National Union of Rail, Maritime & Transport Workers
RMT response to Consultation on changes to MCA Survey and Inspection Marine Office Locations
Introduction
The National Union of Rail, Maritime and Transport Workers (RMT) organises seafarer ratings working in the domestic short sea shipping sector, predominantly passenger and freight ferries and offshore supply vessels but also including the Royal Fleet Auxiliary, passenger cruise ships and marine research vessels. We represent nearly 6,000 UK seafarers working at sea today, predominantly as ratings in the catering, engine and deck departments.
RMT welcome the opportunity to respond to the MCA’s consultation over the future organisation of the national network of Marine Offices and the working practices of the Survey and Inspection team in the MCA.
Key points
The union’s submission makes the following key points:
· The proposed net reduction of seven Marine Offices between 2014 and 2019 is a risk to the MCA’s survey standards and the provision of seafarer services.
· The loss of the Tyne Office would be particularly damaging, given the estimated 8,000 annual ship movements at Tyne Port and Tees Port alone and its status as the busiest Marine Office for seafarer oral exams.
· Between 2009-10 and 2015-16 the number of seafarers using the Marine Offices network to keep their certification updated increased by 30%.
· The proposed location of the new network of Marine Offices overlaps with the MCA’s earlier reforms to the UK Coastguard.
· The proposal to effectively privatise international strands of the MCA’s survey and inspection role is a serious threat to high regulatory standards with which the MCA, the Red Ensign and the Red Ensign Group is rightly associated.
Marine Office network
RMT believe that the Marine Office network is a vital link between port communities, seafarers, ship owners and MCA Surveyors. There is considerable potential in the MCA’s proposals for the historic link between port communities and the shipping industry to further diminish, especially in areas of high unemployment, such as Plymouth and north east England.
More practically, we are concerned by the potential loss of local knowledge of ports infrastructure and the regulatory requirements attending shipping movements, particularly in the offshore supply and cargo sectors.
The loss of the Tyne Office would be particularly damaging, for a number of reasons and the following facts support our case for the retention of a Marine Office in Newcastle.
· The Tyne Marine Office covers the coastline from Berwick to Whitby, covering the Ports of Berwick, Blyth, Tyne, Sunderland, Seaham and the Tees.
· Teesport has over 5,000 ships call per year and is a one hour drive from the existing Tyne Marine Office. As a result, Teesport is the most frequent port visited by the MCA for Port State Control inspections and surveys.
· The port of Tyne sees 3,000 ship visits a year, totaling 26 million tons. Again Port State Control carries out frequent inspections at the numerous berths and the river Tyne.
· The Port of Sunderland has dry dock facilities, crucial to the maintenance of a diverse range of shipping, particularly in the offshore supply sector. Again, the MCA again frequently are requested to attend the port to carry out surveys.
· Tyne Marine Office has the highest number of members of MCA Survey and Inspection team based in the Marine Office network.
· The Marine Office is located just inside Port of Tyne dock gates. It provides valuable services to local seafarers through walk-ins for advice on legislative, certification and operational matters.
· Workers in the fishing industry are also reliant on the Tyne Marine Office for guidance on a range of matters affecting their industry.
· It is estimated that the Tyne Office currently receives at least three new cases per week of seafarers seeking guidance on updating training certification and qualifications to comply with changes to the Standards in Training, Watchkeeping and Certification (STCW) due to come into effect on 1st January 2017.
· The Tyne office handles the most seafarer oral examinations across the Marine Office network. Last year, it handles over 1,200 and has carried out nearly 7,700 since 2009-10.
· Like many other Marine Offices it also provides a counter service to cater for issues such as discharge books, seaman’s cards and other certification, which can be turned around in one hour.
Following its discussion of the MCA’s proposals, RMT members in the North East Shipping Branch made the following comment:
“The Branch feel the closure of the Port of Tyne office and opening an office a Bridlington will open the North East coast to be exploited by shipping companies when inspectors maybe working from home and do not have a central centre to coordinate their inspections and monitor shipping movements along the North East coast.”
The national union reiterates the call from the North East Shipping Branch for the MCA to keep the Tyne Office open.
