THE SEA-TIME AND TRAINING DEBATE

Captain Michael Lloyd, RD**, MNM, CMMar, FNI, MN.

What?

 Several months ago, last year, the director of the Merchant Navy Training Board (MNTB) announced their intention of reducing the sea-time requirement by one month and substitute a training course on simulators.

This came as a surprise for the professional organisations, as they had never been consulted on this most important matter. 

Through the various inquiries starting from this announcement, a curious story emerged concerning the MNTB, The Chamber of Shipping, (CoS), the Maritime Coastguard Agency, (MCA), and, to a certain extent, an organisation called Maritime UK which claims to represent the whole of our maritime Industry.

Most of the characters involved from these organisations have never been to sea and have little or no knowledge of the requirements and demands that seagoing places on those who man the ships, or the qualities and training required for the seagoing profession.

 Who?

 The Maritime Coast Guard (MCA).

 The MCA is now headed by a business executive whose previous career had nothing to do with the sea. His formative years were spent in the house building industry and in the health service. With only two years in his current position, he knows very little of the sea or the training requirements and therefore is reliant on advice. The other three senior posts in the MCA are also held by those who have no experience of seagoing.

The new Senior Examiner of Masters and Mates only has less than one year as a relief master on a ferry before assuming his post.

The new head of the Marine Accident Investigation Branch is a retired Captain of the Royal Navy. Unfortunately, the civil service does not understand the distinction between warships and merchant ships, and the distinctive difference in the working environments of each service.

 Instead of consulting the expertise of the professional organisations, the Chief Executive of the MCA relies on those senior personnel around him who are, through their lack of knowledge and experience, unable to provide the advice required.

The recruitment of Royal Naval Officers in preference to Merchant Naval Officers is another relatively recent development. In addition to the head of the Marine Accident Investigation Board, the Chamber of Shipping, until recently, had an ex-Royal Naval senior officer, as did the MCA and does the Merchant Navy Welfare Board. The Secretary-General of the International Federation of Ship Masters is ex-Royal Navy, and he doesn’t even have a Master Mariners certificate. Surely between senior officers of the MN and those from the industry ashore, we could have provided personnel of similar abilities? Perhaps these organisations would like to advise us why these positions were never advertised in Nautilus International Telegraph, which is read by most Merchant Navy officers?

 The Merchant Navy Training Board (MNTB).

 The MNTB is a misnomer. It functions directly under the auspices of the CoS and acts as the ship owners/managers recruitment agency. This is headed by a Director with no seagoing experience.

Once the cadets are recruited, they are distributed amongst various companies or to cadet training companies, who then appoint them to ships. Over the years, has had little care or concern with their training received and the conditions under which they are employed resulting in several distressing stories from some of these cadets. These include cadets being appointed to foreign flag ships where they are the solitary British person and unable to speak the language in common use onboard.

There are questions about recruitment which need to be answered. Who interviews these cadets and decides who is suited to a seagoing career? Do those making the selection have seagoing experience? The large wastage rate shows that many being recruited are not suited for or have not been given a true picture of the life they would live at sea. Possibly the MNTB is more interested in filling the quota rather than recruiting the right type of cadets who have the indications of leadership ability and resilience that they will need to become a successful officer in the MN. If you have not been to sea, how do you know what qualities are required?

There is no advice to cadets that they could be on foreign flag ships where their human rights will entirely depend on the country of registry and where any accidents or incidents, they are involved in will be the responsibility of the flag state to investigate or not, as too often happens. 

The Board of the MNTB comprises seafarer’s representatives, from which group all master mariners or serving seafarers have been successfully removed and now comprises union officials with no seagoing experience except one junior officer. These officials of the Unions do what they are instructed to do by their respective heads. 

The next group are the nautical college representatives followed by the owners/commercial training company representatives. There are no marine professional representatives.

The Chamber of Shipping (CoS)

Forget the coats of arms; the CoS is essentially a wealthy trade union for the shipping and management companies and naturally, as a union, places the expectations and interests of these companies ahead of all else. This, of course, includes saving money where possible for their members.

If we can consider that the Merchant Navy is the people, not the ships, then the CoS have little to do with the Merchant Navy except that over the years they have been successful in assisting in severely reducing the sea-time required and the removal of British Masters, Officers, and crews from British Flag vessels.

In over 60 years in this industry, the only actions I have seen undertaken by this organisation for the benefit of those training at sea were by-products of actions taken for the benefit of its members. The crocodile tears over training now being produced seem a little amiss.

 Maritime UK.

