Showing posts with label Transport Canada. Show all posts
Showing posts with label Transport Canada. Show all posts

Monday, July 07, 2014

TC - Interesting for all the wrong reasons

It caught my eye one evening on watch, while catching up on my maritime news. There it was a Transport Canada (TC) advertisement, a few simple lines, in French and English, in a US based magazine. Well, that was strange to start with, I thought to myself, then I read the ad: “News for owners of vessels over 24 meters, change in service delivery for certification and inspections”.  
I know about delegation, but I thought this was an optional program. According to this ad it would seem like TC has made it mandatory effective January 2014, for basically all commercial vessels that most of us are accustomed to.

Wow! Just think about it.

If TC is not going to inspect or even issue certification to commercial ships, defer that responsibility to class, what’s left for them to do? Recreational stuff, some small commercial, nothing that really matters to the greater shipping industry, mostly just hassling individuals people like seafarers. That is pretty astounding, and scary, for a federal agency to give up so much power and oversight to commercial entities.

I am sure that someone at TC would argue that they maintain the authority to enforce and create regulations. Yeah, of course you do; which is why as a professional seafarer, I am most worried with this plan. How can you make effective regulations and policy on commercial shipping, really the meat and potatoes of their “clients” / mandate, if you withdraw more and more the ability to see what’s actually going onboard, in the industry.

TC - Interesting for all the wrong reasons
Despite withdrawing front counter services left, right, and center, TC still seems to have a huge bureaucracy that is going to have to justify itself. But if you’re not enforcing laws, because you’ve delegated that authority to business entities, or just the fact that “regulators” don’t get out from their cubicles, then what are you going to do? Where are you going to get the technical skills to create policies and regulations?

I would imagine that they’ll squeeze the remainder of their clients / mandate; harass small time operators, individual seafarers - as if the certification process was not bullshit enough – and recreational boaters.

Speaking of that recreational boater. I know TC is a notoriously shy agency, but I get the feeling that the agency has a considerable pedigree of experienced seafarers, especially those trained overseas. This should certainly be interesting as to how regulations will be developed for recreational boaters, fishermen and small time operators in Canadian waters.   

This must be a boon for the large operators. Basically they get to wield their usual business prowess with their vessel’s Class, without interference from the people who are supposed to regulate them. I don’t blame them, really they are looking after their own interest, and when you’re encountered with a dysfunctional system, you press for change. I know I have…

As an added bonus to established operators in Canada, TC will crack down with their famous “variable standards” on any budding business. This “see, were still relevant” reaction, is sure to prevent any small operator from becoming a serious competitor, and posing a threat to the established players in the market.

The simplicity of the ad was quite comical, given the huge impacts this has on us as professional Canadian seafarers working domestically. It is astounding that Transport Canada would even push this agenda in the wake of the Lac Megantic calamity hanging over their heads. I must say I am jealous of the ship owner’s et al, to get such treatment.  

I wish TC would relinquish their responsibility for the certification of seafarer process, and let it be properly reviewed and modified to meet real world realities. But I am afraid that at the end of the day, blaming individual is quite trendy, and necessary for governments. TC won’t give up that file as they need to keep the sacrificial lambs on a tight leash and close by. Blaming individuals, the “bad apple”, allows the system and the larger entities from ever bearing the true consequences of reckless behaviour – the rotten barrel, filled with low quality genetically modified apples stored in a wet damp location. 

I’d love to give you more information, but the ad only gives names of 5 approved Class Societies now doing TC’s work, and gives the general TC website and phone number; there, “due diligence” criteria met.

After 30 minutes getting lost on the TC website I finally found something to reference to, clear here for more info on this program.
Pictures from the interwebs

Friday, August 30, 2013

Pressure is building: TC's CoR

TC's HQ in Ottawa
I love what I do, working on ships as a Marine Engineer. It’s hard to classify one-self, but judging from recommendations I have received fairly consistently over the years, I say I’m certainly “average” in my work performance. With liking what I do, and being somewhat successful, it’s little wonder that I wish to progress in my craft, move up the ranks, and achieve a higher Certificate of Competency (CoC).

