MOSS success stories
Safe Seas Clean Seas Issue 47, December 2014 - January 2015
Charter operator Dive! Tutukaka has taken a front-footed approach to safety. At the same time as the company went through the MOSS application process, it also underwent a WorkSafe audit for adventure tourism operators and completed an independent workplace health and safety certification.
Owner and manager Kate Malcolm said moving into MOSS gave Dive! Tutukaka the opportunity to raise the bar. “We’ve always had our own manuals on all of our boats – but sometimes it’s about doing things a little bit differently,” she said.
“You never lose sight of the bigger picture, and that is making sure you’re operating in a safe way no matter what you’re doing. Even if you’ve done something for a decade, it doesn’t mean you can’t improve your way of doing things.”
Kate says the company’s safety manual is a single document covering all facets of the operation, allowing regulators such as MNZ and WorkSafe to access sections relevant to their requirements without the need for separate systems operating in parallel.
Owner and director Jeroen Jongejans said MOSS has enabled them to take a more complete approach. “What I like about MOSS is that it takes a wider view. Rather than just looking at the vessels, it looks at how the company works as a whole,” he said.
Hazard identification for a diving operation is complex, ranging from the usual slips, trips and falls to diving-related risks – even possible interactions with sea creatures.
Skipper Evan Barclay said despite these kinds of challenges, the MOSS application process was not a great leap for the company. And he said there have been unexpected spin-offs, like the close working relationship with the regulator: “For us, it’s great being able to deal directly with MNZ”.
Evan believes that operators who’ve previously been actively engaged with their safety systems will find the process similarly smooth – and relatively quick. “If you haven’t had much to do with your safety system in the past then it might be a bit of a stretch, but really, if you spend the time on preparation, MNZ won’t have to spend a lot of time telling you things you’ve got wrong,” he said.
“For us, moving into MOSS was pretty straightforward. And we haven’t had to change much on our boats – apart from perhaps a bit more on recording of maintenance and our training records.”
Evan said for an operator working in the international tourism sector, reputation is everything. “You just can’t afford to have anything happen that is going to damage your reputation. You have to stay ahead of the game when it comes to safety.”
New Plymouth fisherman Ian McDougall is one of the first single-vessel fishing operators to have completed the MOSS application process. He recommends fishermen get some advice before starting work on their Maritime Transport Operator Plan (operator plan).
“I would say, get somebody with knowledge to help,” he said, rather than simply going straight into the online template on the MNZ website.
MNZ also recommends operators talk to one of its maritime officers before starting work on their operator plan – and that advice is available free of charge.
Ian fishes the west coast of the North Island, from Kawhia to Whanganui, on the Compass Rose. Although he paid a contractor (Clint Lower of Workstream, Training and Compliance) to help produce his operator plan – “my beautiful manual” he calls it – he had to demonstrate during the MNZ site visit that he knew the contents well.
“At the end of the day, I am extremely proud of my manual, but it took a bit of time and money to do,” he said.
Under MOSS, MTOCs (Maritime Transport Operator Certificates) are valid for 10 years, rather than the four-year term of SSM certificates, which Ian said should bring some financial benefits.
“Cost-wise, over 10 years it should work out okay if you’re a good operator. Spreading the cost of survey over five years rather than four will also be a saving,” he said.
MOSS was introduced to improve safety in the sector and Ian said it should do that. “Probably at the end of the day it will, but it can look like they want someone responsible in the firing line, if something goes wrong. Having said that, there are a few operators that need to be hauled over the coals.”
For those operators baulking at putting together their MOSS applications, Ian has some pragmatic advice: “Get over it! Here’s my manual – I will show it to anyone. I’m happy to make it public because my personal aim is to give back to the industry, as one way or another I have received heaps.”
As one of the first charter operators in MOSS, Russ Hawkins of Fat Boy Charters admits to having felt a little apprehensive about applying to enter MOSS.
In business for 14 years, operating about 100 fishing charters a year out of Tauranga with his 7.2m vessel, Russ had heard he might be in for a challenging time meeting MOSS requirements. The reality, however, was far different.
“I thought it was going to be a lot of hassle and take hours and hours, but it was a far easier transition than I thought it would be,” he said.
Russ also puts the cost of MOSS in perspective, when compared to the previous system.
“Sure, there is a higher cost for the initial outlay but when you look at your MTOC, it lasts for 10 years [compared with the four-year duration of an SSM certificate],” he said. “And the advice I’ve had from the maritime officers during the site visit is that if everything is going well and you’re operating properly, they will not want to see you for at least a couple of years after each audit.
“That’s what you want to hear – that the focus is going to be put on operators who aren’t doing things right, rather than the ones who are.”
Russ said the change for operators under MOSS doesn’t necessarily mean a dramatic shift in the way things are done. Hazard identification is key, but the major change is in having a safety system specific to his operation.
“In the past things may have been a little generic, but it’s good to have the survey tailored to my specific operation and boat. There were not a lot of changes made to the way we were doing things, but we got some good suggestions about small details.”
Russ said the MOSS process is not something operators need be worried about. “Getting our MTOC has been an enjoyable experience and not the hassle portrayed by other operators. The team at MNZ was totally supportive and assisted all the way throughout the process.”
Sail the Bay yacht charters
Jeff Whittaker took a pragmatic approach to his MOSS application, prompted by an MNZ audit of his Sail the Bay operation six months after he’d received a new SSM certificate in May.
Jeff operates La Vendemmia on sailing charters and has an LLO certificate. He estimates that in 20 years of chartering in Hawke’s Bay, the Marlborough Sounds and Tonga, he’s sailed about 34,000 nautical miles.
The company carrying out his SSM process hadn’t completed the job, and a new management company was contracted to produce the SSM survey certificate and four-year maintenance plan in time for the MOSS entry deadline of July.
When MNZ identified Sail the Bay for an audit in November, Jeff, while not thrilled about the idea of going through the MOSS application process after so recently completing SSM certification, weighed up his options.
“Initially I was pretty annoyed, but if you’ve got to do it, you may as well just get on and do it,” he said. “I thought it would be a waste of time to go through the whole process to address the requirements of the audit, when I could spend the time to get straight into MOSS.”
Despite attending a workshop, Jeff didn’t feel well informed about the process for entering MOSS, so he contacted MNZ directly and recommends others do the same when developing their operator plan. “I think the best approach is to get some guidance on the requirements. MNZ are very happy to help. It then seems a simple exercise of describing how you operate and what you do,” Jeff said.
“The good thing about MOSS is that it does put you in the centre of the process. I had an SSM manual but I had never really read it right through – I knew the log provisions and the incident reporting requirements – but MOSS gets you thinking about the operation as a whole.”
For Jeff, it hasn’t been a case of having to produce a lot of new information. “I’m not identifying any issues or hazards I wasn’t aware of, but the process of developing an operator plan makes you put them in good order,” he says. “It makes you think about the whole operation... now I’m telling a story about what I do.”