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(not an approved trade, or so I hope) but I’ve seen the welding and have to wonder about that. Some of them can bend a crowbar in a sandpit and pretty much all of them aren’t suitable to be marine engineers. If these gentlemen had mechanical or academic ability they would already have mechanical experience (which if plain sense would prevail the examiner could assess) or would have year 12 maths, physics and English, and could become engineers using the same path as anyone else. I’m not against seamen. Someone has to do their job, which is a labourer’s job. What I’m saying is: NO PREFERENTIAL ENTRY FOR ANYONE. Marine engineers are not labourers. It takes experience and education and if persons don’t have either they need to get one or the other before presenting themselves. This proposal is surely a political move: there’s no sense in it and it won’t create engineers with any sense in them either. Which we need, as anyone who has read this far should understand. To repeat: people’s lives are at stake......”


Brad Ready’s submission included:- “....Standards Reduction – Duration of training for Watchkeeper NO – Not 12 Months!!! Even you at AMSA have said that it needs at least 24 months! If that’s what you think then change the regulations to what you think, not what some other party is telling you to do! Having gone through this system myself I believe there is some “fat” which could be trimmed from the schedule, but to cut it down to 1/3 of the original time is NOT SAFE! The time should be held at 30 months. Further to this the sea time required for qualifying for a class 2 certificate should also be held at the 24months. I can only assume the push is on to reduce the time served for each certificate so that we can arrest the shortage of qualified engineers. However by spending less time in training is not the answer...”


Trevor Smith’s submission included:- “....The reduction in sea service requirements will ultimately result in a reduction in proficency standards. The current sea service requirements combined with the current oral examination results in world class standard of AMSA certified Marine Engineers...”


Allan Gibbons’ submission included:- “....The ... revalidation requirements contained within the MO3 draft states that for the purpose of revalidation “seagoing service” is required to be the same was required for the certificate where as the current system requires similar seagoing service, this means certificates will not be revalidated at the same level for people like myself who work on tugs...”


RTO-lecturer Simon Gould’s submission included:- “....The draft Marine Orders Part 3 will eventually affect all sea going personnel. By lowering the standards of entry, level of training, length of qualifying sea service, and the non auditing of cadet courses, the entire structure of Australian Maritime Qualifications will be lowered, and therefore SAFETY standards will be put at risk...”


Peter Paroz’s submission included:- “....A number of things appear to have been missed in the way Candidates are awarded certificates. Under the proposed MO3-V7, Candidates are now only required to be assessed for the award rather than being examined by way of Final Exam at College followed by an Oral Exam conducted by an Engineer with Class 1 or higher Certificate and AMSA Qualified to do so by the Principal Examiner of Engineers. Also missing is any references to Gas Turbine Certification. Gas Turbines are being used increasingly as a mode of marine propulsion. In the past some operators had Steam Certificates and others had Motor while in fact the Gas Turbine didn’t fit into either Steam or Motor streams. Perhaps an Endorsement on a current Certificate would be the correct answer. There is a marked increase in the number of high voltage (HV) propulsion plants going to sea. Does AMSA have a plan as to how this will be certified? Will it be a separate qualification or kept simple with an endorsement on a current certificate?...”


Garry Slabosz’s submission included:- “....I have been working on LNG Carriers for 12 years which are steam propulsion. MO3(7) will not allow me to revalidate my Chiefs Motor ticket while sailing on a steam propulsion Gas Carrier. Prior to working on Gas Carriers I worked in the BHP Bulk fleet for 10 years, which are Motor propulsion, and gained my Chiefs motor. If MO3(7) comes to fruition my Chiefs motor ticket will be deleted at time of revalidation. All my experience on Motor ships, study and college will have been wasted.


MO3(6) allows revalidation and is consistent with all other Flag states, especially with those who supply On Watch March 2012 page 15


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