However, “moving up” under Canada’s regulatory regime is fraught with “landmines” and numerous obstacles. The sheer size of the project to upgrade’s one CoC, is exhaustive to think of. I have written an article detailing my observation of the numerous problems with it, which you can read here. Upgrading a CoC in Canada is a very big problem that affects all Marine Engineers, and has resulted in a large amount of capable Engineers not being able to jump through onerous regulatory hurdles, and move up the rank ladder, resulting in a “ticket vacuum” on board commercial ships operating in Canada.

Uneven playing field

The certification system in Canada is not the same as other countries. As a result, I propose that a large majority of Canada’s future Certificate of Competency, Class 1 and 2 at first, will have been trained abroad, migrating into the Canadian licensing system at the upper certification levels. I believe the writing is on the wall, this stream of certificate issuance - the recognition of foreign issued Standards of Certification and Watchkeeping (STCW) compliant CoC - will be how Canadian ship operators will access nearly all of their current, and future senior Engineering Officer needs onboard.

As such, there is increasing pressure on Transport Canada to adopt the Certification of Recognition model, used by many nations, guided by the International Maritime Organization’s (IMO) STCW10. I think this is the inevitable, and is in my view, logical. I would expect it to be the policy of Transport Canada in the very near future. You can read yourself what the STCW2010 (Manila Convention, page 12, Regulation I/10), to which Canada is signatory, says about this subject.

The problem with this plan, is that I am not seeing any changes to the way Canadian trained engineers are certified, which is far more burdensome than other nations issuing the same Certificate of Competency. Another words, I have no problems competing with foreign trained engineers, but please Transport Canada, give me an even ground to compete on!

Kicking the can down the road

It is not hard to imagine that a Certificate of Recognition is to the benefit of Canadian ship operators, for the next 5-10 years perhaps. During that time, operators will have access to STCW CoCs, that are very motivated to succeed in their new country of immigration.

When you start a business, you are committed to getting it off the ground, and moving an entire family a long distance is no different of an enterprise. This means that these immigrants to Canada will take any work, subpar conditions, and subpar wages, to make their “business case” succeed; I would too. This is a temporary blessing for ship operators; they will have access to a “pliable” workforce holding Transport Canada approved senior Certificate of Recognition – which is what they need to run their fleets – for now anyways.

The lack of changes to the Canadian CoC system is worrisome, and will be again the problem down the road, for these immigrants, once, they too, want to move up the ranks and / or get a full fledge Canadian CoC. Another words, we would just be “kicking the can” down the road; the same problems with Transport Canada “clunky” certification process that plagues Canadian trained Marine Engineers now, will also affect foreign trained ones, further down the line.

The impacts

In the meantime, it will be even more challenging for the “locally” trained Marine Engineers, who will not be able to upgrade, because it is just not worth the investment. After all, why would a fifty year old 3rd Class Engineer spend two years of intense family disruption, great financial burden, “just” to get a 2nd Class CoC, when there will be downward pressure on 2nd Class wages, because of a temporary influx of “young” Certificates of Recognition around?

I anticipate we are on the cusp of Transport Canada issuing Certificate of Recognitions as a matter of routine. This will only be a temporary relief to the shortage of Marine Engineer for seagoing roles in Canada. Until industry and Transport Canada address the underlying issues, there will always be pressure to find qualified engineers to sail ships in Canada. Transport Canada needs to streamline their certification process to the equivalent to other nations issuing CoCs. Industry, for its part, needs to increase their remuneration packages for engineer, to make the arduous process of upgrading their CoC, a worthwhile investment.

Of course, point of view hinges on the fact that the Government of Canada is indeed interested in keeping a "Canadian" fleet and its expertise; which from the signals I see from Ottawa, this is not an identifiable priority.

Monday, July 08, 2013

TC curtails certification on Island

TC HQ in Ottawa, Wikipedia
If you live on Vancouver Island, and required any marine certification assistance by Transport Canada Ship Safety, you will be required to go to Victoria to get your certification work done; or you may choose to go Vancouver or Prince Rupert. Effective July 2nd 2013, the Nanaimo office of Transport Canada Ship Safety will no longer process deck or engine examinations, issuance of certificates, endorsements, etc. 
Transport Canada is making the marine safety examinations cost-efficient by consolidating services in Victoria. The department will provide the same service as before but through one central location on the island. 

