MPR2019 on the horizon, finally

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Re: MPR2019 on the horizon, finally

Postby Shame_on_TC_2017 » Sun Nov 11, 2018 4:14 am

Also what training courses are required for an ETO officer. The first ssb that was canceled mentioned a diploma in automation and control or an electrical engineering degree as options that together with a marine medical and standard COP’s would meet the requirements for an ETO license to be granted.

This discussion paper is less clear than the canceled ssb about what programs meet the requirements for an ETO COC

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Re: MPR2019 on the horizon, finally

Postby TDC » Thu Nov 15, 2018 6:51 am

I'm Glad this is getting sorted out, been dragged too long.
I do have one area which I am not 100% clear on and was hoping someone on here would be in the same boat so to speak and may be able to shed some light. If a marine superintended/technical manager who has previously under the old MPR attained enough sea time to write first class exams previous to moving into a shore management role ,but has not completed the 1st class certificate can this previous sea time still be used to write first class exams or attain the new stcw chief certificate. Under the old MPR I was under the impression that sea time did not have to be attained within a 5 year period however in the new proposed STCW it looks like a Marine super with 2nd class will have to go back to sea to go from second to first class or as they call it the new chief unlimited or above 6000kw. For most people this is not an issue as most follow the ranks to chief before becoming a shore manager, and there is allowance for certs to be renewed with shore side service. However with that said I'm unclear on if shore side service can be considered to upgrade. Any advice?

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Re: MPR2019 on the horizon, finally

Postby The Dieselduck » Thu Nov 15, 2018 11:33 am

In earlier post I attached the full document, which I found a little much to digest, so I broke the 183 page document down into parts you can download and absorbed more readily.

2018.11-MPR2019 Div 1 - General Provisions.pdf
(211.9 KiB) Downloaded 54 times


2018.11-MPR2019 Div 2 - Deck.pdf
(344.06 KiB) Downloaded 56 times


2018.11-MPR2019 Div 3 - Engineering.pdf
(221.41 KiB) Downloaded 111 times


2018.11-MPR2019 Div 4 - Ratings.pdf
(162.61 KiB) Downloaded 45 times


2018.11-MPR2019 Div 5 - Endorsements CoP.pdf
(282.42 KiB) Downloaded 52 times



This caught my eye, as to WTF does this mean? Short and sweet, but with possible heavy ramifications. Again, perfect for when Canada ditches cabotage, a fly by the seat of your pants alternative certification process will allow government owned ships to continue sailing outside Canada if need be?

2018.11-MPR2019 Div 7 - DND CCG.pdf
(167.13 KiB) Downloaded 57 times



This is an interesting part, referring to the TP2293 considerably, but which holds the most potential for us "in the pipe" of upgrading CoC. The upgrading process is somewhat laid out, but it is not clear and leaves allot to be desired.

2018.11-MPR TC Eng Assesment.pdf
(170.31 KiB) Downloaded 79 times



I see this theme several time throughout the document - accepting foreign training at par, which is a pretty slippery road as far as I am concerns, especially reinforced with the provision to provide dispensation for foreign CoC on Canadian ships for up to six months, under special circumstances. I think I know where that's leading and who's asking for it, and I can certainly imagine what the exceptional circumstances will be.

2018.11-MPR2019 Non Cdn CoC dispensation.pdf
(137.18 KiB) Downloaded 48 times


2018.11-MPR2019 Safe Manning Eng.pdf
(171.05 KiB) Downloaded 39 times



The bulk of the documents is the implementation of the Marine Labour Code - which there is some language there that looks to be from the international text, and stipulates many good things, but again, seems to point to a system where, if we take a look at the big picture, aims to set up quick and dirty regulations so when cabotage is dead and gone in Canada, such as expected and heavily championed by both major political parties in Canada, the basic framework for non canadian to work in Canadian waters will be there.

