Understanding SOLAS and STCW rules
Navigational ability has always been an essential skill for any seafarer concerned with reaching a specific place even in seas that are almost enclosed let alone on the open oceans. Regulation as to the abilities of navigators and the equipment needed on board have evolved by flag states over centuries. Today most of the regulations concerned with navigation on board vessels are found almost entirely within the texts of STCW and SOLAS but there are both flag and port state elements that will also need to be investigated.
Navigation as a subject is not covered by SOLAS until Chapter V and then most of the regulations are concerned with matters such as weather information, ice patrols, bridge layout, navigation warnings, hydrographic services, life-saving signals and ancillary equipment.
The carriage requirements for the key navigation systems such as radar, compasses and tracking systems do not appear until regulation 19 where they are laid out in a way that deals firstly with all ships and then the additional requirements that come with increased ship size as measured in gross tonnage. The divisions of ship type and size according to Chapter V Regulation 19 paragraph 2 are:
- 2.1. All ships, irrespective of size
- 2.2. All ships of 150 gross tonnage and upwards and passenger ships irrespective of size
- 2.3. All ships of 300 gross tonnage and upwards and passenger ships irrespective of size
- 2.4. All ships of 300 gross tonnage and upwards engaged on international voyages and cargo ships of 500 gross tonnage and upwards not engaged on international voyages and passenger ships irrespective of size.
- 2.5. All ships of 500 gross tonnage and upwards (2.6 details some duplication requirements)
- 2.7. All ships of 3,000 gross tonnage and upwards
- 2.8. All ships of 10,000 gross tonnage and upwards
- 2.9. All ships of 50,000 gross tonnage and upwards.
In some instance alternative ‘other means’ are permitted for certain requirements. When ‘other means’ are permitted under this regulation, they must be approved by the Administration (Flag state) in accordance with regulation 18. The navigational equipment and systems referred to in regulation 19 shall be so installed, tested and maintained as to minimise malfunction.
Regulation 19 2.10 covers the ECDIS carriage requirements and details the various dates of the rollout programme. Although there are two tranches of ships still to come under the regulation, there is a dispensation allowed to flag states that permits any vessel that is planned to be decommissioned within two years of the compliance date to be exempt from the requirements.
Under the SOLAS regulations, navigational equipment and systems offering alternative modes of operation shall indicate the actual mode of use. Integrated bridge systems shall be so arranged that failure of one subsystem is brought to the immediate attention of the officer in charge of the navigational watch by audible and visual alarms and does not cause failure to any other sub-system. In case of failure in one part of an integrated navigational system, it shall be possible to operate each other individual item of equipment or part of the system separately.
Performance standards for the various systems are laid out in numerous IMO documents are subject to changes from time to time. When the performance standards do change, it is not normally necessary to replace equipment fitted prior to the change of date but in some cases, ECDIS is a good example, a change in the performance standards may necessitate an adaption to the equipment fitted. When a new system or piece of equipment is added to the mandatory carriage requirements because of new IMO regulations, there is often a rollout programme which will see different ship types and sizes affected over a period of time. The most recent example of bridge equipment affected by new performance standards is the VDR for which new standards came into effect in June 2014. Part of this was influenced by the requirement for electronic inclinometers to be interfaced to the VDR and which have also had new performance standards published in July 2013.
Prior to that, changes to the regulations were mainly concerned with the introduction of AIS, LRIT and ECDIS and with the development of the e-navigation concept. E-navigation will be looked at in the following chapter but in the IMO’s own words its work is to develop a strategic vision for e-navigation, to integrate existing and new navigational tools, in particular electronic tools, in an all-embracing system that will contribute to enhanced navigational safety (with all the positive repercussions this will have on maritime safety overall and environmental protection) while simultaneously reducing the burden on the navigator.
The IMO says that as the basic technology for such an innovative step is already available, the challenge lies in ensuring the availability of all the other components of the system, including electronic navigational charts (Now in progress with the mandatory carriage of ECDIS), and in using it effectively in order to simplify, to the benefit of the mariner, the display of the occasional local navigational environment.
E-navigation would thus incorporate new technologies in a structured way and ensure that their use is compliant with the various navigational communication technologies and services that are already available, providing an overarching, accurate, secure and cost-effective system with the potential to provide global coverage for ships of all sizes.
Polar Code provides cold comfort
The IMO’s Polar Code which had been in development for several years is now a fact and its text has been distributed in RESOLUTION MSC.385(94) (adopted on 21 November 2014). As a consequence there is a new chapter XIV of SOLAS that enters into force on 1 January 2017.
One of the requirements of the Polar Code is for ships affected by it to have a Polar Waters Operational Manual (PWOM). The structure and aims of the PWOM have their own section in the Polar Code but with particular regard to navigation matters such as passage planning and details of the limitations of any equipment must be included. It may be that much of this information is already included in the safety management system of vessels that frequent Polar Waters and in such cases the procedures and instructions can be easily incorporated into the PWOM. For all affected new ships, it will be necessary for the ship operator to devise a PWOM perhaps using a template but bearing in mind that some information will be ship specific.