Jillian Glover, Transport Canada Spokesperson

The Nanaimo office has always been a busy one by all observations, apparently too busy, with comments that the inspection workload has gone up 500%. But with limited deep sea traffic, and no noticeable increase in local marine activity this explanation, seem to ring a bit hollow. The usual two front office staff has also taken retirements, at the same time, strangely enough. Seems to me that Transport Canada is just closing the office, maybe not "officially", but in practicality.

Well, you can't blame small fishing boat for increase in inspections - Source TSB of Canada
Even more curious, is that the Nanaimo office has had two engineering examiner on duty for many years, while the only Victoria engineering examiner has recently retired. I am told there is now a long time TC employee from the St Catherine's office, an engineering examiner, that has now relocated to Victoria, another is anticipated shortly.

One hopes that now that a trip to the TCMS office will take the better part of a day, we will not have to go four or five times to get what we need to earn our living. It is hard to get any information out of TC, and they certainly don't volunteer it, so the decision seems poorly advised from my perspective. At least as far as certification are concerned,  and the wages those certificates earn, vis a vis the cost of living in the capital regional area, one would say it would be more logical to keep certification services at the Nanaimo TCMS office.

Not to mention Victoria, has a physically smaller market of Canadian seafarers working in the area, as oppose to Nanaimo, less than two hours from Campbell River, Powell River, Port Alberni, Nanaimo, etc. All communities with vibrant working harbours and seafarers. Nanaimo - with its existing examination infrastructure - or even Campbell River would be more logical area for a Canadian Seafarer Certification office, certainly a more central area to better serve it's clients, than Victoria.

For me, as a TCMS client, this will cost me in time and money, and I cannot imagine what a persons in Port Hardy, or up island will have to go through to get a certification. Again this is not surprising to me, I have a distinct feeling that Transport Canada is committed to putting as many "stick in our wheels" as far as Canadian seafarers are concerned.

Below is the brief "official announcement" of the end of important seafarer certification services out of Nanaimo.
Consolidation of Transport Canada’s Marine Examination Centres on Vancouver Island

Effective July 2, 2013, Transport Canada's marine examination centres on Vancouver Island will be consolidated into one location in Victoria at:
501-1230 Government Street
Victoria, British Columbia
V8W 3M4
Phone: (250) 363-0394
Open Monday to Friday, 8:00 a.m. to 4:00 p.m. (except holidays)

Over the next few months, Transport Canada's Nanaimo marine office will continue to receive applications of certificate renewal and seatime assessment, which will be forwarded to Transport Canada's Victoria marine office for processing.

Clients in the Pacific Region will continue to have access to marine examination centres in Vancouver, Victoria and Prince Rupert.

Saturday, April 20, 2013

Highs and lows

May Edition now
on news stands
Toot tooot. There's my own horn.

BC Shipping News has picked an article of mine featured here, a few months ago, about the realities of the marine engineering training efficiency in Western Canada over the past twenty years. The piece, Reap what you sow, was the first part of my larger exercise, exploring the marine engineer workforce situation in Canada. The article is in the May issue of the magazine, coming out shortly; you can read the other articles I penned, over at the website, or on the main website, on the Ship's Library page.

I believe there is bound to be, if not already afoot, some major changes in the marine work force. For one instance, I was recently advised to keep an eye out on the Canada Gazette (a federal government document listing the changes to government laws and regulations). In particular, Transport Canada's changes to Marine Personnel Regulation, and the forthcoming recognition of foreign Certificate of Competency in Canada - CoR.

I am told this will entail a drop of traditional marine engineering assessment, per se, by TC Marine Safety. Additionally, I understand the Marine Emergency Duties "D" course, and the Propulsion Plant Simulator (PPS) course will not be required to get the CoR. Personally, I am not surprised at all, and see it as inevitable, after all, there has been no effective training program or support for Marine Engineers in Canada, to meet the nation's needs. That was the point of my article(s).

However, if you took those courses on your own, like most do, you will surely understand the ramification of such a move by Transport Canada. With the push for Temporary Foreign Worker Program (TFWP) visa and their ease of issue, and its great success for Canadian companies, our Canadian shipboard workplace is set for a major shift. The obvious result will be a further drop in wages, or at least a freeze for an indeterminate time frame. For those of us who have trudge in this very tough career path, laid out by TC and lacked support form Canadian operators and unions, for the last 15 years, it is a double kick in the gut really.