2018.11-MPR2019 Maritime Labour Standards.pdf
(371.49 KiB) Downloaded 36 times


I still take the stand that I don't really care if you do all these great for shippers initiatives, but level the playing field for seafarers as well. It looks like we will still have to jumps through a myriad of hoops to move up with Canadian CoCs, meanwhile non tax paying, non Canadians trained CoC will undercut us with the help of Canadian government, just makes no sense.

I'm I naive enough to think that every one can win. What is with this obsession to kill our profession and sink us as much as possible, what drives the Canadian government and its myopic string pullers to do this? There is ample opportunity for Canadian seafarers worldwide, if we could just have a level playing field.
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Re: MPR2019 on the horizon, finally

Postby Nova636 » Sun Nov 18, 2018 4:34 pm

Hello, I hope that everyone is able to digest this information and understand how it will effect them.
I know I have more questions then answers and was wondering if anyone could give me some information on where I stand.
I presently hold a 3rd class marine ticket with a chief engineers endorsement. I have been sailing on Tugs (3728kw) and a fishing vessel (2300kw) as the chief engineer. From my readings on this form, the certificate that I will receive is the "Officer in Charge of an engineering watch," which will be a combination of a 3rd and 4th class ticket.
My concern is how this change will effect the safe manning certificates, as I am pretty sure I will no longer be qualified to do my present jobs?
Just hoping somebody read this a little differently and does anyone know when they may come into effect?

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Re: MPR2019 on the horizon, finally

Postby geezer09 » Thu Nov 22, 2018 9:10 am

Did anybody attend the Transport Canada consultation in Vancouver this last weekend concerning the changes to the MPR?

I was really hoping to attend but couldn't make it. Any comments on how this went would be appreciated by alot of people on these forums I am sure.

Personally, I am more concerned on the changes to the ticket upgrading procedure and a more accurate ETA for the comming into force of the new MPR. Anything general insight on this would be appreciated. More specifically, was it discussed if someone with a 4th class ticket will have to go back to school to upgrade or will he still be able to study on his own and challenge exams?


This has been said before, but, having recently come out of a cadet training program and with insight on the current state of at least one of these schools, i will say it again :

As soon as these new regulations come into force, anybody holding a 1st Class ticket will see the value of their ticket plummet. One year in school and 10K tuition will get you a chief ticket. From my limited experience, currently approx. 10% of holders of a 4th class are capable of upgrading to 1st class, this will shift to 90%.

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First consultation session report

Postby The Dieselduck » Thu Nov 22, 2018 10:42 am

I attended the MPR2019 consultation session in Vancouver, this past monday, November 19, 2018. It was a lively discussion, and the panel was made up of the guy actually drafting the text, one deck side and one engineering consultant to that process and the overall person responsible for the project.

• Elisabeth Bertrand - the boss
• Scott Weatherdon - Drafting
• Bernard Leclerc - Engineering
• Mario Lavoie – Navigation

They were open and helpful in explaining the process, and made notes to take back to the drafting table. The MPR2019 is a living document right now, and is changing - being refined - constantly from what I am told, based on feedback and such, and will not look like the document above. The timeline is set and is currently on target for Summer 2019 implementation.

I recorded the whole day's discussion, and I will upload the engineering part of it, when I can access good internet.

Here are my notes from his presentation
Bernard Leclerc – Engineering after lunch
• Explain that’s system is changing, but it’s just a change in titled
• Discussion on ETO and HV training, some confusion about how to roll out with IMO
o HV training to be accepted from non cad training
o HV is 1000V
• There is some discussion about transition, lots of grey areas. But will continue to work on the same capacity.
• Some discussion on grandfathering of 4th class, nov 2017 TC SSB only if part a was started before. ???
• Leadership and management experience will be for maintaining CoC, but if wanting to upgrade CoC will have to do training at approve course.
• Flow chart discussion.
• Sea time issues in charge of watch,
• Steam ship is a mode propulsion, even is auxiliary plant if considerable
• 75 months of seat time current mpr, proposed seatime to CE will be 50 months. Not quantity of sea time going for quality.
• Renewal time frame is a bit of a red herring, 12 month sea time in charge of a watch in five year.
• Sea tie issues are dominating, and are to be cleared up, very confusing
• Industry wants the 6000kw so TC is obliging, any second to get that endorsement
• Level 1 and level two – operational and management level;
o No more orals
o Multiple choice, or sketch and describe, no sure yet. For part B. Suggest one exam with EKM and EKG.
o Part A – program will be exempted. Cadet program 2014 after, exempt to CE
o Bridging course, management course 8 month at Georgian, BCIT is getting a bridging from cadet prior to 2014 program to CE
• Method of delivery will be crucial when the course is approve, and may exempt course taker to be exempted from TC assessment


