Sea service aboard warships

Watch keeping time aboard all warships will be acceptable, where applicable, for commercial qualifications. Part 32 currently has four definitions for NZDF vessels:

• military commercial ship
• military ship
• naval ship
• warship.

It is planned to consolidate these in an amended Part 32 to:

• military commercial ship
• warship.

In the proposed framework, qualifications #5 (largely existing NZOW but for vessels >24m and <500GT) and #6 (existing NZOM) will become full STCW qualifications when the rules are amended. These will require appropriate sea service. As these are STCW qualifications we can determine the proportion of approved sea going service allowed aboard “non-STCW ships”.

The new Skipper Coastal/Offshore <24 metres (qualification #4) is non-STCW and equates to the existing NZOW with ILM endorsement. All required sea service must be gained while holding SRL aboard commercial ships in a deck capacity. Service aboard ‘military commercial ships’ would be recognised.

For OOW <500 GT near-coastal, evidence must be provided of having completed:

1. 36 months’ sea service in a deck capacity aboard commercial ships 12 metres or more in length, of which 18 months must be obtained outside restricted limits aboard non-fishing vessels; or
2. a training programme, including 12 months’ sea service aboard commercial ships 12 metres or more in length, operating outside restricted limits in a deck capacity aboard non-fishing vessels, 6 months of which must be obtained outside restricted limits.

For this qualification, time spent aboard ‘military commercial ships’ would be treated as having been gained aboard commercial ships.

For Master <500 GT Coastal (qualification #6), 12 months as officer in charge of a navigational watch is required while holding OOW <500GT near-coastal. Such watch keeping service would be acceptable aboard a ‘military commercial ship’. It is proposed that watch keeping time aboard warships would be acceptable to a maximum of 6 months plus at least 6 months’ experience as OOW aboard commercial trading ships.

MNZ would continue to accept RNZN courses or certificates for OOW <500 GT near-coastal, Master <500 GT Coastal and Master <500 GT near-coastal as long as they fully met STCW requirements.

Sea going service, as defined by STCW, will be recognised aboard ‘military commercial ships’ in the ratios currently in Part 32 for OOW Unlimited upwards. This continues to recognise that such ships are very similar to merchant ships in their activities. Where the rules currently require sea service to be gained in the capacity of an officer in charge of a navigational watch (eg, Part 32.17(2)©(i)(bb) for OOW); where ‘military commercial ship’ is mentioned it would also include a ‘warship’.

Experience aboard warships of all types is unaffected by the review for marine engineering qualifications.

However, having said all the above, it must be pointed out that we are bound by the existing rules until we amend Part 32. This process is anticipated to be completed by 01 April 2013, when new qualifications will be available and required, and the transition from old to new ones will start. The best advice regarding sea service, and the changes summarised above, is that existing naval personnel working towards STCW qualifications should keep a very good record of their sea service, if aboard a “’military commercial ship’, or their watch keeping time if aboard a ‘warship’, as these experiences will be recognised towards the appropriate new qualifications.

Sea Service - response to question

Question:
Can you please tell me how many hours one of my junior staff (an SLR holder) must actually stand on board a “relevant” vessel before achieving the entry level qualification to be skipper of a 14m pilot boat or a 22m tug?

The previous rule, for example, would not allow more than 8hrs in any day. My staff all work 12hr days (shifts). On some days they may be all of 12hrs on the vessel. On other perhaps not. Nobody in the ports industry lives on board any vessel 24/7 and in a number of ports including Auckland, the vessels are entirely unmanned unless in use.

You have defined sea service as service on a relevant vessel for the qualification.

You have also said a candidate must complete 100 hrs aboard and a task book to go from QDC to SLR <12m and < 12 pax.

You have then said a candidate must achieve six months sea service to advance to >12 pax AND <24m.

• What do you mean by six months sea service?
• Does a month = 30 days (more or less)?
• Does a day = 24hrs or 12hrs or 8hrs?
• Does the sea service; time spent on board a relevant vessel, equate to 6mths x 30 days x 24hrs = 4320hrs?
• Does it equate to 6mths x (30 x 8hr days) = 1440hrs?

Response:

A prescriptive ‘8 hours per day’ does not always reflect the amount of sea service acquired; this point was raised during the consultation process – particularly by port companies.
Regarding all STCW and non-STCW qualifications, we will publish guidance on sea service in the Advisory Circular to the amended rules. Until then, here are some thoughts on how we might define and accept sea service:
STCW refers to sea-going service in months, with the definition of a month being “a calendar month or 30 days made up of periods of less than one month”. Part 32 currently defines a month as “30 days”; it is likely the rule will be amended to reflect the STCW definition. This is sea-going service and includes time when the ship is in port. A maximum of two months for OOW can be claimed when the ship is undergoing repairs or survey.
The rules currently refer to months of sea service for all qualifications.
However, regarding the breakdown of months for port company vessels, advice on the Maritime New Zealand website currently gives the following criteria for sea time.

How is sea time calculated?
As a rough guide:
• 125 hours commercial sea time is one month’s sea service
• 500 hours recreational time is one month’s sea service
Please note that eight hours (commercial or recreational) is equal to one day.


Some people work more than 8 hours in one 24-hour period, particularly within restricted limits, and some mechanism is needed to recognise this. Clearly 24 hours a day is unacceptable and we would be hard pushed, for example, to accept 12 hours a day for a continuous seven-day period. We could accept sea service when the person is aboard the vessel carrying out tasks associated with the operation or management of the vessel but couldn’t accept time on standby in the office, or at home.
A possible way of dealing with the matter when there are no clear limits on hours of work, as with STCW, would be to have normal criteria such as 8 hours per day, but the ability to accept more than 8 hours if the hours of work are clearly being controlled by the vessel’s fatigue management plan and the roster of the individual.
Another thought is that it may be preferable to refer to hours of sea service for all non-STCW certificates rather than months and in that case, the 6 months’ sea service required to progress from SRL <12m to SRL >12m would comprise 750 hours.
It would then be possible – if someone was averaging more than 8 hours per day – to move on to the next endorsement sooner.