Never mind the taxpayer angle as well, a triple kick to the gut, since those temporary worker don't contribute to our communities or its tax base, and companies have low tax rates, guess who gets to pick up the tab. Great Economic Action Plan ! I don't like to be dire, but for some reason this seems so obvious to me, as it is sad. 

Jeez ! This entry started out so positive, arggggh.

Monday, March 18, 2013

On a wing and a prayer - Blue Riband

Source - Interwebs
I was visiting my friend over at Navcanada in Surrey, BC, getting a tour of the very impressive west coast air traffic control center. The "Center" handles the air traffic controlling duties of the many flights I take every year, so its nice to demystify it. The impressive tour of the new facility was fantastic, but one of the most memorable tidbit I took away from my visit was actually from one of the trade magazines, Skies Magazine, my friend had on his desk.
There was one article in particular that caught my attention. The article dwells on the plans of the College of Professional Pilots of Canada, and how they are attempting to created a self regulating body, much like Medical Doctors and Professional Engineers have access to; it is also a big dream of mine for Marine Engineers in Canada, as proposed in the Blue Riband project.

I was ecstatic to see this article, as the similarities between professional pilots and professional mariners are similar. Sort of a "Ah Hah" moment for me. I feel, like the professional pilots, that we are involved in high levels of bureaucracy, large of amounts of regulations, exposed to criminal sanctions and are, overall, a fragmented bunch, lacking direction and representation as a whole.

Logo of the CPPC
It is great relief for me to see a similar body of professionals, who are forging a bold step ahead for their profession. This illustrates the possibilities of a united and focused group, offering us a template for change to our own peer group. It is sad that our professions have taken such a "backseat" over the years. However it is very exciting to see that similar professionals have identified similar issues with their craft, and are working towards meaningful solution.

I am learning more about the group, and hope you will too. It may spur some brainstorming sessions. Perhaps serve as a catalyst to the possibility of change. You can read the excellent article here; and visit the CPPC's website here. Maybe you will be inspired by the CPPC and revisit Blue Riband, perhaps express your support or ideas on moving it forward.

Monday, January 28, 2013

Costs of being a marine engineer

credit - interwebs
A few weeks ago, I compiled a list of the steps required to achieving and maintaining a Transport Canada 1st Class Certificate of Competency. The list identifies the individual steps to hold a 1st Class and the associated cost not only in terms of money, but also in terms of time for training, in the “classroom”, and time served aboard a ship. I compiled one list for the Marine Engineering Cadet stream, and one for the so called “Alternate Path” stream, or “hawsepiping”.

No matter how you slice it, the path to becoming a Marine Engineer in Canada is not an easy one. It is very long and many requirements have to be met, to succeed. But it is clear that taking the Cadet path to 1st Class is the best option; costing about $25,500 dollars and taking about nine and half years to complete. The “Alternate Path”, is considerably more burdensome in the number of steps, and considerably more expensive, at $32,800 – 26% more. However it takes about the same time as the cadet stream, 9.2 years, to complete.

The data is compiled in its entirety, but some individuals may be able to find shortcuts to some aspect of the requirements listed, but overall, these “shortcuts” are quite minimal. The costs, as they are compiled neglect a considerable additional financial burden: the cost of housing, food, transportation, taxes, and such are not included in these summaries. With an expected time in school of over three years, this would represent a considerable financing challenge by an individual pursuing a Marine Engineering career.

Sea time served aboard a ship is also calculated as the necessary sea time, which does not include time off, or vacations. When these factors are considered, the length of time required to complete the program stretches considerably. The length depending on the type of watch, 8 or 12 hrs served on board, and leave rotation. Leave in Canada is mostly at day for day – or at least ought to be, so theoretically, the 6.2 years of sea time Transport Canada requires, could end up being twelve years in actual time.

These costs also ignore the elephant in the room, that is, the social cost of a career at sea. These affect individuals differently, but principally include social isolation, leading to social disorders such as substance abuse and failed marriages / relationships. The impacts to the support network that a seafarer is able to maintain, are also considerable. Children with absent parents and the impacts this produces are immeasurable. Impacts on spouses and their ability to function “normally” are also greatly affected by this career choice of their spouse.   

credit - interwebs
The purpose for me to compiled these lists were to ascertained whether the return on such a considerable amount of time, financial, and social investment are worth the returns. I recognize that the social cost is not readily calculatedly. It is also safe to say that the job satisfaction benefits are also not calculable. So the question becomes is it comparable to other professions or trades; I would propose not.

