THE FINAL QUALIFICATION FRAMEWORK
By Captain Tim Wilson, Director, New Zealand Maritime School
Maritime New Zealand has now released the final version of the proposed Qualifications and Operational Limits Framework for QOL.
The final word indicates that further consultation is disappointingly but perhaps understandably, not being sought prior to proceeding to rule development. The release of the draft rule in the future will however, give all of us the final opportunity to have our input into requirements that will have the most profound impact on the operation of our industry.
My initial reaction is Maritime NZ has responded perhaps as well as it could to many of the initial issues given the diversity of stakeholder interests. A fuller understanding of the real implications will come over a little more time.
Andrew Clapham , who inherited the Qual Review project for Maritime NZ and those who supported what are some fundamental changes from those initially proposed, deserve some rare recognition from the industry for their constructive approach. Of Course, we will not agree on the final version. That is the way of our industry but I do believe a far better balance has been achieved between the interests of all the stakeholders.
Positive changes include restricting the application of fill STCW provisions outside restricted limits to vessels of at least 24m. This removes a number of onerous and largely irrelevant requirements on much of the small commercial fleet in the coastal and offshore areas.
Operators of vessels under 24m in length will no longer require full STCW certification or have their engineering requirements based on the combined power of multiple-engine vessels. Proposed non STCW compliant certificates in these operating areas have also been dropped.
The discretion of the director of Maritime NZ to approve alternative certification to operate larger vessels within restricted limits has now been ;limited to 3000 tonnes and most now be supported by a transparent process.
The outcome is that pragmatic requirements for smaller domestic vessels can now been developed without threatening the employment internationally of New Zeal and seafarers. This is a great outcome, given the implications of the initial proposal.
The framework pro vides a linear progression from lowest to highest level certification, with a number of new entry points and reduced sea service requirements for initial certification. This is excellent. However, the sea time requirements for linear progressions extend the total required to achieve the higher levels and greatly favour those following structured training pathways. The balance between these pathways need further thought.
Although it is surely time for everyone in the industry to finally consider a wider future seafarer supply strategy, an incredible amount of work is required to convert employers and trainees to the benefits of structured pathways through the industry.
Certainly from the New Zealand Maritime School’s perspective. The benefits of structured training for seafarers, their employers and the industry under this framework are such that we are already drafting schemes to allow structured training for a higher qualification to be gained while acquiring sea tome for a lower level one.
This is perhaps not a bad long term outcome but does greatly disadvantage those not on this path from the beginning or seafarers already in the system.
The use of the phrase “adjacent to sheltered waters” to define restricted limits and avoid the application of STCW for vessels between 24m and 3000 tonnes inside the 12 mile inshore limit is still not entirely convincing.
In theory, this would allow relatively large trading vessels to operate coastal voyages in contravention with at least the intent of STCW. In practice, the complex shape of our coastline is likely to effectively restrict such operations to the Cook Strait, and perhaps limited coastal operations on relatively small sections of the coast such as bunker and dredger operations.
In my view, the flexibility allowed for such vessels is still too broad and too dependent on the judgment of the director. Conversely, a large number of seafarers and operators will be adversely affected by the removal of the unlimited area endorsement for NZ Offshore Masters. The irony is I have only just returned from the United Kingdom where the administration is considering copying our requirements for this qualification in order to meet a compelling need in the workboat sector.
There is a further irony. The final framework provides for an increase in the number of separate qualifications and endorsements, rather than the reduction flagged at the outset of the proposal. This is not necessarily a bad thing, provided learning content and practical competence development is not unnecessarily duplicated.
Some further thought is required in the transition between lower level fishing and non fishing certification, as little credit is given for transferrable practical skills in the sea time requirements of the framework at this stage.
The learning content work also follows later in the project, but Maritime NZ, the industry and the educators have a real challenge ahead to ensure the appropriate and evidence based competency standards and learning content support the final framework. In conclusion, we now have a framework we can work with, but there is an incredible amount of work to be done before this equates to an effective qualification system that works for the stakeholders.