...The removal of the requirements of an Oral Exam and the insertion in its place of the wording Final Assessment is the most significantly worrying item in the draft. There must be a final filter where a competent and knowledgeable and approved assessor employed by AMSA exams a prospective holder of any certificate on his knowledge of safety principles, operational principles, engine operation and marine equipment maintenance. if there was any doubt as to the potential of what can go wrong when poorly qualified and managed people are let loose in the Maritime context look at the Macondo Disaster. Look at the complete and total breakdown of command and control in the emergency situation. Or read some of the Maritime incident reports. These are not made up...”


John Dyer wrote a letter to Minister Albanese which included:- “....I have over 50 years experience in the marine industry, both ashore initially in training as a fitter/turner and after that as a Marine Engineer.


I have personal experience during that time, with the various methods used to overcome the shortage of Marine Engineers, that the industry always seems to experience. The most remembered was that in the 1960’s, when the shortfall was overcome by allowing personnel with a heavy Trade Certificate (eg Fitter) to come away to sea for up to 2 years as a Junior Engineer, then to leave to get a Part A of the old 2nd Engineer Certificate, before returning. Other methods, eg traineeship, cadetship, have been more successful, but all methods to overcome skills shortages have one underlying dilemma in common, poaching of personnel by institutions outside the “blue water shipping” not prepared to bear the cost of training.


Just as drug cartels come up with more intuitive ways to smuggle drugs past authorities, we can now draw a parallel with ship owners finding a new way to reduce costs of training, by surreptitiously using AMSA to put forward un-debated new draft MO3 Regs that propose to shorten and reduce qualification and training times to overcome a massive demand in the offshore and support industries, which previously gained their personnel by poaching “blue water” personnel. That source of personnel is quickly drying up, as Australian manned ships decline in number and personnel retire due to age.


As a “hands on” Chief Engineer, I find the level of experience and training of new personnel these days frustrating, and these personnel have come from the current system that is far superior to that proposed by the draft MO3 Regs. The thought of having ex IRs as Engineering Watchkeepers sends shivers up my spine. Not to detail the poor education status of some IRs, but their duty of care, loyalty, dedication, ethical morals, concentration skills and overall ability leaves a lot to be desired. Their current work practices replicate very little Engineering Watchkeeeping duties, so unless the individual is exceptional, the average IR will be a liability as a Watchkeeper, not an asset as is perceived by these draft MO3 Regs.


I also find it repugnant for AMSA to suggest that experience as an Engine Room IR (no matter how good he is) is suitable experience over and above that of a Class 3 Engineer or approved Trade qualification. There are very few IRs that continually spend time in the Engine Room, and there are plenty who cannot or will not spend time in the Engine Room, ever. The Engine Room duties of an IR are limited to cleaning, washing, greasing, manual labour, assistant to Engineers and similar work, with virtually no regular machinery maintenance work performed nor any Engineering Watchkeeping duties performed. Conversely, however, the Trainee Engineer or Engineer Cadet participates heavily in Watchkeeping duties and machinery maintenance, as this will be his future work.


As more and more marine accidents are reported to AMSA, and later investigated by AMSA, the underlying factor in most accidents is noted as the lack of experience. That lack of experience maybe described as poor training, no training, too tired to think properly, inexperience, lack of support, poor information, etc, etc. Can you imagine if these draft MO3 Regs get up, what could happen? Within an Engineering complement of 4, there could possibly be only one Watchkeeper with experience, while the other 2 could be ex IRs, and have to continually call out the experienced Engineer or Chief Engineer. This could lead to a dangerous situation, or at best a frustrating situation, which could easily result in an accident or machinery failure or personnel injury.


AMSA should be raising the standards if anything, not reducing standards just because ship-owners want to reduced training costs. The current LTI (lost time injury) programs going around shipping circles for the last decade, has been very successful in reducing personnel injury, even if it has a carrot waving in the form of incentives or rewards to those involved. I fear these high qualities will soon be eroded and the industry will be back to the “bad old days”. A lot of causalities come from the inexperienced and young. I can immediately think of 3 examples where personnel were killed due to either inexperience or lack of knowledge, (Junior Eng on Iron Hunter asphyxiated with CO2; Cadet Eng on ASP tanker electrocuted; IR at night fell down grating on Spirit of Esperance). All these 3 deaths were either a direct or indirect result of lack of training or knowledge.


In conclusion, I would like to add that it is very poor insight on behalf of AMSA to immediately discard the previous Regs that AIMPE & AMSA had agreed to, and were in the final stages of conclusion. This was done without consultation or agreement, and shows how far away the industry has positioned itself from each other, and how political “safety” has become...”


On Watch March 2012 page 19


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