The sheer amount of requirements to be met is staggering, and requires a long time frame to complete. I estimate an initial salary in the range of $50-70k per year in Canada for a 4th Class with two years experience on the job. I further estimate the range for 1st Class to be around $100-120k per year, however, these latter figures are, if and when you do get a 1st class license, which takes at least 8-11 years after achieving a 4th Class.

If you were to weight options, perhaps a Red Seal trade, such as Diesel Mechanic, Millwright, Electrician, or even a police officer would, I suggest, would offer a more reasonable return on investment, than Marine Engineering would. Journeyman status is quickly reached, 2-4 years, with fewer initial and ongoing training and licensing requirements by comparison. I would suggest that they reach higher initial earnings, and more importantly, considerably less social impacts on the individual or their families.

I would suggest that Marine Engineer remuneration packages offered in Canada are currently inadequate to attract new Marine Engineer to the profession. In strict comparison to other avenues of post secondary education, an investment in Marine Engineering is a long term outlay of capital, with meager returns.

The remuneration situation also fails to recognize the current realities of seafaring and its impact on an individual’s ability to have a family, a basic human need. The ability to raise a family has many facets made more complicated, by the very specific and enormously taxing work requirements. These challenges are seldom anticipated by new entrants into the maritime world, until well into their careers. Therefore the overall remuneration for a career minded Marine Engineering professional, is woefully inadequate, particularly in Canada.

credit - interwebs
I would suggest a proper remuneration package starting at $95-120k per year for 4th Class to at least $200k per year for a 1st Class. This might seem like a large amount to employers, but I propose it is what it will take to address the stagnation of Marine Engineering wages since the 1980’s.

Those who are now retiring in great numbers, had their peak wage demands back then, and as their lives moved to post family one, their cost decreased. I theorize that they settled for marginal wage increases from ship operators since the 1980’s. However, this generation is now retiring, and in order to attract career minded professionals, the wages in this demanding profession will have to reflect the current realities – however dramatic that might feel like now. 

You can download the files from the main website (Ship's Library), or by clicking below...

Monday, October 01, 2012

STCW10 coming to Canada

SCTW10 rising from the deep

The next Canadian Marine Advisory Committee (CMAC) meeting is a little more than a month away - to be held in Ottawa, on November 6th through the 8th. Transport Canada, which regulates pretty much everything we do in Canadian shipping, and especially us seafarers, uses this medium to discuss changes in their policies and regulations.

They have proposed a long list of amendments to the Marine Personnel Regulations, those are the regulations that oversee the Training and Certification of Canadian seafarer. The amendments are there to address the recent changes to the Standards of Training Watchkeeping and Certification (STCW) of seafarer, as adopted by the IMO convention, held in Manila, June 2010. These are major changes to the STCW convention, and they are known as the Manila Convention or STCW10.

Transport Canada is obligated to introduce these agreed international changes into its regulatory framework. Many of the changes directly impact seafarers, right now, such as hours of rest / work; and these regulations are already in force, beginning 2012. There is further regulations which will impact Marine Engineer in particular, you can read about the proposed changes to the Canadian engineering certification system here

The biggest one for currently certificated engineers is the Safety Training, previously known as Marine Emergency Duties (MED) now has a validity limit. Meaning that the training, if not up to current standards will have to taken again. Refresher courses will have to be introduced at the maritime schools, to be taken every five years, and there is also some additional training introduced.