The important piece missing, especially for us engineers, is that "nuts and bolts" of the actual CoC process. This is currently stipulate in the Transport Publication 2293 the certification of seafarers. This document and several supporting ones, are being extensively revised and will stipulate the CoC process in details. Using this vehicle, TC will be able to tweak the process in the future without huge delays.

In general i get the sense that Marine Engineering in Canada is on a very slippery slope. The introduction of new power limits at the behest of industry - primarily 6000kw (which will need a second class to be chief) in domestic waters, and the increase use of SVMO will really erode further our ability to nurture talent and provide paths of progression, making the whole idea of a career in marine engineering even more obscure.

Let's be honest there are a tremendous amount of changes coming and it will be messy. It will be very messy for anyone who has not gone through a recognized cadet program after 2012. Hawsepiping will be murky territory, but it seems TC is trying to smooth the path but this will require a great deal of ducks to be in line, so I am not overly confident of its smooth achievability.

Sea time and its interpretation will dramatically change, so this will be very difficult to decipher at the inspector level, so be prepared. Sea time for a particular CoC or CoP will be looked at from a IMO perspective, "last five years". So yeah lots of changes.

Here is my submission for now, you are encouraged to review the draft MPR2019 document (above) and submit your observation by February 2019, that's not much time.

Thank you for the opportunity to comment on the updating of the Marine Personnel Regulations of 2019. I applaud your efforts to be transparent and inclusive and recognize the sizable undertaking this represents, and the many aspects that ought to be consider. Since I am family man, the consultation session held in Vancouver on November 19, was the first time I’ve had the opportunity to access the process. Typically the vehicle used for this is CMAC; however I find it prohibitive for an average worker to attend, without undue burden on family budgets, therefore I express my appreciation for your commitment.

My background is of a marine engineer who has sailed in a professional capacity on commercial ships for the last 23 years. I hold a TC 3rd Class Motor CoC and had formal training through a Marine Engineering apprenticeship at PMTI (now BCIT). I have sailed in nearly all the markets in Canada, Lakes, Rivers, Pacific, Atlantic, sub arctic, and foreign going. My comments are from a purely “deck plate” perspective and are not motivated by anything other than making sure that if my young sons decided to pursue a career as a Marine Engineer in Canada, they would encounter a fair, achievable process that recognizes that they are humans.

I had the opportunity to review the proposed MPR 2019 and had numerous questions a result. During your presentations, I am satisfied that you have acknowledged my concerns and have provided sufficient insight to address them.

I am concerned about the Marine Engineering certification stream in Canada, in so far as the actual process and what form it will now take. I understand and extensive review of TP2293 is forthcoming which will speak to this concern. Again, I urge you when drafting this document that a perspective of an actual person (a 56 year old ERA in Stephenville, or the 17 year old in High School), and can that person achieve this with some regularity, and with a reasonable expectation of success, with a hope of progression.

We should strive to have “high standards” in Canada, but the reality is that shipping in an international affair, and that we as Canadian seafarers should be able to compete with our international peers, not be a competitive disadvantage to them. In my view, the “stuffing” of new IMO requirements into an already burdensome process, has produced many barriers that have restricted new entrants and upgrading, leading to untenable situation in the marine industry in Canada.

