International Harbour Master’s Association Congress Cork May 2012

THE GOVERNANCE OF PORT SERVICES PROVIDERS: COMPETENCY IN

TOWAGE OPERATIONS

BY CAPT. A CRAWFORD RD AFNI FITA

& CONTRIBUTIONS BY CAPT. A NYGH MNI FITA

BACKGROUND QUESTIONS

• What are the important factors in deciding what is the best ‘model’ for towage provision in a port?

• How can you choose the best towage provider to meet the port’s specific requirements?

• What ensures that the selected towage service will operate to best practice and appropriate safety standards and offer value for money?

• How do you properly assess the selected towage service in terms of reliability and the sustainability?

• How do you ensure competence of personnel engaged in the provision of marine services.

BACKGROUND QUESTIONS

• Is the appointment of a specialist consultancy company an appropriate way to assist in setting key performance indicators for the towage providers and ensuring proper compliance via an auditing process?

• The possible development of a training syllabus for Classification Societies for a scheme of training to provide approved endorsements for tugmasters to operate active Escort Tugs as part of a new Class standard for these specific vessels.

• The draft UK Marine Coastguard Agency Towage Endorsement Scheme applicable to all certificates of competency. Who should become the approved assessors for such a voluntary certification scheme?

INTRODUCTION

The aim of this presentation is to briefly cover:

• Examination of current marine standards and best practice that stipulate or encourage the formulation of an effective training and assessment policy within port marine operations.

• Methods for the competent training of tug masters, pilot boat coxswains and their respective crews.

• How such training systems and standards should interact with Port Safety Management Systems.

• What to assess in selecting a towage contractor.

• How improvements can be implemented.

RELEVANT APPLICABLE REGULATIONS & STANDARDS

Relevant regulations and standards include:

• The Standards of Training, Certification and Watch keeping (as amended up to 2010) Annexes A/1/6 & A/1/8.

• International Organisation for Standardisation - ISO 9001-2008 code in Clause 6

• International Safety Management Code (2010) - Safety Management Systems ISO.

• Port Marine Safety Code (UK only) – 2010 and A Guide to Good Practice in Port Marine Operations

• Potentially the DRAFT UK MCA Towage Endorsements to all STCW Certificates of Competency (UK only)

RELEVANT APPLICABLE REGULATIONS & STANDARDS

Good examples of appropriate defined standards of good harbour management of port marine operations can be found: • Within many worldwide ports Safety Management, Quality

Systems, risk assessments registers are all properly reflected within specific port and pilotage instructions.

• In the UK Port Marine Safety Code and its Guide to Best Practice in Port Marine Operations is established for safe port operations

• In the syllabus and required knowledge indicated in the draft UK MCA Voluntary Towage Endorsement Scheme, and similarly within the Boarding & Landing of Pilots by Pilot boats Code of Practice.

• Within port industry training programmes where national occupational standards and syllabus have been derived for specific purposes e.g. pilot training programmes.

STCW 2010

• Resolution 8 of STCW 2010 ‘Companies must ensure that their Masters and Crews, in addition to being qualified for a specific role on-board, are also competent to perform their assigned duties’

• Originally drafted as a competence standard for all seafaring nations.

• Not an education & knowledge based standard

• The candidate for examination must have appropriate experience and knowledge.

• Specific competencies are defined in the tables within the standard (for example A/1/6 & A/1/8 and assessment are defined in A/1/16 relating to MASTER – STCW 500gt (and above)

ISO 9001-2008

The International Organisation of Standardisation (ISO) is an international Quality Management Standard that requires evidence of application within written management policies and procedures.

Under ISO 9001:2008 Section 6: Resource Management, the standard requires that ‘Personnel performing work affecting conformity to product requirements shall be competent on the basis of education, training, skills and experience’

ISM CODE (2010)

The purpose of the International safety Management Code (ISM Code) is to:

Ensure Safety at Sea

Prevent human injury or loss of life

Avoid damage to the environment and to the ship

ISM CODE COMPLIANCE

An approved SMS consists of the following key elements:

Commitment from top management with a top tier Policy Manual

A Procedures Manual

Procedures for conducting both internal and external audits

A Designated Person to serve as the link between the ships and shore staff

A system for identifying where actual practices do not meet those that are documented and for implementing associated corrective action

Regular management reviews

Resources and Personnel states that: ‘The Company’ should ‘establish and maintain procedures for identifying any training which may be required in support of the safety management system and ensure that such training is provided for all personnel concerned’

PORT MARINE SAFETY CODE (UK)

• The Code applies to all harbour authorities that have statutory duties and powers relating to marine safety founded on primary legislation i.e. Statutory Harbour Authorities.