TC is introducing new Certificates of Competency (CoC) for deck and engineers; in particular...
  • Fourth-class Engineer, Motor Vessel, Domestic
  • Fourth-class Engineer, Steam Vessel, Domestic
  • Electro-technical officer
  • Small Vessel Machinery Operator, Steam Vessel
  • Able Seafarer engine
  • Electro-technical rating
 ...and new Certificate of Proficiency (training)
  • Basic Training for oil and chemical tanker cargo operations
  • Basic training for liquefied gas tanker cargo operations
  • Advanced training for oil tanker cargo operation
  • Advanced training for chemical tanker cargo operation
  • Advanced training for liquefied gas tanker cargo operation
  • STCW basic safety
  • Fast Rescue Boats
  • Survival Craft and Rescue Boats Other Than Fast Rescue Boats
  • Advanced fire fighting
  • Marine basic first aid
  • Marine advanced first aid
  • Medical Care
... and new Endorsements
  • Chief Engineer, Motor Vessel up to 2,000 kW, Domestic Endorsement
  • Chief Engineer, Steam Vessel up to 2,000 kW, Domestic Endorsement
  • Continuous proficiency in marine emergency duties
  • Endorsement attesting the recognition of a certificate
  • Air Cushion Vehicle (ACV) Engineer, Class I;
  • Air Cushion Vehicle (ACV) Engineer, Class II;
  • High-Speed Craft (HSC) Type Rating;
  • Air Cushion Vehicle (ACV) Type Rating;
Got a headache yet....?

By the looks of it, Fourth Class will now require the full Part A exams, including new ones like "Industrial Chemistry" and "Electrical, electronic and control engineering". Oh that's wonderful! I wonder where TC is going to get those exam questions out of the 1960's Reed's books. Third class will be required to do Simulator level 2 as well, typically this wasn't required until Second Class.

As I see it current Cadets should be relatively ok. Senior ranks - Second or First Class CoC holder will be hit with refresher courses, and additional requirements for maintaining their Certificate. The real problem will be for the "keeners" who have experience onboard, typically older, and are trying to work their way up in the field, upgrading to a Fourth Class or Thirds. These people, I think are really screwed, as there is no practical way they can move up now.

Of course, this group of ship's engineering staff have very few people talking on their behalf. The senior ranks, well, they have adjustments to make but overall not too bad, the unions may speak on their behalf. No matter how you slice it, these are extra burdens to achieve certification in an already challenging process.

TC reached out to the CIMarE, this is where I first heard of it, yesterday, even though these changes were proposed last CMAC in April. I run probably the largest web community of those affected; TC, email is relatively free - wouldn't hurt to let us engineers know.

Canadian Institute of
Marine Engineering
Ultimately, CIMarE is a volunteer organization, so their input is great, but at the mercy of many pressing issues affecting its membership, like putting food on the table. Unions, well, if history is any indication, I think will be absent from any meaningful input on this subject. Sorry young guys and gals wanting to be ship's engineers, your on your own.

The first time STCW was introduced, back in the late 1990's, I think it safe to say it was chaotic. In the US, it was downright scary. I don't think it will be as bad now that we are use to the STCW concept, but I predict a major slowdown in the Certificate queu at your local TC Marine Safety office, already running at high output and quality assurance levels  - sorry a bit of sarcasm there.

If you are in Ottawa in November, you are invited to attend. You can see all the proposed changes here, here are the really interesting ones, the changes to the Engineering certificates. CMAC's website is here, you can visit the CIMarE's website here, and discuss this topic on The Common Rail. Deckies, don't worry, you were not forgotten, you'll definitely want to look up how these changes apply to you.

Sunday, July 29, 2012

NA ECA: well, maybe

"proud to be stuck in 70's"
Transport Canada, last week, declared that they will not be be enforcing the North American Emission Control Area (NA ECA), which stipulated burning a lower sulphur fuel for ships, and which comes into force next week - August 1, 2012. The whole idea of the ECA is to reduce pollution and the impacts it has on human and planetary health.
" Due to significant additional discussions required with the domestic marine industry, the marine air emissions regulatory package will be delayed by a few months and will not come into effect on August 1, 2012, to implement the NA-ECA and standards for Canadian vessels operating in the Great Lakes and St. Lawrence waters.
Until the proposed Regulations come into force, there would be no means to enforce international standards under the NA-ECA to limit the sulphur content in marine fuel to 1%, which come into effect internationally on August 1, 2012.  As well, there would also be no means to implement new domestic standards for vessels voyaging in the Great Lakes and St Lawrence waters.
As a result of the above, interim measures are required for the period of August 1, 2012, to when the Regulations come into force, which is expected towards the end of 2012."
The above is a quote from Transport Canada; and means that if your ship is found to have fuel on-board, with a higher than the 1% sulphur content mandated, while in Canada's part of the NA ECA, you might get a stern verbal dressing down by a mean looking, but otherwise toothless Transport Canada inspector. Even more worrying, there is no firm date now on when we can expect implementation of the ECA in Canada. You can read the full Transport Canada Ship Safety Bulletin here.