 This new organisation claims to represent the entire maritime industry in the UK. Somehow, they forgot to include any nautical professional organisation.

Nautilus UK is a member, however as we have stated, they represent only those who have joined this organisation. Their officials who sit on the Board have little or no marine professional qualifications or experience. There are very few, if any, Master Mariners or Chief Engineers included on the Board of Maritime UK.

Maritime UK is only included as they published a Seafarer Cadet Review produced by a working group with, again, none having any sea-going experience or nautical professional qualification. It must be a coincidence that they published this review at the same time the MCA consultation of the sea-time proposal is taking place. The CoS is a leading member of this organisation.

 Why?

 The proposal is that the sea-time requirement for deck cadets be reduced by one month and a short simulator course would replace this. There is a provision that this reduction could increase to two months.

 This proposal came from the MNTB; however, such a drastic proposition could not have originated from the Director of the MNTB, as this is far above the director’s pay grade. The approval for it came from someone or a group within the CoS. The Chief Executive of the Chamber when this occurred was ex Royal Navy. It is difficult to believe that an ex Royal Navy officer would have sanctioned this or that in the Royal Navy, he would ever have proposed a reduction of sea-time training.

Those who made this decision approved the Director of the MNTB to expedite this reduction. First, the MNTB Board approval had to be obtained. Easy considering the absence of any professional seafarers’ representation.

The plan seemed to be without a problem. Infer that the initiative for reducing sea-time came from the MNTB. The CoS would support this and it would be placed before the MCA. The MCA would support this and they would place it before the IMO. Seems simple, doesn’t it? Note that there is no mention of simulator training, for at that stage the plan had nothing to do with training, it was to reduce the sea-time to save costs to its members.

However, there were stirrings of dissent. Nautilus International stated they had no previous advice of this during the internal MNTB discussion period and at the vote, they opposed this but others outvoted them on the Board. At this time, a well-researched dissertation was being circulated, now referred to as ‘The Kyle Report’. This, amongst many other points, presented the only and far-reaching research into the views of the seafarers and it is where the figure of 78% of those opposed to any further reduction in sea-time came from. 

Regardless, these people pressed ahead. Except that now simulator training suddenly appeared to appease those who were opposed to the sea time reduction.

The Nautical College representatives suggested the pill could be sweetened by adding simulator training, instead of sea-time. It was now sold as an organisation wanting to enhance cadet training by adding simulator training to a reduced sea-time. ‘we are only doing this to improve training.’ This was rushed through and presented to the MCA. 

At this stage, there had been no consultation with the marine professional organisations or the seafarers. One would have thought that the CEO of the MCA would have considered the proposal carefully, which would have shown him many points missing from it. 

In addition, if he had known the ways of the industry, he would have asked a few more questions before sending this to the International Maritime Organisation (IMO), as a done deal. He chose not to do so and advised the IMO of the MCA intentions. One must wonder at the relationship between the CoS, a private organisation and the MCA that is a government agency. The same accord granted to the CoS is not available to other marine organisations.

The title MNTB sounds as if it is an approved government department. Not so, it is a private organisation funded by the CoS. That gives them exemption from having to react to any request for disclosure of documents relating to this subject.

The Board refuses to release minutes of their meetings, even to the Merchant Navy that they claim to represent. There is no requirement to declare any commercial or financial interests. That would have eliminated the college representatives and training companies from this debate.

With the proposal now in the public eye, the opposition grew, much to the surprise of those who had a part in this. The opposition to this was for various reasons, but not because of the use of simulators. Indeed, simulator training as an additional enhancement of bridge watch-keeping is welcomed by all professionals.

One reason to oppose this reduction was the fact that there was a naïve assumption by these non-seafarers that sea-time was to be spent standing on a bridge, keeping watch. 

Watch-keeping is of prime importance and, when crossing the oceans, occasionally can be monotonous and with seemingly, to those not familiar with seagoing, little training is involved, but ships are not all the same. As we know, every day is different, especially when considering weather. Then there is the multitude of other aspects to seagoing. Cargo, port, anchors, maintenance, safety, drills, crew, paperwork, study, personnel, and leadership are just a few, none of which are available in a simulator. 

In addition, the plan was without the detail of how it was to be implemented. How were the Cadets going to be trained in the simulator? How were the standards of instruction to be coordinated throughout all the colleges? What class of certification and experience should the instructors have? How many students in a class? What examination was to be introduced to ensure that the cadet taking the simulator course has passed and deserves to have one month off his sea-time?