• Included is a summary of the legal duties and powers of harbour authorities relating to marine safety.

• All harbour authorities within the UK now broadly comply with the Code, which is non-regulatory but not optional!

• The Code is considered to be an authoritative articulation of best practice in port safety internationally.

• The Code is not intended to replace or duplicate any other legal or administrative requirements.

PORT MARINE SAFETY CODE (UK)

Within the Code, competence standards are highlighted as follows:

• All persons involved in the management and execution of marine services should be qualified and trained to the appropriate national standard

• Harbour authorities must assess the fitness and competence of all persons appointed to positions with responsibility for safe navigation.

• Achieving marine port safety is a team operation and people in these roles must be competent and adequately trained. The Guide To Good Practice On Port Marine Operations was

prepared in conjunction with the Code and offers further information and guidance on a range of related standards.

Training and competence (PMSC)

All parties involved in the management and safety of navigation must be competent and qualified.

• These standards should be placed into port policy, supporting procedures and local regulation.

• Training and competence assessment must form part of periodic audits:

A port authority must ensure that contracted harbour vessels and craft being employed within its port limits are fully fit for purpose and that the crew are appropriately trained and qualified for the tasks they are likely to perform.

Harbourmaster’s engaged in the licensing of any craft or personnel must ensure that proper and appropriate processes, standards and competencies have been established and are applied uniformly in the interests of port safety.

Ship Movement Method Statements

‘Movement Plans’ can be formulated, operated and enforced under the powers of direction of the Harbourmaster.

• These are important tools for the conduct of safe marine towage operations as they ensure that:

All parties know the relevant details of any particular port passage well in advance;

There is a clear, shared understanding of potential hazards, margins of safety, and the characteristics of specific ships prior to movement;

Intentions and required actions are agreed for the safe conduct of the movement including the effective use of tugs and their availability and any significant deviation should it become necessary;

Pilotage Directions (PMSC)

Pilotage directions should be based upon formal risk assessment should define the geographic area within which pilotage is compulsory and specify the requirements for different ship types and the conditions where it is compulsory to use tugs.

Competent people (i.e. trained, qualified and experienced) must be employed in all positions of responsibility for safety of navigation.

Towage Procedures and Guidelines (PMSC)

Should ideally include: • Communications and the agreed system of orders between the pilot and

the tugs;

• The operation and employment of tugs in restricted visibility;

• Through risk assessment guidance on the use of tugs and other marine craft operating within harbour areas;

• Recommendations of the type of tugs and method of towline preparation

• Discussion concerning towing operations may be necessary in view of prevailing weather and tidal conditions and any other special circumstances.

• In all non-standard movements a towage plan or method statement should ideally be submitted to the harbour authority a minimum of 24 hours.

Towage Plans

• Particulars of vessel to be moved e.g. Bridge card

• Type of tug, propulsion method, towing from winch or hook and location of winch/hook

• Proposed method of towing

• Operational status of navigational aids and equipment

• Minimum speed to maintain steerage of vessel to be assisted

• Movement of other vessels in the area

• Navigational characteristics of the particular area of the harbour

• Tug securing points – an assessment of strength of deck fittings against maximum BP of attending tug(s). Does the vessel have adequate securing points in the right positions? Are there any obstructions or hazards to note?

Towage Plans

• Windage profile and environmental assessment. The lateral and longitudinal forces and yaw moment coefficients depend on ship’s form, draft and trim, superstructure and masts, and the angle of attack of the wind.

• Bollard pull requirement - the calculated windage, current, beam waves, underkeel clearance, tow rope angles when making way, known depreciation of recorded BP in older tugs, tug propeller effects, balance of forces fore and aft, redundancy and reserve power.

• Restricted visibility operations – should consider a Contingency Plan should visibility deteriorate after the tow has commenced and/or if the tug has to disengage at any stage of the operation.

• Competence and training of key individuals – are there persons under training?

CHOOSING THE BEST TOWAGE PROVIDER?

• A port authority has to make provision either from approved contractors for marine services in their port or by supplying services directly.

• There is at times a wide gap between the actual services provided by towage companies to what is stipulated in the body of a formal licensing agreement by the Port Authority.

The towage provider under or minimises the quote to win the port then has to maximise return by minimising expenditure.