Although there is little in the Polar Code as regards additional navigational equipment there are requirements for certain additional items with a period allowed for retrofitting through to January 2018.
Navigation with magnetic compasses at extreme latitudes has always been difficult due to the proximity of the magnetic poles in both hemispheres. This is recognised within the Polar Code which requires all affected vessels to be equipped with two nonmagnetic compasses able to operate independently of each other.
This would seem to suggest the need for two gyro-compasses, but as German navigation specialist Raytheon points out ‘very close to the North Pole, even the gyro compass loses some of its accuracy. The gyro error at Spitzbergen (80 degrees N) is 2.3 degrees; at a latitude of 85 degrees north (300 nm from the pole) the error is 5.6 degrees. In the new Polar Code, therefore, IMO requires that for travel in latitudes above 80 degrees N a satellite compass must be on hand as well’.
There is also new requirement for ice training. Previously many of the ice specialist working on ships that operated in ice-infested waters were well qualified by experience but with little if any formal recognition of their skills. This will need to change but since there is little likelihood of any immediate surge in the number of ships operating in ice, the pressure on the few specialist training courses that do exist will probably not be too great for them to cope.
Initially it was planned that the necessary changes to STCW would have an effective date of 1 January 2018 but at MSC 96 in May 2016, it was decided to defer adoption of the new changes to MSC 97 next year and for the date to be altered to 1 July 2018.
Teamwork now a requirement
While it is the equipment that makes up the hardware of a ship’s bridge, safety in navigation is as much about using the equipment properly and communicating with others both on the own bridge and on other vessels. It is therefore not surprising that a large section of Chapter V of SOLAS is devoted to this sort of activity.
Most regulations governing crew numbers and duties are formulated by flag states although the competency of officers and ratings is governed by STCW. The latest version of STCW is the 2010 edition and although this came into force in 2012 there is a transitional period through to 2017 during which holders of existing certificates can continue to be covered by them before having to meet the new requirements.
Included in the 2010 version is a new requirement for bridge resource management for senior officers and leadership and management skills within their certificate.
Companies should be responsible for providing training in these areas where seafarers do not have appropriate training. Official casualty investigations frequently highlight the human factor as either the root cause or a contributory factor and consequently there is a movement within the industry to improve bridge team procedures and management. Under STCW 2010 Officers in charge of navigational watches must have knowledge of bridge resource management principles, including:
- allocation, assignment, and prioritization of resources
- effective communication
- assertiveness and leadership
- obtaining and maintaining situational awareness
- consideration of team experience
There are three means of demonstrating competence permitted and these are evidence of appropriate training, simulator training or approved in service experience. Beyond STCW and any flag state requirements there is no regulation currently that makes training in bridge team management compulsory because the requirement could be met by way of in service experience but failure to address known problems could be considered a non-compliance with a company’s safety management system and may be picked up on by a PSC inspection.
Under the IMO committee restructuring put in place in 2013, there is a new sub-committee reporting to the Maritime Safety Committee (MSC) that has taken over the role of developing regulation with regard to STCW and other codes and conventions. The Sub-Committee on Human Element, Training and Watchkeeping will address issues relating to human element training and watchkeeping, including minimum international standards for training and certification of seafarers and fishing vessel personnel. It will also deal with technical and operational issues related to maritime safety, security, and environmental protection, to encourage a safety culture in all ship operations including the issue of safe manning. Other work covers the review, updating and revision of IMO model courses; and promotion and implementation of the IMO’s human element strategy. The issue of safe manning is something that many believe requires an international regulation and should not be left to flag states to determine. This is a controversial issue and will be resisted by many flag states but a future rule change cannot be ruled out.
Working practices requirements are not all concerned with encouraging teamwork but address some more routine matters. Regulation 28 covers the requirements for maintaining the ship’s log. The regulation states that ‘All ships engaged on international voyages shall keep on board a record of navigational activities and incidents which are of importance to safety of navigation and which must contain sufficient detail to restore a complete record of the voyage, taking into account the recommendations adopted by the Organization’.
The recommendations referred to are contained in IMO Resolutions A.916(22). This regulation gives flag states the option to record the information in a different way than in the official logbook. Electronic logs are available from companies such as Kongsberg (K Log) and IB (Infoship ELB) among many others. These systems can automatically record speed and position at fixed intervals with other information being entered manually as required.
Not all flag states permit electronic logbooks and it should be borne in mind that Port State Control and other officials may at various times wish to inspect a ship’s log and difficulties could arise if information that they might expect to find in writing is missing. Regulation 28 also requires ships above 500gt engaged on international voyages exceeding 48 hours, to submit a daily report to its company giving position, course and speed and details of any external or internal conditions that are affecting the ship’s voyage or the normal safe operation of the ship.
This requirement is one that most sensible operators had in place long before it became an official requirement. The report may now be sent by automated means with many operators taking advantage of tracking services offered by specialist providers that also make the information available to charterers or, in the case of liner vessels, shippers and receivers