from an ILM (one of the most common current Certificates) to the new Restricted Limits Skipper Certificate could end up anywhere from the most basic level of this qualification to more advanced levels, based on Maritime NZ's individual assessment of their "summary of sea service gained since attaining the qualification." Even if Maritime NZ follows the "indicative table" of equivalent qualifications provided in the original QOL proposal, most ILM holders will probably end up with a Restricted Limits Skipper Certificate endorsed to 24m. This represents a considerable reduction in privileges afforded by their original ILM qualification in terms of vessel size and passenger carriage and is clearly to the disadvantage of current ILM holders.
The most recent information on transition is particularly concerning because it sits uncomfortably with the Maritime Transport Act and with the original QOL proposal. Transition clearly entails some elements of revalidation (ie, refresher training, where sea time has not been maintained). This leaves open the question of whether evidence of medical fitness is required and whether applicants must also successfully complete a fit and proper person test. The latter is certainly required under the Maritime Transport Act when a maritime document is being issued. This suggests the application process is going to be more complicated and rigorous than the latest material from Maritime NZ suggests.
If transition does require something along the lines of a full revalidation, this raises the possibility that a number of skippers may lose their certificates and their livelihoods as a result of the transition. In some instances this may be warranted, but it also likely that there will be many borderline cases that will need careful scrutiny before a final decision is made. What happens in this event? Is there going to be an appeals process? Can the certificate holder continue to operate, while waiting for the completion of a potentially lengthy and litigious process? Clearly, this represents a risk to Maritime NZ, to skippers and to the maritime industry which has not been publicly considered and debated.
Questions can also be raised about the syllabuses for new non-
STCW qualifications, like the Restricted Limits Skipper. Have these even been started yet? Are they going to be available before the April deadline? If so, at what point are these going to be shared with the industry for comment?
Given the lack of obvious progress to date on these important issues and the imminent implementation date, two scenarios are likely: Maritime NZ can elect to push ahead regardless with a process that shows every symptom of being unduly complex, contentious and expensive for all involved, or it can complete the much-needed work on costs (transition and ongoing), risk management and curriculum development in a robust and timely manner. It will then be in a position to engage the maritime industry honestly, with the bonnet wide open and with the full price clearly marked on the windscreen. The latter approach will inevitably involve a later implementation date, but with a far better product. The shiny car will have been road tested and everyone will know what they are getting and what they are paying for. The NZMTA is going through a positive change at present, with a focus on developing stronger liaison with Maritime NZ and other stakeholders to improve the outcome of maritime regulations for operators. We feel confident that Maritime NZ, through its new directorship, will engage more positively with our industry to achieve this. Details on MTA membership packages and benefits are available on the website: www.marinetransport.co.nz Contact: Margaret Wind, Executive Officer, New Zealand Marine Transport Association on: 0800 667723 or +64 9 535 7702, email: info@marinetransport.co.nz
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