Meanwhile, the USCG, jointly tasked with the EPA in enforcing the new regulations, have slightly more tonality in their enforcement "mean voice". They will be telling shipowners in US ports to comply.... if you want to... but don't go out of your way - like a pothead asking for chips from the 7-11.
"Duuuuuude! can you swing by to the corner store, and get me some chips and some low sulphur fuel? But you don't have to if you don't want to... Thanks bros"
Over in Alaska, the State government - which has dubious track record for taxing passenger ships there - the state government is up in arms that the cruise ship industry will be damaged by the ECA, and has file suit to have its implementation put on hold altogether.

I guess Canada's marine industry has a better connected lobby than in the US. I'm sure in some plush office, some are "high-five'n" each other over the success of this deferral of regulations.

Let me propose that a toothless enforcement agency creates an uneven playing field (well duh - that's the point). Sure "shareholder value", will rise a small fraction of a percentage point; someone may feel powerful that they have manipulated the regulators in their favour.

But this dilution of regulations, the watering down of regulator's mandate, is in my view, corruption of the system, and yet another short term solution that will yield bigger problems down the road. I know the mainstream media treats us like stupid lambs, but the fact is, the general population recognizes when an institution is corrupt or pandering. Over time, people will adapt and find creative ways of getting their goals achieve - we have seen this in California with CARB and other jurisdictions.

Over the past decade, shipping companies have been up at arms about ballast water management regulations. In several jurisdiction, news rules have "pop up", have been haphazardly implemented, circumventing the usual foot dragging "regulatory" channels, much to the ship owners laments.

I think the way ballast water management has been forced onto governments and ship owners, by legal action(s), is merely a preview of things to come. I propose that with out a strong, active, and unyielding regulatory regime that people can depend on, to protect the greater good's interest, those in shipping can only expect the unexpected down the road - and they will not have the right to be surprised. Perhaps, the seafarer criminalization trend is a manifestation of this populist apathy towards the ability of our institutions such as regulators to do the right thing, effectively.

The NA ECA has been on the table for some time. Yes, there will be cost to implement, but the idea is there for a reason - emissions have been linked to human health issues and do harm to our communal environment - whether you "feel it" or not, its just the way it is. If you dont believe me, go into the garage, start your SUV with the garage door close - then let me know the results after 15 minutes.

I am going to go out on a limb, and say that fuel sulphur limits are going to be the norm, on all waterways and oceans, in the very near future, I think it would be prudent as an operator to expect this instead of continuously fighting it.

Is an unstable and unpredictable regulatory playing field in the future, and its associated compliance cost and headaches, really worthy of a short term "win" for shareholders / industry ?

DNV's map of current and possible ECAs in the future
You can read more about the NA EPA, and its enforcement in the United States here.

By the way, if you got the Almost Live reference, your automatically "alright" in my books. ehehehe.

Tuesday, July 17, 2012

At least, its not the Grey List

Ocean Aventurer; maybe too much
Canada's flag is not on the Paris MoU's Black List or Grey List; but then again the flag is not on the White List either. The lists are issued by the Paris MoU, a group of 27 nations banding together to inspect 24,000 ships last year, in hopes of reducing substandard and dangerous ships.

Most of us seafarers know these inspections as Port State Control (PSC) inspections, and they are a tribute to various nations' faltering efforts to assure minimum standards of quality on the ship flying their nation's flag.

Despite 181 Canadian flagged ships, and another 225 ships owned by Canadian entities, Canada is not a resident on any coloured list, due to lack of representation in the participating PSC port's. A flag state needs 30 inspection in 3 years to make it into the ranking scheme.

North American media darling, Iran, has actually moved up to the White List, leaving Kazakhstan just above the USA on the Grey List. While India has also fallen into the Grey list form a previous White List standing.

What do these lists mean to us lowly seafarers? It means that if you are on a ship flying the flag of Germany, currently at the top of the White List, you can probably have a bit of shore leave on your next port call, since the PSC inspector will be less likely to target your ship.

The targeting of ships for inspection is based on experience; German ships have consistently had less defect findings than any other, so why waste precious inspection resources on these ships.  A high ranking would suggest a superior attitude towards safety and operational standards, by those shipowners and operators who fly the German flag. Kudos to them !

