MOSS on a roll
Safe Seas Clean Seas Issue 41, September 2012
Once signed off, the rules, advisory circulars and MNZ’s response to submissions made during the consultation round in June will be posted on MNZ’s website.
Planning for MOSS transition and implementation is well underway. This includes entry control into MOSS – for both operators and surveyors – audit, and also involves major changes to the way in which regulatory survey will be carried out under MOSS.
How MNZ plans to raise the standard and improve the consistency of survey was a major area of concern for submitters during the MOSS consultation. Survey consistency is something that MNZ is determined to get right.
All MOSS surveyors will be required to meet MOSS standards. MNZ will improve standards and consistency of survey by:
- implementing stronger entry control for surveyors into MOSS – including developing a competency framework that formally specifies the combination and level of knowledge, skills and behavior required
- working with surveyors to establish consistent interpretation and application of survey standards
- increasing MNZ’s support for and education of surveyors
- exiting poor surveyors from MOSS.
A key part of this work is developing the survey guidelines to help surveyors consistently interpret the standards set out in the Part 40-series maritime rules.
“Many of the rules are currently left open to interpretation and discretion – over 200 references to surveyor ‘discretion’ were identified when we started looking at this work,” says programme manager John Oldroyd. “Helping surveyors interpret these rules also puts a strain on MNZ resources, as surveyors rely heavily on support from the safety systems management team.”
The MOSS team has set up a survey working group, which includes a number of surveyors, to draw up these guidelines. “We see this as an important part of establishing and building a relationship with the surveying community and using their expertise to help improve standards and consistency,” says John.
A request for expressions of interest from surveyors received over 30 positive responses. “We’re delighted with this, as it shows the high level of investment the industry is prepared to put into developing the future state under MOSS.”
Two of these surveyors are part of the working group, with others acting as subject matter experts, as required. Material will be available to the wider survey community for review and comment.
The working group’s objectives are to identify and assess areas in the rules that:
- require surveyors to use their discretion
- are ambiguous or where standards are missing
- have redundant requirements or that require operators to apply for exemptions (which are highly resource intensive for MNZ to process).
The working group will provide content for guidelines and will also develop a review process to ensure the guidelines can be kept up to date.