 What do we mean about simulator time? If we take a one-week course, then this is 5 days. less if we take off the introduction time at the start of the course and the examination at the end and the usual early Friday release. Allowing for the 0900 start, tea break at 1100, luncheon at 1300, coffee at 1500 and finish at 1700, that allows the student 6 hours a day. But that is if he/she is the only student. As there are not enough simulators or instructors for such intensive instruction, the chances are that there will be several students on each course. It could therefore well be that each student will only receive 1 hour of personal instruction per day. That makes 5 hours over the week. Can anyone argue that 5 instruction hours in a simulator is worth 1 month’s sea-time?

Next, there was no proper consultation with all the stakeholders before progressing to the IMO. It is quite bizarre that a project is not subject to consultation until after it has been presented as completed to the IMO! Equally bizarre is the fact that those who never have been to sea and therefore cannot possibly understand what training is required, caused all of this. 

To undertake consultation with the Cadets but not the Captains is, if nothing else, insulting to all MN officers. I wonder if the Royal Navy or other services consult their new trainees as to what kind of training they want before the trainees fully understand the reason for the training?

 Then there is the legality of what the MCA has done. It should be noted that the IMO circular (STCW.2-Circ.92) appears to have not been withdrawn by the UK Government although the statements contained within that communication are false, as the simulator training instead of sea-time has not been approved in any form applicable to Certificates of Competency. In fact, the Dutch example, now repeatedly quoted by those advocating a reduction in sea-time, is not recognised by the IMO, EMSA, and other responsible bodies.

 In the MCA document submitted to the IMO, they showed that, at the time that the communication was issued, the MCA had received evidence to support the effectiveness of the courses that they have approved. This is an untruth, as of the date of this letter, it is understood that the course has yet to be run as a pilot or otherwise, and at the time, no college had been authorised to run the course. So now, we seem to have the CoS misleading the MCA who misled the IMO.

We must also consider the history of the Chamber of Shipping. In a few decades, we have gone from serving in a well-managed and trained Merchant Navy where our qualifications were well respected. to where we are today. We went from 4 years sea-time to three. Then to two and then one and these people within the administration of this organisation, who have no concern for our profession or the qualifications we work hard to achieve, now want to reduce this even further and with the possibility of devaluing our certification in the international employment market. Worse, we know this will not be the end. 

This will also spread to the engineer cadets, then become two months reduction. Then what? Six months? How about no external examinations, instead let the colleges examine the candidates? Where do we draw the line? 

One of the strange reasons given by the MNTB was that there were many Cadets with one month of sea time left and unable to get berths to complete this. It is an absurd argument as, if the sea-time was reduced to 11 months, then they would still say that there are cadets with only one month left and could carry on with this statement regardless of how the sea-time was reduced. Of course, the bringing together of the marine organisations and charities to build or convert a ship for training, that we, the nautical professionals, have been advocating for many years, escapes them.

Another reason was that, in several cases, the onboard training was of a poor standard. So, what has changed? I am sure that in all professions those doing on-the-job training are not all good at what they do, but that is not unusual. It does not mean you abandon practical training for theoretical, especially when the colleges have all but given up practical seamanship training. We are not training cadets to stand on bridges or wandering around in uniform with checklists. The title of Seaman Officers requires occasional mundane tasks and getting their hands dirty. Something those who conceived this proposal may not have experience of.

It is the shipowners who seem to have sanctioned this plan, that are the ones who have reduced their manning to such levels that to expect tired officers, who are well over their official rate of legal hours or what is safe, to be too concerned about training, or whether a cadet is being used as ‘cheap labour. When there is no one else, and that happens frequently in modern shipping, then the cadets have to be used to the best advantage of the operation of the ship, rather than to the best advantage of the cadet.

We were complaining about cheap labour sixty-five years ago. But working with the crew, doing the manual labour alongside officer duties was the finest training we could have. After all, the Merchant Navy had pride in never giving an order to the crew that you could not undertake yourself. I was taught that phrase on my training ship and it applies equally today as it did then.

 The answer is not in our hands, it is in the shipowners. How about a training bonus for those officers engaged in training? A training course for trainers? How about manning their ships properly for a change? Joint pressure of us all on Government to contribute to the training costs would enable the colleges to provide longer and better pre-sea training with seamanship again a central part. All this would contribute to improving training, but, to once again blame those at sea, is disgraceful.

In another bizarre twist, the MCA announced that there would be a consultation.

Consultations are inevitably carried out before proposals are accepted and acted on, not after! Maybe the CEO of the MCA realised he may have been misguided by the CoS, stating that a full consultation had been carried out when it was becoming increasingly obvious it had not. Interestingly, the MCA did a survey conducted in the winter of 2019, but this has yet to be published. Could it be that the findings were not to their satisfaction?