In reiterating my concerns brought to you during the consultation meeting of November 19, 2018, I have made a list of concerns, and my perspective for your consideration.

1. MPR2019 proposes significant changes in the Marine Engineering CoC structure and there is a lot of uncertainty in the marine engineering community over the actual process it will entail. I understand that the actual MPR document does not cover this aspect of discussion, and forthcoming review of TP2293 is the vehicle chosen to stipulate this process. I therefore implore simplicity, and achievability be consider as paramount, with the general concept proposed above be considered when reviewing TP2293.

2. My second question was about why the MPR2019 were taking shape as they are. I understand the Labour Code, the Manila Amendments are extremely important, but I am worried that these processes have a predominately business driven agenda. Again I ask that you consider the impacts to individual Canadian seafarers and their family, when drafting these regulations – are they achievable, simple to follow, will the requirements be accessible in such a large country. I implore you to limit numerous exceptions for certain “squeaky wheels” and ask for uniformity across all marine markets in Canada.

3. Section 101, recognition of Certificate of Competency issued by non-Canadian sources: there was considerable discussion on this topic as attendees recognize this to be a slippery slope. I am satisfied that your expressed intention is to solely facilitate a “migration process” or direct entry. My concerns arises that this will further eroded our Canadian training capacity, and that the standards of recognition of the CoP (outside of MPR2019) will be relaxed in the future so as to permit “offshore ticket mills” to undercut Canadian skills and capacity.
a. Related: In discussion with the panel, I understand that Section 212 (dispensation) is only to be taken in extremely rare circumstances. I am, however, concerned that this may be misinterpreted in the future and poorly applied.

4. Division 7 – recognizing certificates issued by Canadian Coast Guard and Department of National Defence. I understand this Division to be simple (good) but considerably broad and worrisome as to its objective. My understanding form the discussion is that this is under review, and that TC standards as stipulated under TP2293, and related documents, will be used in assessment in similar fashion as “direct entry” process. I am therefore confused about the intent of this division.

5. Sea time – I observed that there was considerable discussion on sea time and most expressed confusion over the various references in MPR2019; in my experience, it mirrors frequent complaints from my peers. I would implore that the guidelines issued to TC inspectors in whichever vehicle is used - MPR2019, or the forthcoming TP2293, or what have you - the language use be clear and direct so as to prevent ambiguity and inconsistent application - such as it is now.

6. Section 201 – Alcohol prohibition. I suggest that no alcohol consumption for 4 hr (section a) prior to watchkeeping duties, is tenebrous at best. What a seafarer does outside of their duties is not the domain of TC or the employer. I believe the standards of impairment are clearly defined and should suffice.

7. Section 307 – In the past I have observed what in my view were numerous excessive fees in the facilitating the employment of a seafarer – visa processing fees, excessive medical exams fees, and letters of sea service is vague. Where we have a shortage of competent seafarer now, it is less of a concern, however I find the use of “other than” to be vague and needing further limitations to prevent abuse.

8. Section 309 – I understand that Canada has two official languages but to require the Bargaining Agreement be supplied in both official languages to unrealistic in the Canadian workplace from my experience. I realize this applies to a very small amount of ships, but seems onerous.

I am very much interested in reviewing the draft of the revised TP2293 as the majority of my concerns, regarding the “nuts and bolts” of CoC certification, sea time, and syllabus, will be stipulated in this document. In the mean time I respectfully submit the above for your consideration in drafting the Marine Personnel Regulations 2019.
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Re: MPR2019 on the horizon, finally

Postby JK » Fri Nov 23, 2018 2:38 am

“Renewal time frame is a bit of a red herring, 12 month sea time in charge of a watch in five year.“

This is an issue for shore engineers. Right now as long as you are a tech superintendent, with a letter of compliance, you could keep your ticket active in the same 5 year term.

