Posted: 31st August 2017 | Written by: Captain Adrian Croft
Part 5: Perspectives on Safety in Yachting
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Currently there is no regulatory requirement for any deck officer (including Master) following the attainment of their last CoC, to be formally re-assessed (post ECDIS certification) as to the level of their navigational skills at any time later in their career. As long as the deck officer sea time requirement is fulfilled at time of revalidation of CoC, the CoC Issuing State assumes that navigation skill sets are current.
Is this assumption correct?
If it is, why is it with other commercial transport licenses such as in aviation and passenger road transport, there is a requirement for a scheduled formal reassessment before revalidation of the license holder?
Imagine if an unscheduled ColRegs test (such as NaviRules) was untaken by a wide group of deck officers currently serving on yachts. How many would pass to ColRegs exam standards? Empirical studies have shown that 50% of watch keepers believe that poor application of ColRegs is caused by ignorance or wilful disregard of these Rules. Would it be surprising if around 50% of the test group would not pass this unscheduled ColRegs test to exam standards?
Does the yacht owning/operating management company require pre-employment/continued employment assessment in core navigation skill sets of a deck officer candidate?
One shipping company (Carnival Corporation) after the tragic foundering of the passenger ship Costa Concordia, built and now operates a safety training center with full bridge mission simulators and a Proficiency Training and Assessment program, which evaluates each of the corporation’s maritime officers annually. For continued company employment successful completion of this assessment program is mandatory, no matter where or when the CoC was issued.
The grounding of the Costa Concordia
They also recognized that it is increasingly challenging to maintain well trained and qualified ship crew, especially as new technologies are introduced, requiring additional special training which makes the task more formidable.
Does the yacht owning/management company have a fleet Safe Navigation Policy, with clear concise Regulations and Procedures? If not, would it not be prudent to do so?
As per EMSA summary review of marine accidents and casualties 2011-2015, in 2015 there were 2,198 casualties with ships of which over half were navigation related. (contact 18%, grounding/stranding 16%, collision 16%). Not surprisingly a large number of onboard fatalities /injuries (42%) are also correlated to a navigational casualty. Of the 161 ships lost, collision was the second most significant factor (43 cases), flooding/foundering being the first factor (49 cases).
Navigation causalities, despite a large range of technical, legislative, training and publications initiatives are still occurring on vessels that are almost exclusively in Class, employ deck officers holding valid STCW CoCs, with an operating company SMS in place ship and shore side.
Most navigation audits conducted onboard and in port as part of an SMS audit are, at best, a paper exercise, typically reviewing chart/publication updates, navigational records, navigational equipment, passage plans and compliance with company procedures.
According to a recent MAIB investigation report, navigation audits carried out when the vessel is in port are considered ineffective. The vessel in question had undertaken a company navigation audit when alongside shortly before becoming a navigation casualty. The audit failed to raise serious, embedded, poor navigation practices.
Lady Moura famously grounded off Port Canto marina in Cannes. A passage plan, if it was actually in place, was woefully ineffective as it clearly did not consider Under Keel Clearances.
What is Safe Navigation? Why is it important?
Navigation is a knowledge-based skill and it relies firmly on the human element, which is defined by the USCG as: “The human and organizational influences on maritime safety and system performance”.
Safe Navigation is the successful conclusion of a passage by a vessel from berth to berth (alongside or an anchor berth), without a navigational based incident or injury to the vessel, associated personnel and the marine environment. It demands the adoption of all statutory and advisory compliance related procedures and established best practices in force, to reduce navigational risks to the lowest level practically possible.
The main physical risks to Safe Navigation are:
Heavy Weather Damage
Best Navigation practice in action especially if radar(s) are also setup with corresponding parallel indexing lines, thereby verifying ship's track/position via two independent means. Also consider the use of Radar Overlay if available.