Regardless, this consultation is being rushed through in an unseemly fashion, with no doubt the outcome already decided. After all, are the MCA and their friends in the CoS going to admit they were wrong?

The spin has already started, being that we, in the nautical professions, are out of touch with modern training. We don’t understand simulators, we refuse to modernise, we don’t want to accept new technology. Strange, isn’t it, how we have had to adapt at sea to technology more than they have in the offices ashore? How we have continuously accepted new equipment in our engine-rooms and on our bridges with no prior training, how we have to struggle to maintain our ships with manning reduced to such that we cannot comply with the legal requirement for watch-keeping and fatigue. I could go on but those who know what is happening at sea understand.

What is needed is for the MCA to withdraw the proposal from the IMO and together with all the interested parties, sit down and have a proper consultation on training over the next year. instead of rushing a thoughtless proposal through with the results of any consultation already decided on.

Our cadets should realise that we are supporting them and their future, which is part of our duty. International qualifications awarded in different countries are accorded respect, dependent on the reputation of the training required. Without respected qualifications, where will they be? While it is interesting to know their views, the nautical professions know what is required to ensure we have capable officers for the future. No profession can allow the trainees to dictate how they are to be trained and the MNTB must recognise this.

Whatever happens, the MNTB must change. We must follow the cadets’ progress throughout their training and hold into account those ships and companies where this is compromised. We cannot continue to just throw them at commercial training companies with dubious records of care. We must advise them and their parents of the risks that some flag states pose to them regarding their human and civil rights, their well-being on board, the due process of justice if required, and following Clause 94 of the Law of the sea stating their responsibility to our cadets.

The MNTB seafarers representation must be changed from the unions to the professional organisations. The Unions only represent their members and have no professional representation whereas the organisations such as the Honourable Company of Master Mariners and the Nautical Institute, with their many years of experience in dealing with the training of cadets and their accumulated professional knowledge can offer far more to the MNTB than the Unions.

 The marine professional organisations and senior officers of the MN are showing their responsibility by drawing the line in the sand at one year’s sea-time and protesting about how these people with no knowledge of our profession or seafaring are trying to force proposals through as if we and our opinions and experience do not exist. 

The MNTB in its present form is not fit for purpose and cannot be allowed to continue. It should be independent of the influence of the CoS and have professional seagoing representation instead of the unions on its board. The board must be transparent in its deliberations with a declaration of financial interests. It must ensure that the welfare of the cadets while under their jurisdiction is part of their remit and the training companies have no part in the decisive process.

 Hopefully, this further reduction of sea-time debacle will bring about a change in the CoS's attitude and the MCA towards the nautical professions and those who go to sea for a career.

It is a ridiculous situation where we have so many organisations with those in senior positions, now directly interfering in our nautical professions, having no nautical qualifications or understanding of those who go to sea and the ways and means by which we fulfil our professional obligations.

 A final point is, who is paying for all this? The consultations, then the pilot schemes, and any incidental expenses gathered along the way. It would seem that as it all emanated from the CoS, they should pick up the tab and not from any training budget either.

Conclusion

Because of this affair, there was the recognition that the nautical professionals were now being completely ignored by the decision-making organisations that are increasingly staffed and led by those unfamiliar with seagoing and the many aspects that affect those at sea.

From this understanding, the Maritime Professional Council has been formed bringing all the professional organisations together to provide a unified voice of all the maritime professional organisations enhancing their ability to provide professional advice to any who require this. This is to be launched on HQS Wellington on the 3rd of September. Hopefully, this voice will, at last, be welcomed and listened to.

Let us hope that common sense will prevail and this proposal will be withdrawn from the IMO, plans for a pilot scheme scrapped and we can all sit down together and discuss the overall training of our Cadets and hopefully the possibility of a much-needed training ship.

This is not intended as a diatribe against those working in these organisations. Many of them earnestly believe that they are acting in the best interests of the industry and those at sea. But, while welcoming help in areas relating to our profession and a willingness to listen to advice, this direct interference by people with no nautical professional qualifications or knowledge of the ways of the sea must stop.

 The regard with which a profession is held governs the respect it is accorded. That regard should not be just for the present. It is for the recognition of the service rendered to the nation in the past, the efforts of the present to ensure the endurance of the profession, and the concern for the future generations to be properly prepared to take their place on the sea.

We cannot force these shore driven organisations to respect the Merchant Navy, but we can refuse to be disrespected.