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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