When the chairman of the International Chamber of Shipping (ICS) made comments in Manila in November proposing a comprehensive revision of the global convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), it probably caught many in the maritime community off guard.
Dating originally to 1978, STCW has been amended and expanded several times, most recently with the Manila Amendments adopted in 2010, which aimed to keep training standards aligned with new technological and operational demands. Those amendments came into full effect at the beginning of 2012 and were implemented gradually through 2017. But with a breadth that includes mandates on rest hours, security training, alcohol limits, and training and competency for deck and engineering personnel, achieving compliance with the Manila Amendments has been a challenge, at least in the United States.
“My concern is that putting the infrastructure in place to implement these agreements takes forever. We can update the convention, but it will still take five or six years to actually implement those changes,” said Sarah Scherer, director and associate dean at Seattle Maritime Academy.
In his published remarks, ICS Chairman Esben Poulsson asserted that employers already commonly impose additional training requirements on officers with STCW certification, and more needs to be done. His conclusion: The existing convention is not measuring up to the needs of the times.
“A fully revised STCW regime would allow the industry to adapt much more effectively to technological developments, including increased automation,” Poulsson said. He added that a revised STCW “should seek to improve transparency and the robustness of implementation oversight. The so-called STCW ‘white list’ of nations that have communicated information to IMO (the International Maritime Organization) about compliance now serves little real purpose as it includes virtually everyone.”
The goal, according to Poulsson, should be a more transparent and effective monitoring system of national implementation to ensure that STCW continues to deliver competent seafarers.
Since shipowners are required to ensure that their vessels are manned by qualified and certificated mariners, it should come as no surprise that ICS will have views on the next comprehensive revision of STCW, said Stewart Inglis, senior adviser in the chamber’s Marine Department. “It can be recalled that it was ICS that led the requests at IMO in the early 1990s, which culminated in the significant 1995 amendments to the STCW Convention and Code, arguably the last comprehensive revision,” he said.
While there has been no specific demand for an overhaul, Inglis said ICS regularly receives information from its members regarding STCW, including concerns about the convention’s implementation or application.
The IMO’s Subcommittee on Human Element, Training and Watchkeeping discusses lessons from marine casualty investigations during a meeting in January 2017 in London. The world body has yet to begin work on the next comprehensive revision of the STCW Convention and Code.
ICS members provide their comments on different subjects and issues through a set of ICS committees, subcommittees and panels. Matters related to the STCW Convention are considered and discussed by the ICS Manning & Training Subcommittee, which has agreed that the chamber “should begin its preparations for the next comprehensive revision of the STCW Convention and Code,” Inglis said.
He explained that shipowners are uniquely positioned to identify the training that seafarers need to be able to perform their functions on ships, and assess whether STCW can be expected to lead to the delivery of qualified and competent seafarers to meet the needs of the industry — in other words, “remain fit for purpose.” As such, “ICS will be seeking to play an important role in identifying the priorities and aspects to consider for amendment during the next comprehensive revision of the STCW Convention and Code, whenever that may be,” he said.
When the 2010 Manila Amendments were adopted, the conference of parties also adopted a number of resolutions, Inglis said. One of them recommended that “a comprehensive review of the STCW Convention and Code should, as far as possible, be carried out every 10 years to address any inconsistencies identified in the interim, and to ensure that they are up to date with emerging technologies.”
It was therefore clearly conceived by the parties that the next comprehensive revision of STCW should be completed around 2020, Inglis said. “Clearly the envisaged time frame will not be met, but given the current pace of both technological and regulatory developments, there would be grounds to commence work on the next revision now,” he said.
In Inglis’ view, the next comprehensive revision of STCW “will be a critical one in its history.” It should be designed to respond and adapt to technological developments, he said, and account for the increasing automation of ship systems, equipment and operations. But in no case should safety be compromised in the process, Inglis said.
Safety cannot be compromised by provisions of the convention alone, he explained, since STCW only sets the international minimum standards for the training and certification of seafarers. The effectiveness of the STCW regime, specifically its contribution to maritime safety, security and protection of the marine environment, is reliant on its implementation and application. However, he added, “a comprehensive revision could provide an opportunity to make some changes to STCW that would enhance and facilitate implementation and application.”
Work on the next comprehensive revision of STCW has not yet been initiated at the IMO, so it is too early to determine whether it might result in a complete overhaul or just a series of amendments. An overhaul should not be ruled out, though, before the work commences, Inglis said.
It is important to remember that a comprehensive revision would likely take many years, he said. First, there would need to be a proposal and agreement at the IMO to undertake the revision, which could happen in 2020, and then a number of years would be required for any package of amendments to be submitted, discussed and agreed upon, Inglis explained. Following that process, entry into force of the amendments would occur two years later and possibly include an additional transition period.
As autonomous and remotely piloted vessels continue to make inroads across the maritime industry, there will be an increasing need for advanced training and oversight at remote operating centers.
“As such, mid- to late 2020s for entry into force and nearly 2030 for the end of any transition period might be realistic,” he said. “A shorter time frame would likely be preferable, but not necessarily possible.”
Scherer said some parts of STCW should be updated to reflect the development of modern equipment, and to take into account the findings of recent accident investigations by the National Transportation Safety Board. However, she said, “we are really bad as a country. We agree to these conventions, but with the 2010 requirements we couldn’t figure out how to make good on them until 2018.”
Scherer also noted that the U.S. Coast Guard is often short on funds to hold parties accountable and enforce STCW requirements. “Until we get our act together, the regulations can be there but it will be a challenge to implement them,” she said.
Lt. Amy Midgett, a spokeswoman for the Coast Guard, said the service and its government partners “are fully engaged at the IMO and would be involved with all discussion of updates to STCW or other IMO conventions during a formally convened session.”
Elizabeth McNie, assistant professor of marine transportation at California State University Maritime Academy, said greater flexibility would be ideal in the STCW Convention, “but given the number of countries involved, it’s much more easily said than done.” She also said technological innovation is outpacing the ability of global institutions to stay abreast of the latest developments, and for that reason STCW has been lagging in its ability to effectively address the changes.
In particular, McNie noted, the development of autonomous and semi-autonomous ships is raising important questions about the training and education necessary for operators, particularly those who work in remote centers.
“Large parts of STCW may become irrelevant for a seafarer who never goes to sea,” she said.