Losses due to a navigational incident or injury potentially consist of:
Criminal penalties due to negligence due to contraventions of navigation regulations
Civil penalties due to accident and pollution damage
Company vessel unable to trade (repair period or total constructive loss)
Company reputational loss with existing and potential charterers
Company reputational loss in the industry sector and the Public domain
Increased scrutiny by Flag Administration and Port State control Inspectors
Increased Insurance premiums for statutory insurance coverage requirements
Increased company legal and administrative costs
Best Navigation practice in action showing give way vessel clear compliance with ColReg Rules 5,7,8,15 & 16
TMSA (Tanker Management Self-Assessment), is the maritime industry’s only risk management system that recommends both internal and external navigational assessments to take place while a vessel is under way (from berth to berth). Vessels under this system are to be assessed within a period not to exceed 12 months by a suitably qualified specialist contractor. (Currently the Nautical Institute is the only body offering training courses and qualification as a Navigation Assessor.)
It is only when a vessel is underway that the implementation of all statutory and advisory compliance related procedures and established best practices governing safe navigation can be observed as being correctly implemented onboard. In this scenario, the bridge team is on stage in action, demonstrating their skill sets measured against industry compliance standards and best navigational practices.
Ideally (in yachting) compliance assessment standards should be extracted from SOLAS, STCW 95, MLC 2006, Bridge Procedures Guide and the UK MCA MSIs/MGNs, Passenger Yacht Code (PYC) and Large Yacht Code 3 (LY3).
Ideally best navigational practices should be extracted from latest recommendations found in MAIB reports, The Nautical Institute on Command, publications such as Collisions/Groundings and their Causes, and in particular the integration of ECDIS into the Navigation Bridge environment.
Ideally the Assessment system should be amended on the basis of revision to the adopted standards and individual Flag State requirements as well as new findings as more vessels are audited.
Navigation Assessment - Tangible Benefits
SMS requirements can be compared by shore side management to assessment findings
SMS on navigation amended and upgraded based on assessment findings
Provide an overall view of the level of safe navigation of the vessel
Improve safety in navigation onboard
Improve planning and execution of voyages
Highlight trends in navigation practices where shore side management intervention is required
Identify where further training and instruction for use of equipment onboard is required
Highlight good and bad aspects of onboard systems to include design implications and ergonomics
Provide a platform for a continuous improvement in navigational safety through added value in terms of learned competencies, fresh insights and new resources
Foster better cooperation and encourage continued improvement in professionalism of all concerned stakeholders. (Confirmation of Best Practices in action/Mentoring/Coaching as needed)
Are typically scheduled to take place with planned vessel movement
It is argued here that an annual Navigation Assessment by a trained and certified Navigation Assessor, when the vessel is underway, is a far more exhaustive, systematic and objective process, than a typical SMS dockside navigation audit will ever be.
Surely it would be in the interest of any yacht Underwriter/Yacht Operating Manager to endorse such a process, considering the cost in hiring a qualified specialist Assessor is a fraction of the yearly insurance premiums paid, or the loss incurred in a navigation casualty. Do we have to wait for our own tragic yacht navigation casualty, follow up investigation, published report (if ever released) to change industry mindsets for the better?
About the Author
Adrian Croft is an experienced seafarer having served as master on both private and commercial operated yachts, cruising extensively in the Mediterranean, USA East Coast, West Indies, South Pacific and Indian Ocean for over two decades before which, he served in his formative years as a deck officer on general cargo vessels and large passenger carrying tall ships.
Adrian currently holds a Marshall Islands Master Unlimited Tonnage CoC (Yachts-Passenger Yachts), MBA in Shipping & Logistics (issued with Merit) Middlesex University/Lloyds Maritime Academy, Certificate in Naval Architecture Lloyds Maritime Academy, Lead Auditor ISM Lloyds Register, Project Management Registered Practitioner Prince2®, and is certified as a Navigation Assessor. Adrian is also an elected council member of the Professional Yachting Association and the Nautical Institute. For fun he holds a FAA pilot's license for general aviation aircraft, helicopter, seaplane and glider.
Currently Adrian is actively looking for a new command or challenging shoreside position in the luxury yacht sector.