally intended for work on windfarms but extended to the whole of the energy sector. Industrial Personnel would be neither crew nor passenger with their training and safety regulations outside current requirements. Previous problems with the proliferation of riding gangs should make us wary of any such proposals.
A different form of unfair treatment for seafarers has been the attempts to introduce guidance on Maritime Security, more draconian than is required under the ISPS Code. We have been successful in having the proposed guidance returned to the working group to be redrafted in a more acceptable form to protect seafarer’s rights and although the work it is ongoing it should not impose greater restrictions on the seafarer than currently exist.
To achieve a lower EEDI most ships are reducing total engine power, in some cases, particularly with bulk carriers the reduced power is insufficient to ensure a safe manoeuvring speed in adverse conditions.