26 October 2017 | C17043
The Sub-Committee on Human Element, Training and Watchkeeping, at its 04th session, noted the urgent need for some clarification on the implementation of the 2010 Manila Amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), 1978, as amended.
Ship Owners/ Managers/ Operators | Flag Administrations | Surveyors
The Sub-Committee noted that problems associated with requests for documentation during inspections or surveys that is not required by the STCW Convention, 1978, as amended, were resulting in significant and unnecessary administrative burdens on Administrations, companies and seafarers. It was further noted that some problems were linked to inconsistencies in interpretations regarding the status of IMO model courses. References to the STCW Convention, 1978, as amended, were made in varied ways within certificates and documentary evidence and there were reported misinterpretations of the training and familiarization provisions for Electronic Chart Display and Information Systems (ECDIS) as required by the STCW Convention, 1978, as amended.
The 2010 Manila Amendments to the STCW Convention and STCW Code introduced four new certificates as set out in regulation II/5 (able seafarer deck), III/5 (able seafarer engine), III/6 (electro-technical officers) and III/7 (electro-technical ratings), and that misinterpretation of the applicable provisions had been reported.
To assist all concerned, the Sub-Committee prepared clarifications on a number of issues as described below.
Provision of documentation for verification
Under regulation I/2 of the STCW Convention, 1978, as amended, the documentation authorizing the holder to serve in certain functions on board ship are certificates of competency and certificates of proficiency and, only with regard to regulation V/2, documentary evidence. The list of certificates or documentary evidence required under the STCW Convention, 1978, as amended, is set out in table B-I/2 of the STCW Code.
Certificates of competency, certificates of proficiency and documentary evidence issued in accordance with chapters II, III, IV, V, VI and VII of the STCW Convention, 1978, as amended, are evidence of having successfully completed all required training and that the required standard of competence has been achieved.
While IMO model courses may assist with the development of training programmes, they are not mandatory, and Administrations are not required to use them when preparing and approving training courses to meet the objectives of the STCW Code, as amended.
The validation of an IMO model course means that no reason was found to object to its contents. It does not mean that it is an official interpretation of the Convention, or that approval was granted by the IMO bodies. It is agreed that:
- in accordance with regulation I/4 of the STCW Convention, 1978, as amended, seafarers should not be required to provide documentation for verification that is not required by the Convention; and
- certificates or documentary evidence issued under the STCW Convention, 1978, as amended, should not be required to contain reference to IMO model courses.
References to the STCW Convention, 1978, as amended
The normal practice within IMO is to refer to international conventions by an acronym of the title of the convention and the date on which it was made (e.g. SOLAS 1974). Where amendments are made to the original convention, the title is then amended to reflect the amendments (e.g. SOLAS 1974, as amended) but it is not normal practice to append the year/dates of the amendments to the title of the amended convention.
It has been reported that different references to the STCW Convention, 1978, as amended, can be found in certificates and endorsements, which has led to some confusion. In particular, if the references had different meanings, or if the differences were unintentional.
The format of certificates and endorsements provided in section A-I/2 of the STCW Code refers to “the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended”.
In order to avoid confusion, it is recommended that certificates and endorsements referring to the STCW Convention use the reference “the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended”, without appending the year/dates of the amendments.
It is important to note that seafarers may hold certificates and documentary evidence that contain a different reference to the STCW Convention that remain valid and should be accepted.
Training requirements for Electronic Chart Display and Information Systems (ECDIS) and provision of the documentation for verification
The STCW Code contains requirements for approved training on ECDIS. In cases where the approved training has not been completed, a limitation shall be included on the certificate and endorsements issued to the seafarer. Where such a limitation is not specified, the certificate and endorsements are evidence of having successfully completed the required approved training and that the standard of competence has been achieved.
No requirement exists for the approved training on ECDIS equipment to be type-specific. The knowledge, understanding and proficiency required to be demonstrated is generalized to ensure seafarers have the necessary skills for basic operation of all types of equipment.
In accordance with regulation I/14, companies are responsible for ensuring that seafarers employed on their ships are familiarized with the installed equipment, including ECDIS.
It is agreed that seafarers required to have training in the use of ECDIS:
- should not be required to provide documentation of training in ECDIS that is specific to the installed equipment; and
- are required to be familiarized with the ECDIS equipment installed on board.
Regulations II/5 (able seafarer deck), III/5 (able seafarer engine), III/6 (electro-technical officers) and III/7 (electro-technical ratings)
Misinterpretation of the applicable provision of regulations II/5, III/5, III/6 and III/7 has been reported. In particular, port State control officers have required personnel on board to possess applicable Certificate of Competency or Certificate of Proficiency, when such personnel are not included in the Minimum Safe Manning Document (MSMD) of the ship.
Ship Owners/ Managers/ Operators including certificate-issuing Parties and Administrations, should take into consideration above clarifications to the 2010 Manila Amendments ensuring necessary actions to be taken, as appropriate.
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