The risk to the port is that in the process the service becomes less reliable, which in turn increases the risk to port infrastructure, assets, third party users and commerce.

• How is a Harbourmaster to ensure an appropriate standard of service and ‘best practice’ in this complex and specialised discipline and how does he/she know whether the towage provider is delivering to an acceptable standard or not?

CHOOSING THE BEST TOWAGE PROVIDER?

• Prior professional reputation is a useful primary indicator;

• A formal assessment of marine services providers and continue to conduct periodic audits.

• An initial assessment should form part of the selection processes that are necessary prior to establishing a service provision contract and should include consideration of the following:

Is there a high-level safety policy with safety management procedures, work instructions and records?

What is the accident and incident record of the organisation over the last 2 years?

What relevant experience and qualifications do the local manager and his immediate superiors have? An obvious lack of marine qualifications in either deck or engineering specialisations might raise some concerns.

CHOOSING THE BEST TOWAGE PROVIDER?

Does the vessel operate to an appropriate planned maintenance system?

Is the majority of staff familiar with their company’s procedures and do they know where to look for guidance? Be wary of contractor-selected hosts during visits, and seek conversation with other members of staff.

What is the observed general standard of personal and protective clothing?

Can original Class, Flag and test certification be easily produced from properly organised filing systems on board?

Can staff produce their certificates of competency/service and are they valid

CHOOSING THE BEST TOWAGE PROVIDER?

• Rigorous application of safety management principles and by taking nothing at face value in any evaluation assessment and in all subsequent audits.

• As a condition precedent to operate is the production of valid certification to demonstrate that quality assurance programs exists

• Harbour Authorities should take a particular interest in their prospective towage/marine services provider’s shift patterns and working hours. For example - Is the crew therefore sufficiently rested for the impending ship movement?

• By general observation and a thorough approach, poor standards can be identified.

THE CONTINUAL ASSESSMENT OF MARINE SERVICE PROVIDERS

Questions needed to be asked:

• In a key and dangerous environment such as active escort towage, does the harbour authority possess the necessary in-house expertise to fully evaluate all of the important safety aspects of its marine services providers?

• Does this organisation test their staff for dyslexia as part of their induction process?

• If their manuals are in English, can all crew members actually read technical English?

THE CONTINUAL ASSESSMENT OF MARINE SERVICE PROVIDERS

• What training is given to staff on a computer based SMS systems?

• Do crews have up-to-date copies of the SMS and other primary procedures?

• Do crews have un-fettered access to the SMS, fleet and technical memoranda and other updates?

• Often the tug’s computer is either in the Master’s or Engineer’s cabin, if so how do the rest of the crew access the SMS so as to learn and study it?

THE CONTINUAL ASSESSMENT OF MARINE SERVICE PROVIDERS

Comments on assessment:

• When assessing a towage or marine services provider, particular attention should always be given to their local record on retention, recruitment and training…It is not always poor pay that drives high staff turnover!

• ISO accreditation plus compliance with the ISM Code are good indicators of a sound safety management ethos and structure, but these standards can be quickly undermined by a variety of human factor issues.

THE CONTINUAL ASSESSMENT OF MARINE SERVICE PROVIDERS

• Both ISO 9001:2008 and the ISM Code whilst containing important aspects in shaping best practice, do not adequately cover technical and vocational detail in marine operations.

• ISO accreditation and compliance with the ISM Code are not required for most tugs in the majority of Flag Administrations, so their absence is not necessarily an indicator to poor performance.

So where do you look for such detailed information on the conduct of safe towage operations in terms of tug suitability and reliability and importantly, in training and crew competency?

WHY DO WE NEED COMPETENCY BASED TRAINING?

The main driver for vocational training on tugs has been the change from conventional fixed screw propulsion to the omni-directional marine propulsion units - a revolution in tug design over the last 30 years.

• The modern harbour tug will be either an Azimuth Stern Drive or Azimuth Tractor Drive tug. Azimuthing propulsion units replace shafts and propellers enabling the propeller and its associated nozzle to rotate about its vertical axis (360° rotation).

• ASD tugs can also be referred to as “reverse-tractor tugs”.

• Technology improvements in towrope and winch design have also reduced safety margins when compared to the slower towage operations of the past.

HOW DO YOU DEFINE A NON-SUBJECTIVE COMPETENCE STANDARD?

• Question: Does an STCW Certificate of Competency cover the required specialist competencies for a tug master of a modern 65 T BP ASD tugs engaged in active escort towage operations with tankers?

