On 1 February MNZ released a report on the key issues identified in the first stage of its qualifications and operational limits review (QOL Review). A summary of these issues is outlined below.
This information will be used to help direct the design of an improved qualifications and operational limits framework, along with other key inputs including international standards and maritime obligations.
The outcome will be relevant qualifications and appropriate operational limits that meet the needs of New Zealand’s commercial maritime industry &ndash: while ensuring the safety ofvessels, their crew, passengers and cargo, and protection of the marine environment.
Between July and November 2009, QOL Review Project Manager Bridget Carter and Principal Maritime Advisor John Mansell interviewed 434 representatives from the maritime community, asking them what works and doesn’t work with the current qualifications and associated operational limits, and how they could be improved. More than 1,150 comments were recorded and 30 written submissions were also received.
Bluff representatives of the maritime community interviewed by MNZ.
Back row: Dave Henigan (left), Bob Hawkless, Paul Pascoe, Graham
Denny, Dave Pollard (MNZ), John Mansell (MNZ).
Front row: Graham Anderson, Bridget Carter (MNZ), Warren Crighton.
"The free and frank views shared by so many people will help ensure the new framework is firmly anchored to the needs of New Zealand’s commercial maritime businesses," says Bridget.
"In addition to gaining a clear understanding of the business and operational requirements of the various industry sectors, the discussions provided MNZ with valuable insight into the environment in which certificates are obtained, how MNZ syllabuses are delivered, access to training, availability of funding, and consistency of standards in the current examination process."
The community engagement programme confirmed the breadth and diversity of maritime operations in New Zealand and highlighted a number of concerns with existing qualifications and operational limits. It also identified what is working well. There was strong support for maintaining the quality of New Zealand maritime qualifications to ensure they are recognised internationally. Most of the key issues relate to domestic qualifications (LLO, ILM, NZOW and NZOM) and vessels operating within coastal, inshore and enclosed limits.
"While many operators are happy with the operational limits they work within, there is an overwhelming demand from commercial fishermen for a return of a 100 nautical mile limit, to more closely align with commercial fisheries," says Bridget.
“We found that commercial operators are doing their best to comply with the rules and respect the need for them. However, it is apparent that there is a lot of misunderstanding or misinterpretation of maritime rules owing to their complexity and the way information is presented."
For people progressing up the career path or operators required to hold higher qualifications because of crewing requirements, the biggest operational issue is the need for, and ability to obtain, coastal sea time. The validity of sea time as a measure of competence was raised as an issue consistently across all industry sectors.
Following wider industry comment on these key issues received during February, MNZ is ready to commence detailed design work on the framework. It is intended that the first draft of the new framework and a proposed approach to the transition of existing qualifications to the new framework will be released for consultation later this year.
MNZ is planning a roadshow throughout October 2010, visiting all major ports and regions to present the proposal. Following this extensive industry consultation, the framework will be fine-tuned and the final proposal will be reviewed with representatives from each type of maritime operation. The new qualifications and operational limits framework is due to be delivered in March 2011.
Barriers to entry
Entry to the commercial maritime sector is constrained by the lack of recognition given to experience and skills gained in both the commercial and recreational sectors.
It is not easy to plan a career that spans multiple industry sectors and know from the outset what experience or qualifications will be required at each stage.
The current qualifications framework makes it difficult to transfer between sectors.
The current qualifications framework does not recognise a separate and specific "“inshore industry" or provide a career path for it.
Quality of qualifications must be retained.
Current qualifications and operational limits are focused on sea time rather than experience and competence.
Qualifications and syllabuses have not kept up to date with technology advances in engineering, navigation and communications.
There are problems with getting domestic and super yacht qualifications recognised overseas.
There is no appropriate qualification for small work boats operating in either very restricted or multiple areas.
The current link between distance offshore and level of engineer required is not appropriate, and is at a high cost to operators.
The engineering syllabus for MEC 4, MEC 5 and MEC 6 is out of date and not appropriate for smaller vessels and modern engines.
Endorsements should be used as a means of demonstrating competence for specific skills, experience and types of operation.
ILM is the core qualification at the heart of commercial operations in the industry in New Zealand, but does not provide sufficient competence for the higher-end privileges of the ILM qualification.
The current method of calculating sea time is open to abuse and does not ensure ‘quality sea time’ is obtained.
Coastal sea time is hard to get and is a barrier to obtaining the NZOM qualification, in particular when required for inshore operators.
There is a high demand for a 100 nautical mile fishing limit to be reintroduced to align more appropriately with fishing areas, for example the 200 metre contour.
The current 12 nautical mile inshore limit is based on the territorial limit and does not allow for practical transit routes between locations.
The inshore limit does not take into account increases in vessel speed and technological advances in navigation and engineering that make it possible to travel further from the coast and still be able to access a safe haven.
There is no flexibility to allow vessels to operate beyond the limits of their qualification for specified periods to suit certain fisheries or other activities.
Passenger/non-passenger and fishing operators wish to operate within the offshore limit to the extent of New Zealand’s exclusive economic zone (EEZ).
Any changes regarding revalidation must consider the impact, costs and benefits, and demonstrate that there is a safety benefit.
Syllabuses are out of date, too theoretical and do not reflect modern technology in engineering and navigation, for example chart plotters, GPS, computerised engines, modern outboard motors.
There is too much large merchant shipping influence on syllabuses for lower-grade qualifications.
There is a lot of repetition between the syllabus and courses for LLO, ILM and NZOW.
Training is repetitive and does not recognise prior learning.
Individuals are required to repeat training unnecessarily as they progress through different certificates. This makes training long and expensive.
People find it hard to get on training courses at suitable times owing to the limited number of courses.
Courses are believed to be unnecessarily long – to suit schools and government funding mechanisms rather than candidates.
There is limited uptake of unit standards owing to lack of understanding and misalignment of MNZ and NZQA qualifications.
Industry-specific training under Part 35
Although Part 35 is well regarded, it imposes management overheads on participating organisations.
There have been no regular audits of Part 35 by MNZ to ensure compliance and competence of trained candidates.
There is no practical component to the examination process and therefore candidates don’t have to demonstrate competence.
Qualifications and syllabuses have not kept up to date with new technology advances in engineering and navigation, and examinations reflect this.
Examination questions are sometimes theoretical and not relevant for domestic qualifications.
Application of STCW
The STCW basic safety training course, which requires full fire training with breathing apparatus, is excessive, expensive and provides no lasting benefit for operators of smaller vessels.
Communication on previous changes to qualifications and operational limits has not been effective or adequate.
Interaction between the maritime community and the MNZ Licensing Team is not always satisfactory.