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Re: MPR2019 on the horizon, finally

Postby Shame_on_TC_2017 » Fri Nov 23, 2018 7:58 am

Important that not only you must go to a cadet program, but it must have been recently because even for seconds that graduated when there was only second class exemptions they do not have any credit for chiefs exams.

It won’t be possible to challenge any engineering exams if you have not already completed one exam and are “grandfathered” into the old system. In the future the only way to upgrade will be to go to an approved training program to get credit for part A subjects. Then after you pass one or two (under discussion) multiple choice / short answer tests to get your license. This will cover general engineering, motor engineering, and orals combined. So it’s not just go to school and get your ticket, there will be exams to pass in addition to getting credit for the mathematic subjects.

Owen sound is apparently the only school that will meet the full requirements for management level engineering because of their emphasis on management and actual changes to their program. Brenard Leclerc said that even schools that previously gave out first class part A exemptions will not meet the new managerial skills / ship business / maritime law requirements that are needed to be IMO / STCW 2010 compliant.

They talked about how bad oral exams are because of how subjective they are and are wildly different, mostly based on the examiners experience. They acknowledged that people are failing their orals because people have different experience than the examiners. Which is wrong.

I’m glad they are doing this consultation, this is the right way to do things. Just unfortunate it’s 6 years delayed.

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Re: MPR2019 on the horizon, finally

Postby The Dieselduck » Sun Nov 25, 2018 9:54 pm

You can find the audio recording of the consultation session that occurred in Vancouver, Monday Nov 19, 2018 here. The sound is not super great, but I think you can hear all the comments adequately.

You can download the files from my "general folder", since I cannot upload that file format on this medium. Navigate to

http://www.dieselduck.info/_bigbin/MPR2019/

to download the five parts - morning intro, navigation, engineering, various, and labour code / wrap up.
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Re: MPR2019 on the horizon, finally

Postby Supplyguy » Wed Jan 09, 2019 3:14 am

I was lucky enough to have attended one of the consultation sessions and to my understanding the part a exams for the chiefs will still be an option during the transition period (a possible two year period after new mpr is implemented, length of transition period is still
To be determined). After the transition period you will have to go to school wherever an approved course is being offered.
What really threw me off about this was not the part a but the part b exams. From what was discussed during the consultation it sounds like once the new mpr is in effect then the old part b exams (General, motor and orals)are no longer an option and we will have to do the new part b which will be the previously discussed in other people’s remarks of the one or two MC or short answer exams (TC hasn’t confirmed what it will
be yet)

My concern here is I’m in the process of completing the part a exams now. What is going to happen if you have the part a complete and are studying for part b and the mpr changes. I think some people are going to find themselves in one of three scenarios here

1. Countless study time put in for studying for the general and mpr changes and suddenly your into a new exam system.

2. You have the general knowledge complete and are studying for motor. Again countless time spent studying and what will happen? Would you be grandfathered in the old system or would you be forced to do whatever the new process is on top of already have completing the general.

3. You have general and motor done and are studying for orals and mpr changes. Again would you be grandfathered in or be forced into completing whatever new exams come out on top of already have doing the old general and motor.

I’ve expressed this to the email that was provided at the mpr consultation sessions as well as at the consultation session and the response was you will be put into the new system. I’m sure I’m not the only 2/E caught in this situation and we all need clarification on this.

Don’t know if anyone has any insight to offer here but I feel this is a big concern! The study for this stuff is time
Consuming as everyone is aware and it would be a shame to spend so much time studying for the part b only to be cut off and have to challenge new exams.

From the consultation session there was an email provided that we can express our concerns to TC that will be considered and can be submitted up until the end of Feb 2019. The email is Ava.cramp@tc.gc.ca.

Anyhow everyone safe sailing and if anyone has any insight then please comment!

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MPR19 - Guild's submission

Postby The Dieselduck » Tue Feb 19, 2019 12:24 pm

The Canadian Merchant Service Guild released its submission to TC regarding the proposed MPR.

