GENERAL OBSERVATIONS
The meeting will be chaired by Mr Brad Groves of Australia and vice-chaired by Mrs Mehte Medina of the United States.
It is anticipated that a maximum of 4 IFSMA delegates will attend the meeting but, as many will be conflicted during the week it is important that attention is paid to the staffing of the plenary throughout.
As with HTW 1 the volume of work is limited, with only 43 papers submitted, however there are a number of topics of interest to ship Masters in particular the revision of the guidelines on fatigue and the standards of colour vision. The sub-committee is expected to take on a greater amount of work once the new structures are “embedded”.
It is reported that three Working groups and two Drafting Groups will be established, namely;

Agenda Item 1 – Adoption of the agenda
No significant comment.
Agenda Item 2 – Decisions of other IMO bodies

Substantive issues are included in the main body of the agenda, however it is possible that issues may be subjected to detailed discussions. Increasingly this is taking place and therefore, it is imperative that close attention is paid and intervention made as necessary.

Agenda Item 3 – Validation of Model Training Courses

A number of delegations continue to have concerns regarding the content and suitability of IMO model courses. It is reported that some delegations are considering speaking up in plenary regarding courses that are not up to standard rather than allowing them to be passed to the Drafting Groups. Intervention is not likely to be necessary.

Agenda Item 4 – Reports on Unlawful Practices Associated with Certificates of Competency

Paper HTW 2/4 submitted by the secretariat lists reports received by the IMO on fraudulent certificates. The numbers are actually quite insignificant but it is likely that this is more a reflection on the level of reporting rather than a true representation of the scale of the problem.

Agenda Item 5 – Guidance on Model Course Development

Paper HTW 2/5 submitted by the United States attempts to address the concerns relating IMO model courses discussed under Agenda Item 3. It is felt that the paper does offer solutions to some of the issues so it is likely to be supported in principle.

Agenda Item 6 – Guidance for the implementation of the 2010 Manila Amendments

Attention is drawn to paper HTW 2/6 submitted by IMHA. This paper provides information on the outcome of the experts workshop held in Kobe, Japan to review the currently available options for vision testing and their validity. The paper identifies the need to undertake a study to identify the safety critical threshold for colour vison deficiency in seafarers undertaking lookout duties.
The proposal is expected to receive strong support although funding is likely to be an issue. If the study goes ahead, it is predicted that the outcome could be submitted for consideration by a subsequent HTW meeting as the basis for the revision of the minimum vision standards in table A-I/9 of the STCW Code. It is therefore recommend that an intervention is made supporting the IMHA proposal. If the proposal is successful then there will be opportunities to raise any other concerns relating to the vision standards at a later date.

(Allan to write speaking note)
Agenda Item 7 – Follow-up action to the STCW-F Conference resolutions 6 and 7
No papers submitted.
Agenda Item 8 – Role of the human element

Attention is drawn to paper HTW 2/8 submitted by Australia, Dominica, the Marshall Islands, IFSMA and the Nautical Institute. This document provides information on a proposed approach for the revision and update of the Guidelines on Fatigue. Commenting paper HTW 2/8/2 submitted by the UK fully supports the proposals and it is predicted that other delegations will follow suit and the paper will be forwarded to Working Group 3. Consideration may be given to attending the working group.
Paper HTW 2/INF.7 submitted by the ITF and the Nautical Institute also on the subject of fatigue. As an Inf. paper there is no requirement for this to be introduced but considering the small number of papers at this meeting it is likely that it will. An intervention should be made supporting the consideration of these issues in the working group.

(Allan to write speaking note)
Agenda Item 9 – Mandatory Code for ships operating in polar waters

The two papers submitted under this agenda item deal with training requirements under the Polar Code. Many Flag States feel that their current certification system already covers the training requirements of the Code so there it is unlikely there will be significant consequences for seafarers.