• Answer: Not really – unless by some chance, the seamanship orals examiner was an ex-tugmaster and able to drill down into this area of specialist knowledge

• Question: Does the ISM Code or ISO standards fully cover tug master competencies?

• Answer: No, they only require (non specified) adequate training.

• Question: Does the UK Port Marine Safety Code cover tug master competency?

• Answer: In overview it does.

HOW DO YOU DEFINE A NON-SUBJECTIVE COMPETENCE

STANDARD? • Question: So where can you find the necessary detail and content on tug

master competencies and specific subject matter and operational knowledge?

• Answers: In the UK PMSC Guide to Good Practice refers to the British Tug

Owners Association ‘crew training’. The European BML with a Towing and Pushing Endorsement – is the

minimum tug master standard in the UK. Holders of an STCW Inshore Tug Certificate of Competency (Master)

STCW (Category D Waters) OR a Certificate of Competency (Master II/3) for domestic vessels

operating in Category C and D waters

These are the accepted alternative minimum IMO STCW qualifications.

HOW DO YOU ESTABLISH A NONSUBJECTIVE COMPETENCE

STANDARD? • Take the trainee up to a high non-subjectively-assessed

‘defined standard’

• In the SeaWays Training System there are 17 separate tug-handling skills captured in the Competency Circuit, all of which are directly transferable into towage operations.

• Because this type of training is to a defined standard, there are minimal variances in the service provided to a pilot.

• Sets a non-negotiable defined standard applicable to any port operation involving harbour towage and other auxiliary services such as pilot boat operations.

WHY A STANDARD MUST BE MAINTAINED

• Over the following 12 months and common perhaps to any competency training in other walks of life (driving, riding, diving etc.), the skill set degrades unless it is constantly maintained.

• The need for, and review of, an assessed standard will always be undertaken after a serious accident or incident.

• Prosecution may follow if prima facie evidence exists that a lack of competence by a certificated and legally responsible person was a contributory factor (e.g. the tugmaster).

A TUGMASTER TRAINING PROGRAMME

• The SeaWays Tug Master Training Programme incorporates the principles and content of all the above: • It uniquely consists of a modular series of on board training programs and exercises moving systematically through the key elements of tug handling training: Learning to drive the tug Undertaking harbour towage Escort towage • All modules are fully documented and incorporated in comprehensive manuals written by tugmasters for tugmasters. • The training is unique as it progresses through exercises that incrementally increase in level of skills and multi-tasking required by the tug master. • It builds skill sets in an environment of competence founded in confidence, with the student having an input to the pace of training at all times.

WHAT IS THE REQUIRED STANDARD TO ACHIEVE?

• Several IACS members have now proposed Class Rules on Escort and Offshore vessels which will:

improve safety standards

reduce marine insurance premiums.

• SeaWays Training Programmes have been evolved over 15 years to be compliant with STCW 95, ISO 9001:2008, ISM Code and UK PMSC. They have recently been reviewed to ensure full compliance with the proposed MCA towage endorsement scheme.

• Externally accredited training masters must be identified, trained and deliver the internal training program. They can then be employed to carry out on going compliance assessments.

Is it a level playing field?

• The competency based training system should have a ‘No fear or favour‘ ethos.

This can be achieved by delivering a modular structured programme to ensure a solid foundation of necessary skills is built up.

The programme aims to build skillsets in an environment of competence but founded and supported by an equal improvement in the confidence of the student who should have an input to the pace of training at all times. The student must have an input on the pace of training at all times.

• Training standard must be defined in writing and non-subjectively assessed with the award of a Certificate of Achievement (not ‘attendance’) upon successful completion.

Training at no cost?

There are tangible savings derived from good training:

For the towage company from reduced accidents and incidents

Wear on equipment and machinery e.g. A fuel consumption reduction of >20% is common following the SeaWays training.

Safer towage operations for crews, tug and ship but also third party assets and infrastructure.

‘PROPOSED’ UK TOWAGE ENDORSEMENT SCHEME (VTES)

Brief background to the scheme:

• The current proposals originated from a series of accidents in harbour towage.

• Due to a series of accidents, the UK MAIB had issued notices to tug owners and operators concerning the competence, standards of training and in particular, familiarisation training on tugs types that have a significantly different propulsion system.

• This highlighted that training should incorporate instruction and validation on all manoeuvres that the master is likely to perform in standard port operations.

