Australian flag, and a member of the Australian Institute of Marine and Power Engineers, I am without doubt, a stakeholder. ....
.... At 34 years of age I have a vested interest in both the present and future health and vitality of the Australian maritime industry.
I cannot emphasise enough how strongly I believe that the draft Marine Orders Part 3 (Issue 7) will be irrevocably damaging and have far reaching and irreversibly negative impact with respect to the training, qualifications, skills, quality and standard of marine engineers in Australia. In fact, there will not be an area of the maritime industry in Australia that is not negatively impacted in some way. It is not only the current holders of certificates that will be affected, but also future certificate holders, maritime Training Providers, Ship Managers and Owners, and the Australian public at large. Australia enjoys a reputation of being a provider of world class maritime engineering training, with AMSA Certificates of Competency being recognised as among the highest quality in the world, along with Australian marine engineers being sought after as among the best trained, best qualified, safest, most highly skilled and experienced, on the global market. All of this will be destroyed the instant that the draft Marine Orders Part 3 (Issue 7) as it presently stands, becomes law. The standard of Maritime Training will be compromised due to less stringent audit requirements. Existing certificate holder’s certificates will be rendered worthless overnight and will be dealing with a raft of poorly trained, poorly qualified, new entrants that for the most part did not have the academic or trade background suitable to enter the industry in the first place, and escaped through the cracks of an assessment system that simply is not as rigorous as it was previously. These new entrants will be a hazard to themselves, and others, and the increase of safety incidents will be monumental, potentially costing lives, damage to assets of ship owners, and potentially disastrous to the marine environment in terms of pollution incidents. In addition to this the standard and quality of maintenance work carried out may result in delays or shut downs of offshore construction, oil and gas production, port movements in the case of towage, and passengers in the case of ferries. This is simply unacceptable, and cannot be allowed to take place by the Australian Maritime Safety Authority. Is it not, after all the primary task of AMSA to promote safety and protect the environment? It is impossible this be fulfilled by reducing the training, qualifications, skills and experience of the maritime workforce, which is what MO Part 3 (Issue 7) as drafted does...”
Matt McIver’s submission included:- “
....AMSA must maintain its regulatory position on training and standards. The industry and self interest groups must not be allowed to self regulate. The requirement for a high standard must be the goal. AMSA must maintain the requirement for Oral Examinations for certificates of competancy. In Australia we have become complacent and take for granted the reliability of our ships which can only be credited to a high standed of training and competancy. Shipowners and managers in Australia take for granted the high level of vessel reliablity with little or no downtime. ..”
Kevin Sorensen’s submission included:- “....I do not believe a Cadet engineer can complete a watchkeeping engineering qualification in 12 months.
I
completed a cadetship in 3.5 years and I felt this was not enough to sufficiently give me the tools and education I required. I do not believe that a Rating deck hand is sufficient experience to complete an engineering watchkeeping qualification. Furthermore I do not believe that anyone who has not completed the highest level of high school education could sufficiently handle the part A section of a watchkeeping course. We would be setting them up to fail...”
Ian Brightmore’s submission included:- “
....As a serving Chief Engineer on board ‘blue water’ vessels, I am concerned that several of the proposed amendments to MO3 are guaranteed to lower the standard of training and hence competency of prospective Marine Engineers who are engaged and trained under the proposed amendments, as follows:
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Engineer Cadet training period reduced to 12 months from 36 months. (MO3/7) I do not believe that any student of Marine Engineering can properly absorb the vast amount of knowledge required in the multiple subject syllabus of Marine Engineering within a 12 month period. Students need to be able to ‘digest’ the information and tuition they are given if they are to be able to properly retain the knowledge they are given and then apply that knowledge once on board a vessel. Attempting to cram the syllabus into 12 months will lead to a poor quality learning experience for the individual and a greatly diminished effectiveness once assigned to a vessel as a result of inadequate training received. Reduction of Class 2 qualifying sea time from 24 to 21 months. (MO3/7)
I believe that qualifying sea time and practical experience are inextricably linked and therefore a reduction in On Watch March 2012 page 11
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