Seafarer services
Data relating to the existing Marine Office network contained in Written Answers to Parliamentary Questions (and not in the MCA’s consultation document) provide a clearer picture of the significance of Marine Office services for UK based seafarers.
The information[1] reveals that the number of seafarers using Marine Office services between 2009-10 and 2015-16 jumped by nearly 1,400, an increase of 30%. As stated above in the case of the Tyne office, we accept that some of the recent increases will be due to seafarers updating or checking compliance of their training qualifications with the amendments made in 2010 to the IMO Convention on Standards in Training, Watchkeeping and Certification (STCW) due to come into effect internationally on 1st January 2017.
It is clear, however, that international maritime regulations affecting seafarer qualifications are subject to regular amendments and the introduction of the ILO Maritime Labour Convention in 2014 provides minimum employment and safety standards for all seafarers working in the shipping industry. It is therefore essential that the Marine Office presence continues in maritime centres that retain a high number of seafarers working in the industry, such as north east England.
In addition, the key issue of seafarer safety is also addressed and better maintained when an open and active Marine Office is available to service the needs of MCA Surveyors discharging the UK’s Port State Control responsibilities. With 18 members of the MCA Survey and Inspection team currently based at the Tyne Marine Office, it is clear that a permanent S&I presence in the port and north east England region is essential.
Maritime Coastguard and Rescue Co-ordination Centre estate
As the following tables demonstrate, the MCA’s proposals for a reformed Marine Office network echo, in some cases the locations of the reformed Coastguard estate.
UK Coastguard & maritime rescue co-ordination centres 2016
1. Aberdeen Coastguard operations centre
2. Belfast Coastguard operations centre (Bangor)
3. Dover maritime rescue co-ordination centre
4. Falmouth Coastguard operation centre
5. Holyhead Coastguard operations centre
6. Humber Coastguard operations centre (Bridlington)
7. National maritime operations centre (Fareham)
8. London Coastguard office
9. Milford Haven Coastguard operation centre
10. Shetland Coastguard operation centre
11. Stornoway maritime rescue co-ordination centre
Closed Coastguard stations: Forth, Clyde, Great Yarmouth, Solent, Portland, Brixham, Liverpool, Swansea and Thames.
Network of Marine Offices proposed in March 2016 MCA consultation (bold indicates where Coastguard/Maritime Rescue Centre also exists)
1. Southampton
2. Dover
3. Ipswich (New)
4. Bridlington (New)
5. Liverpool
6. Falmouth
7. Cardiff
8. Glasgow
9. Aberdeen
10. Belfast (Bangor)
Closed Marine Office locations: Brixham, Leith, Newlyn
Earmarked for closure in the Mar-Apr 2016 MCA consultation: Tyne and Plymouth (2017); Beverley, Orpington, Harwich (2018) and Norwich (2019).
In addition to the union’s concerns over the complete loss of maritime rescue and administration services in places such as Brixham under the MCA’s reform programme, RMT would like to know more about the MCA’s plans to share services, especially IT or other joint working between coastguard and Marine Office services proposed at Dover, Bridlington, Falmouth, Aberdeen and Bangor.
MCA Survey and Inspection outsourcing
RMT recognise that there may be scope for a more mobile Survey and Inspection team in the UK, although this depends heavily on the quality of IT services that the MCA procures for its S&I team when they are on the road.
RMT do not, however, support the consultation’s proposals for outsourcing international S&I tasks to Red Ensign Group administrations and private sector ‘recognised organisations.’
In the case of the REG administrations, RMT has long standing concerns over the effectiveness of the MCA’s own inspection regime for S&I and other statutory duties conducted by maritime authorities in the REG. We cannot accept such a change under the current arrangements which see the MCA going out every 4-5 years to audit safety inspections and other duties of REG administrations.
We share our sister union Nautilus’ opposition to the proposal for increased use of the euphemistically termed ‘Recognised Organisations’ in discharging the UK’s S&I of tonnage registered under the Red Ensign. These RO’s are usually private sector classification societies that will have an existing relationship with the ship owner which would clearly lead to conflicts of interest, to the detriment of the UK Register and seafarer and passenger safety.
1
[1] Written Answer 19th April 2016 to PQ 33599.