‘PROPOSED’ UK TOWAGE ENDORSEMENT SCHEME

Key points:

• The UK MCA collaborated with industry and produced, in 2010, a draft Marine Guidance Note for three proposed voluntary towage endorsements to any certificate of competency.

Towing and pushing

Ship Assist

Sea Towage

‘PROPOSED’ UK TOWAGE ENDORSEMENT SCHEME

• It was developed at the request of the UK towage and workboat industry.

• Its aim is to ensure that towage masters have the necessary skills for specialist operations and to provide guidance for their training.

• It identifies the specific underpinning knowledge and skills needed to safely operate in this area of the maritime industry.

• The original working group was formed from the towage industry in the UK, and addressed the specialist nature of towage in rivers, harbours and coastal areas.

• Its an assessed standard – Assessors are ‘to have a minimum of 5 years relevant experience in towing operations as master and relevant assessment experience’.

A WAY FORWARD

A WAY FORWARD

How should such endorsements would be structured, governed and administered? I must repeat the call to key stakeholders to focus and consider this important subject:

The International Harbourmaster’s Association (IHMA)

The International Maritime Pilots' Association (IMPA) and regional and national associated organisations (e.g. EMPA – UKMPA)

The Nautical Institute (NI)

Government Marine Safety Agencies and Marine Management Organisations – worldwide

A WAY FORWARD

Marine Education and Training – National Maritime Training bodies and representative e.g. IAMI & GlobalMET (International) – MNTB & MSA (UK only)

International Association of Classification Societies (IACS)

UK Port Skills and Safety (PSS) and associated colleagues worldwide

International Ports and Harbours Association (IPHA)

Recognised national and international industry bodies e.g. National and International Chamber of Shipping and the European Tug Owners Association.

International Tug Master’s Association & Masters of Towing Vessels Association

A Steering Group?

• A proposed steering group will initially scope terms of reference.

• Capture any related and current training and competence initiatives underway within each maritime sector and organisation represented.

• Communicate awareness and an informed debate of the key issues requiring international coordination.

• The aims of the Steering Group is to formulate concrete recommendations within a defined framework and timetable.

• A Steering Group could be chaired and lead by the IHMA .

• Final recommendations and approved project programmes would be widely promulgated and tabled for further discussion with individual organisations, agencies and up to government attention.

• The IMO may ultimately include its recommendations in STCW by adding sectorial standards of training and competence.

IN SUMMARY & CONCLUSION

• A harbourmaster has a direct responsibility to ensure safe and effective operations within a port but currently lacks an internationally recognised defined and applicable standard in terms of quality of marine operations service provision and related competencies.

• A marine service provider cannot be properly audited unless there is an agreed, defined set of relevant standards in place specific to each type of marine operation assessed.

• For any audit to provide value and compliance it has to be independent, and conducted by recognised and suitably qualified auditors who are suitably qualified and experienced with specific practical expertise.

IN SUMMARY & CONCLUSION

• An ISM and or ISO audit is focused only on the Safety Management System and its procedural structure and compliance. It does not cover the vessel operations compliance or performance nor the practical assessment of the competency of the vessel’s master or crew.

• Good examples of appropriate defined standards of good harbour management of port marine operations can be found selectively worldwide.

IN SUMMARY & CONCLUSION

• Existing IMO STCW certificates of competency have no specific or practical application to the safe and effective operation of modern high powered tugs.

• STCW is primarily a competence-based system reliant upon individual skills and experience. This is a paradox that can only be resolved by the addition of appropriate endorsement to general certificates of competency that relate to tonnage and operating areas in isolation.

IN SUMMARY & CONCLUSION

• The safe operation of tugs requires specialist skill sets trained and assessed to non subjective standards for universal application around the world.

• There are independent consultants with specific and relevant expertise who can assist in competency based training programmes, and undertake on going operational auditing on behalf of the harbourmaster and national marine safety agencies.

IN SUMMARY & CONCLUSION Last one!

• Through effective training and annual assessment, the safety of towage and other marine operations can be improved.

• Effective training and auditing will ensure that new entrants to this sector are able to develop a career in towage with confidence and with competence.

• The enormous costs resulting from a major marine incident can be reduce the chance of such incidents by instigating and maintaining good safety management procedures.

• Preventing towage accidents in ports can be best achieved and maintained by the setting of defined and independently assessable competency standards.

• The UK voluntary towage endorsement scheme for all mariners undertaking towage activities, offers a realistic standard in this high-risk area and if implemented, will be a major improvement in port operations at all levels.

Thank you for your attention

www.seawayseurope.com

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