Is there to be a wholesale environmental disaster on our beautiful shores or pristine reefs before someone recognises that the regulators GOT IT WRONG!...
...The eligibility standards of engineer officer certificates of competency must not be relaxed to meet industry pressures lest we sew the seeds that will one day be reaped at a huge environmental cost to all Australians.
The integrity of Australian engineer officer certificates of competency must be upheld so that the Australian shipping industry continues to flourish and go about its business in a clean and efficient manner that the Australian public can be proud of.
The sea time accrued by engine room AB’s, IR’s and CIR’s cannot be recognised as eligible sea service for an engineer certificate of competency because they have not had the training or exposure to watchkeeping duties and maintenance roles that is required. These persons do not start, maintain or repair propulsion or auxiliary machinery and systems on ships and have an extremely limited knowledge of them at best...”
John Hartree’s submission included:- “....I believe your proposed amendments will de-value a certificate I have worked very hard to achieve. I needed to have completed a approved 4 year trade with at least 9 months heavy fitting approved by the Engineering Examiner. I was then required to sit various examinations and sea qualifying periods before attending oral examinations. After many years I finally achieved an Engineering Motor Class1 Certificate of Competency which is recognized Internationally and, because of our high Australian standards, well respected. In your attempt to streamline career pathways you have lowered qualifying times and entrance requirements therefore you have in my view dropped standards to such a level that safety standards and the international respect and recognition of my Australian Engineering Certificate are in jeopardy. I have no problem with a career pathway into Marine Engineering and I believe it is a good thing provided it ensures that standards are not reduced. Unfortunately your draft makes changes to the current regulations allowing entrants to obtain certificates without sound engineering experience and reduced qualifying periods. This is unsafe in my opinion, it astounds me how an IR ,AB Engine , or CIR can possibly have access to a Watchkeepers certificate without meeting either academic-entry or the skills obtained by having a trade. On the other hand a Class 3 Engineer with hands on maintenance experience should be able to be assessed by the Engineer Examiner to determine his or her suitability for trade entry to Engineer Watchkeepers....
...The Australian Institute of Marine and Power Engineers represents the interests of Marine Engineers. I am certain they would be able to assist in achieving a MO3 (7) that is safe and acceptable , I am disappointed that previous agreements between the AIMPE and AMSA re the MO3(7) have not been honoured and our voice via the AIMPE has been ignored....”
Peter Glenn Anderson’s submission included:- “
....Safety is of paramount importance on board ship and inexperienced people often find out the hard way, this is why our levels of qualifications are specific to the tasks required. Degrading these qualifications is fraught with danger, not only for those individuals but also to myself... ...I was in attendance at the recent MO3 consultation forum at Fremantle. It was explained the reasons behind the new proposals - better career path and faster transition to higher certificates to improve the number of people employed in the industry. Yes it does provide this, but what is the point, if those qualifications are de-valued? STCW requirements are the minimum standard, why are we moving towards the lowest standard? As I understand it, the recent 2006 Manila Convention was born about by the likes of Iran. It is well documented the shipping disasters that have occurred due to poor training, now they want to lower the standards again. The chances of environmental impact will be greatly increased.... ...I agree there should be a career path to seagoing qualifications, but this is definitely not the right model. The current MO3-6 can be tweaked, but fundamentally is a fair and honest approach to the attainment of Certificates of Competency. The MO3-7 shortcuts and leapfrogs much of the current legislation, which may produce more Engineers but how useful will they be?...”
A New Zealand – based member Mark Sidebotham’s submission was so good we were
tempted to print the lot of it, but settled for this much. It included the following:- “.... I fully endorse the stance of my professional and industrial organisation, AIMPE. They have the time and the expertise to read and decipher the legalistic language that regulations are always couched in. Engineers are good at creating, operating, repairing and maintaining machinery, not reading legal text, and so it is important for us to have such an organisation to protect us from political chicanery such as this document before us now. Please excuse me for not quoting the clause, the subclause and the paragraph of each item I wish to submit about but I’m an engineer and not a lawyer.
Actually, you can save a lot of time and effort reading my letter in order to find out what I think, by simply On Watch March 2012 page 13
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