You can find the various year's lists here, from the Paris MoU website. The most recent list was issued last week, click here to view the press release, and here for a bit more backgrounds on the lists.  

MV Friendship is a good example of whats been "caught in the net". Transport Canada targeted this ship for Port State Control inspection, while on a port call in Halifax. The Maltese flagged, Greek owned vessel had a cargo of nickel aboard, and was classed by Germanischer Lloyd. Check out this beauty - from a white list flag, from a "high performance" RO (Class) - just imagine the Grey and Black Lists flags.

Saturday, June 16, 2012

Yet one more...

General Walter Natynczyk from CBC
Yet another news story of note, to me anyways, again from the Globe and Mail, one of Canada's national papers, is about the Canadian military's top dog, General Walter Natynczyk lamenting the lack of steel cutting for new ships. I know the military is used to getting whatever it wants, but hey, welcome to the party General; just imagine how the Coast Guard guys feel - have felt for the last 30 years.

For those of you keeping record, the National Ship Procurement Strategy's website had previously anticipated the signing of a firm order - ready to cut steel - in late November 2011, shortly after the decision of the shipyard selection in October 2011. The first contract was expected to be officially signed for the fisheries research vessels to replace the like of the WE Ricker, to be built by the Washington Group's yards in BC. It is now June 2012, and still no firm order on the books for the fisheries vessel or the Arctic Offshore Patrol Ships for the Navy. Public Works and Government Services has removed any mention of time frames for actual steel cutting from their website.

from Ferriesbc
The "latest" fisheries research vessel replacement project is more or less fully drawn up, from my understanding. Unfortunately, the drawings keep getting "revised" on a routine basis, to accommodate the falling budgets, pretty soon there will only be enough money left for an ex-BC Ferries lifeboat to be converted to fisheries research - that is of course if Transport Canada can get their act together.

Mind you, the way the ruling Federal Conservative party is going, the significant cuts to all thing "Science" - who need that superstitious bunch anyways - they may just skip this project altogether, and save themselves the hassle of budgeting for this, in these "tight economic times".

The NSPS is looking more and more, like a traditional Canadian ship building program, yet one more time, with yet one more voice expressing concern. Read the news story here.

Monday, April 30, 2012

TC needs you !

Transport Canada Marine Safety would like your input.

If you access Marine Safety's services, they are looking for some feedback on the length of time they should provide these services.

I thought it was a survey at first, but its basically a "comment card", you would find at your average franchise business, to put in that little wooden box hidden by the end of the counter. The way (or lack thereof) they explain it is not straightforward (big surprise there) so I fill it out thinking they had a bunch of survey question to follow. However this is not the case.

So I suggest you have a look at the program's website, and decide for yourself. Each topic has the amount day they aim to deliver in, if this is too long or short, use the comment card to submit your suggestion. i.e. Issuance of Medical Certificate, right now they target 120 days to give your medical, I think, and judging by discussions on The Common Rail forum, many of you also find this too long. So if you would like to comment on this time frame...

  • the feedback button, click "yes" - you want to provide feedback, then the "next".
  • Now comes a form page with a bunch of tick boxes matching the hierarchy of the areas they previously mentioned,
  • Find the one item - i.e. "Marine Medical Certificate", tick that box (The confusing  part for me is why they allowed choices - so many tick boxes... but I guess you might have a general comment that affect all)
  • Then fill in your "Group" your "name","association or company", info
  • Then enter your comment, i.e. here's what I put down "Seafarer Medical - These are critical to our ability to earn a wage. I think medicals should be issues within 60 days - max. Provisional certificates are fine, but they only last 6 months, and on a 3 month on / off schedule, you end up stressed because you will be kicked off the ship if no valid medical matches your license. Its fine in Canada, everybody know TC and their ways, but try explaining that to a PSC inspector in Hong Kong or Miami. "
  • Then you can enter your email for follow up information
  • Press submit
  • You can press home, to start a new form again, and submit a comment for another topic
I don't know why it seems a bit confusing for me, perhaps it the ISM audit we just went through, but I'm sure it will be for some others. Anyways, have a look and do provide input where you feel you should. It's so rare that anyone ever ask the seafarers for input, that we should not pass this opportunity up.

You can find the TC standards feedback website here, you only have until May 31st, 2012, to provided your comments through this medium.