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Re: MPR2019 on the horizon, finally

Postby The Dieselduck » Wed Feb 27, 2019 8:25 am

Fellow engineer, Jodi Gaudet, submits these observations in an attempt to allay some fears from the new MPRs, and its impacts on Marine Engineers in Canada.

The first addresses the fear highlighted in the submission by the Guild to TC.

2019.01-JG 3rd class exchange.pdf
(1.46 MiB) Downloaded 105 times


The second looks at what it will take to get from rating to officer, and moving forward after that.

2019.01-JG CoC Paths.pdf
(434.31 KiB) Downloaded 104 times


Thanks Jodi!
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Re: MPR2019 on the horizon, finally

Postby The Dieselduck » Sun Mar 24, 2019 2:27 pm

Our freelanced, and free, MMEP reporter at large, Jodi, send this follow up report on the new MPRs.

Quick update from the Pacific CMAC:

- Biggest news is the MPR has now been delayed until sometime in early 2020 (surprise…not)

Seatime:
-Bernard is committed to sorting out sea time issues. He stated that the problems that junior engineers at BCF have had getting seatime in the past should never have happened and he is working on sorting that out.
-Bernard is trying to set up a system where graveyards, supernumerary days, training days etc would be worth at least a percentage of your seatime.
-contrary to what the MPR draft says, it does not sound like there will be credit for part days over 8hrs. As a matter of fact Bernard told me there will no longer be 1.5 days given for a 12 hour day. His rational is that the amount of sea time required from 4th/EOOW to 2nd engineer will be reduced from 24 months to 12 months. If time is earned at 1.5 days for every day worked then total time on board is reduced from 12 months or 360 days to 8 months or 240 days. This does not meet IMO requirements apparently. I see the validity of the reasoning but there will be some seriously pissed off engineers! I am hoping more is going to be said about this at national CMAC.

- SVMO: Based on submissions received (from BCFMWU I suspect) they are excluding passenger vessels from the regulation that will raise SVMO kW to 1999kW. It will stay at 1499kW as it is in the current MPR.

-Other questions I asked:

1000V requirement on vessels: Is this going to be required of all companies sailing vessels with systems over 1000V and will an approved course be required?
The answer was yes all engineers sailing on vessels over 1000V regardless of voyage classification, tonnage etc. will be required to have an approved training course for high voltage. This will be a COP (certificate of proficiency) on your certificate. So far the only college offering an approved course is Nova Scotia community college in Port Hawkesbury.

Will exams still be offered at TC offices?
Yes they will be offered but you will still have to take an approved training course. In some instances you may be exempt from the TC exam if the training course is accredited.

Will there be another MPR consultation when the changes are made to the MPR based on the first round of recommendations?
There will not be cross Canada consultations however a second draft should be released and an opportunity for feedback from industry and labour especially since the big rush is off.

Also Bernard said that there will grace period for engineers who have started a certificate under the old regulations to complete it even after the new MPR comes into effect. That is new as before he was adamant that there would be no grace period.

Anyways those are the main points that I can remember. I am heading to Ottawa in April and hopefully there will be more said there. Will keep you updated



Thank you Jodi ! ! !
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MPR - Current version

Postby The Dieselduck » Mon Apr 01, 2019 6:39 am

Here is the current version of the Marine Personnel Regulations in Canada

2019.02-GoC TC MPR.pdf
(1.47 MiB) Downloaded 83 times
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MPR2019 updates

Postby The Dieselduck » Fri Apr 26, 2019 10:03 am

From the latest CMAC in Ottawa, here are some documents produced by TC to update on the progress of the new MPRs.

ITEM 2 - EN MARINE PERSONNEL UPDATE.pdf
MPR2019 situation update
(1.39 MiB) Downloaded 49 times


ITEM 5 - EN STAKEHOLDER COMMENTS ON MPR DISCUSSION DOCUMENT.pdf
Received comments from stakeholders to TC re MPR2019
(871.22 KiB) Downloaded 32 times
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