RV Mirai Arctic Mission 2014 Post #10 - The Polar Code - Better Sense Prevails at IMO?

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While wearing one of my other hats, as Senior Vice President of The Nautical Institute and member of The Institute’s NGO delegation to IMO, I am very much focused on the Polar Code as it progresses through it’s latest re-incarnation. As soon as I disembark RV Mirai in Yokohama, I fly to London to participate in the IMO MEPC discussions related to the Polar Code. My involvement goes back many years however, to the mid 1990’s when I was part of the team the developed the first proposal for Ice Navigator requirements for inclusion in the first attempt at a Polar Code.

Canada then had a very robust Arctic shipping focused shop in Transport Canada and under Victor Santos Pedro submitted the comprehensive Ice Navigator Position Paper. In that document was the first attempt to define an Ice Navigator and to lay out the skills and knowledge required of a ship’s bridge officer to safely navigate in ice infested waters. In addition well laid out model courses were developed and included. That attempt at IMO did not go far, resulting only in very basic, some would say vague, Guidelines for Ships Operating in Arctic Ice Covered Waters. After a number of very newsworthy incidents in Antarctic waters, the guidelines were extended to Antarctic waters but remained voluntary and quite loose.

Only recently as global interest is growing in the possibility of increased shipping in polar waters, the IMO under the strong leadership of the Secretary General has taken on the task yet again of attempting to put in place a MANDATORY Polar Code to provide a uniform basis of international regulation governing ship construction for and operation in polar waters. Not only would the new code be mandatory, but the Secretary General put a deadline for implementation of 2016. A tall order to ensure all the details were ironed out by then.

Those that have read my musings in the past know of my disappointment as the Polar Code discussion have slowly laboured on. To many involved it soon became apparent that a very robust and meaningful Polar Code would be sacrificed in order to meet deadlines. We have seen successive drafts become more watered down as the various working groups, sub-committees and committees seemed to simply walk away from and delete any item that did not result in complete consensus amongst the huge number of voting flag states and non-voting NGOs at IMO. One of those items that seemed to be tossed aside was what at first was a robust and meaningful chapter on training and certification of seafarers operating ships in polar waters. Chapter 13 of the proposed code soon became a shadow of its former self.

In the first drafts of the Code, Chapter 13 was a robust section with several very meaningful requirements for training and certification of bridge watch officers recognizing that operating ship’s in ice, and in particular polar ice required skills, knowledge and competencies far outside what are within the experience of many of the world’s mariners. Several countries, Canada, Russia and Norway included, had initially submitted to have clear Knowledge Understanding and Competencies (KUP’s) included within the chapter. Those drafts recognized that it takes decades to gain the experience to truly understand polar ice, and a simple training course provides only academic knowledge, and perhaps some decent hands on simulator time.

Slowly the defined list of KUP’s, possible requirements for certification of bridge watchkeepers as Ice Navigators and the allowance for operators to hire specialist Ice Navigators to provide experience that was otherwise lacking in their regular officers were either deleted or tossed over to other committees such at STCW to consider. To be fair, perhaps the detail of training and experience would be better covered in amendments to STCW, however, that meant delays and more possibility to decrease the focused attempt to get ice navigation standards front and centre. The last draft of Chapter 13 deleted completely the allowance for the “additional person” and reduced the training requirements to a table that broke requirements for undefined basic and advanced training into groups identified by ship type and presence of ice. From this humble mariner’s opinion that table did little to ensure that bridge officers would have sufficient knowledge and experience to safely operate in polar ice, but gave ship owners and operators a way to simply “meet the intent” by sending them off to a course somewhere (or even worse using an computer based training program) and checking off a box.

I am happy to report however, that better sense does appear to be prevailing. STCW seems to be getting serious about the KUP’s for ice navigation. After deleting the provision for additional persons or Ice Navigators several flag states have submitted documents to IMO for discussion at Maritime Safety Committee MSC94. Canada and Marshall Islands have joined together in document MSC94-3-10, United States has submitted MSC94-3-4. Both these documents aim to reinsert the allowance for vessel operators to employ additional persons, Ice Navigators to bring to a ship and its Master that may not regularly operate in these ice regimes and thus have met the IMO training requirements. The Ice Navigator in no way subverts the Master of his hierarchy of command, but becomes a part of the bridge team that enables the Master to make the right decisions.

This is not a done deal. A number of flag states fought strongly against the allowance for Ice Navigators, I believe, not fully understanding the utility of the concept that has been proven in many years in Russian and Canadian waters by regulation, and in American waters by tacit approval of the concept.

The Ice Navigator is not a pilot, but an additional resource that joins the bridge team bringing specialized skill, knowledge and competence that adds to the team. We still need to convince some of the flag states and even some of the NGO’s at IMO that Ice Navigators should be part of the Polar Code, their role defined and clear, and enforceable standards are set down for certification and training to ensure shipping in polar waters goes forward safely and efficiently.

6 Oct 2014

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