Thirdly, should an incident occurr, such as environmental pollution, that can be attributed to a lack of training by a holder of a certificate under the proposed MO3(7), and who is under my responsibilty as Chief Engineer, then I can be held accountable by law and could face large fines or even gaol. This inturn compromises my abilty to ensure the needs of my family are met...”
MV “Tasmanian Achiever” Engineers’ submission included:- “....we have real concerns about some of the proposed changes to engineering eligibility. For existing AMSA ticketed engineers and engineer trainees the changes aren’t of real consequence. There is a reduction of three months in qualifying sea service between Watchkeeper and Class 2, and between Class 2 and Class 1 but as most of us rely on employer sponsorship to complete our college training these changes will be negiligible. Providing a pathway for Class 3 Engineers to gain higher certificates is a good change. Many of these engineers have significant experience and could make the transition to higher certificates.
Now retired but long serving AMSA Examiner of engineers Stephen Scriven wrote to Minister Albanese.
Te Hon. Anthony Albanese Federal Minister for Infrastructure & Transport Parliament House CANBERRA ACT 2600
Dear Sir,
NAVIGATION ACT - MARINE ORDERS PART 3 - SEAFARER CERTIFICATION PROPOSED AMENDMENTS
I do not appear to have received a reply to my letter of 27th January on this subject; a copy of which is attached.
It seems appropriate that I should also point out some further area of concern regarding these proposed amend- ments.
It would appear that AMSA will no longer approve or audit training courses for Cadets, or any other courses for the industry for that matter. Once again an abrogation of its responsibilities to maintain a safe and efficient Merchant Marine.
In fact, examination of the proposed requirements for certification in all areas shows a reduction in the qualify- ing sea service for admission to the appropriate examination. In these days advancing technology this seems a very irresponsible attitude.
A glaring omission is a certificate of competency for Electro-Technical Officers. Tis was recently required by the International Maritime Organisation (IMO) to which Australia is a signatory. Te increasing complexity of electrical equipment makes this a vital requirement.
Tis reduction in standards can only result in more navigational errors and machinery failures with resultant groundings and consequent pollution.
I look forward to your acknowledgement and considered reply to this correspondence.
Yours faithfully,
F.H.S.SCRIVEN
There are many more submissions from AIMPE members that I have not yet read, but these quotations are generally reflective of the tenor of Engineer’s concerns with the consultation-draft Marine Orders Part 3 (Issue 7) produced by AMSA’s policy division in breach of all the collaborative work done by AIMPE and the operations division of AMSA and the formal agreement on engineering concerns made 22 October 2009 with AIMPE by the AMSA CEO.
Henning Christiansen FEDERAL SECRETARY
On Watch March 2012 page 22
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