Agenda Item 10 – Passenger ship specific safety training

Attention is drawn to paper HTW 2/10/1 submitted by the United States. This is the report of the Correspondence Group on passenger ship specific safety training. Strong concern has been expressed by some delegations that the proposals contained within would water down the training requirements by replacing approved training with ‘familiarisation’ in some cases. This paper will be forwarded to the working group for further discussion.

Agenda Item 11 – Training in hot-work procedures on crude oil tankers
No papers submitted.
Agenda Item 12 – First outline of the detailed review of the Global Maritime Distress and Safety System (GMDSS)
No significant comment.
Agenda Item 13 – E-navigation strategy implementation plan

Concerns have been raised that many tasks raised under the E-navigation umbrella do not justify an output. It is therefore uncertain how this agenda item will be progressed.

Agenda Item 14 – Guidelines for shipowners and seafarers for implementation of relevant IMO instruments in relation to the carriage of dangerous goods in packaged from by sea
No significant comment.
Agenda Item 15 – Non-mandatory instrument on regulations for non-convention ships
No papers submitted.
Agenda Item 16 – Biennial agenda and provisional agenda for HTW 3
No significant comment.
Agenda Item 17 – Election of Chairman and Vice Chairman for 2016
It is widely expected that the incumbent Chair and Vice-Chair will be re-elected for 2016.
Agenda Item 18 – Any other business

Attention is drawn to paper 18/1 submitted by the secretariat which provides details on the new process for entry into force of SOLAS amendments. SOLAS will no longer change every 6 months instead amendments will be co-ordinated into a four year cycle.
Attention is also drawn to paper 2/18/2 also submitted by the secretariat relating to the MSC draft circular on ECDIS. This paper invites HTW to review the provisions related to ECDIS training and the use of simulators.

INTERVENTIONS

Agenda item 6, by IMHA

GUIDANCE FOR THE IMPLEMENTATION OF THE 2010 MANILA AMENDMENTS

Medical examination requirements, including colour vision testing.

Thank you Chair. IFSMA representing Shipmasters fully supports the paper submitted by IMHA. We have come a long way since colour vision tests were carried out on the River adjacent to this building over a century ago by a forerunner of one of our affiliated masters’ organizations. The work proposed is essential not only to ensure safety but that no person is wrongly denied employment in the shipping industry.

In addition to colour visions, it has been brought to the attention of IFSMA, that there appears to be an inconsistency between the interpretation and the application of the general eyesight requirements applicable to deck officers, as of 31 December 2016.

Under the STCW Convention and STCW Codes, Parts A and B, the 2010 Manila Amendments would seem to remove the capacity of flag States and their medical practitioners to grant exemptions in respect of the eyesight standards to persons who previously held such exemptions in accordance with the STCW Convention in force prior to the Manila Amendments.

If understood correctly, it would not after 31 December 2016 appear possible for flag States to grant exemptions to any seafarers, or to extend any exemptions in respect of eyesight tests to seafarers who have previously been granted such exemptions.

This may be construed as unintentional, as it may result in perhaps a large number of senior masters and seafarers no longer being able to hold a certificate of competency and thus not able continue their career and their service at sea.

We request this last statement recorded in the Report from this Sub-Committee.

Thank you Mr. Chairman

Agenda Item 8

HTW 2/8 by Australia et al. - ROLE OF THE HUMAN ELEMENT
Proposed approach for the revision of the Guidelines on Fatigue
Paper HTW 2/INF.7 by ITF - ROLE OF THE HUMAN ELEMENT
Seafarer Fatigue, Minimum Manning and the Mitigation of Fatigue

(procedurally only able to speak when discussion is opened up and/or after ITF paper as introduced)

Thank you Chair. IFSMA representing the Shipmasters fully supports the Paper submitted by the ITF and NI on the subject of fatigue which we refer to as “tiredness” or “sleepiness”. This is a serious issue affecting all seafarers not only masters, hence our co-sponsoring of paper 2/8 with Australia. We request that this statement is recorded in the Report of this Sub-Committee. Thank you Chair.

Tags: IMO HTW