A Message from the Canadian Institute of Marine Engineering’s Honourary President on Marine Personnel Regulation Proposed Changes
Hello Fellow Members of CIMarE
Many of you will know that Transport Canada Marine Safety and Security is engaged in a major re-write of the Marine Personnel Regulations (MPRs). The stated goal is to align Canadian Regulations with the requirements of the International Maritime Organization’s Standards for Training, Certification and Watchkeeping for Seafarers (STCW) and similar for fishers (STCW-F) as well as the International Labour Organization’s Maritime Labour Convention (MLC). I have been a participant at various CMAC and other meetings as the discussions have progressed.
TCMSS now plans to publish in the Canada Gazette Part I in December 2022. This publication will be the last chance to submit comments. It is anticipated that few changes will be made as TCMSS are asking for input from stakeholders at this time. CIMarE has expressed concerns earlier and now is your chance to help CIMarE determine what further comments should be submitted regarding the changes.
TCMSS plan to publish the MPRs in Canada Gazette Part II in the summer of 2023 at which time they will begin to come into effect.
We have posted several documents in the Member’s Only area of the website to give members insight into the proposed MPRs. Some members may have participated in CMAC meetings or may have expressed concerns through their unions. I encourage any members with concerns to address them to CIMarE through a special email which has been set up for this purpose. Comments will be synthesized and submitted to TCMSS on behalf of CIMarE.
Questions will be responded to.
The email address to send comments or questions to is: MPR@cimare.ca
Click here to go to the MPR Page
The documents posted are
Document 1 – Overview of the MPRs, rationale for changes and general information on certificates and certificate exchange.
Document 2 – Overview of changes being proposed.
The above two presentations were given to the Marine Personnel Standing Committee during the Fall 2021 CMAC Session. There was a lot of discussion over the Safe Manning provisions, particularly as they relate to small passenger vessels and tugs operating in restricted areas.
Document 3 – The proposed Marine Personnel Regulations as of November 2021.
The proposed regulations are organized in Parts under which are several divisions Each division is then subdivided into sections. The general layout is:
Part 1: Certification -Overview
• 1000 to 1008 Division 1–General Provisions
• 1009 to 1038 Division 2–Masters and Mates
• 1039 to 1048 Division 3–Engineer Officers, Electro-technical Officer, and Small Vessel Machinery Operator
• 1049 to 1053 Division 4–Ratings -STCW Certificates of Competency
• 1054 to 1083 Division 5–Certificates of Proficiency
• 1084 to 1094 Division 6–Certificates of Competency for Mobile Offshore Units
• 1095 Division 7–National Defence and Coast Guard
• 1096 Division 8–Transitional Period (Drafting ongoing)
• 1097 to 1102 Division 9 –Exchanges and Renewals
Part 2 –Marine Medical Certificates
Part 3 -Crewing, Training, and Watchkeeping Requirements
• 3000 to 3002 Definitions and Interpretation
• 3003 to 3009 Division 1: Minimum Safe Manning Document
• 3010 to 3021 Division 2: Standards Respecting Deck or Navigational Watch, Engineering Watch, and Radio Watch
• 3022 to 3048 Division 3: Crewing of Canadian Vessels
• Schedule 1: Former Certificates and Other Documents
• 3049 to 3075 Division 4: Training (has subdivisions A to I, and Schedule X: Equivalent Training Certificates)
• 3076 to 3100 Division 5: Fishing Vessels
• 3101 to 3116Division 6: Mobile Offshore Units (MOU)
• 3117 to 3121 Division 7: Air Cushion Vessels
• 3122 to 3123 Division 8: Cable Ferries
Part 4 -Maritime Labour Standards
• 4000 to 4001 : Definitions and Interpretation
• 4002 to 4004 -Division 1 : Requirements Regarding Age
• 4005 to 4008 –Division 2 : Seafarer Recruitment and Placement Services
• 4009 to 4036 –Division 3 : Conditions of Employment
• 4037 -Division 4 : Separate Hospital Accommodation
• 4038 -Division 5 : On-board Complaint Procedures
• 4039 to 4044 -Division 6 : Maritime Labour Certificates and Declaration of Compliance
• 4045 -Division 7 : Log Books
PART 5 Consequential Amendments, Transitional Provisions, Repeals and Coming into Force
• 5000 – onward
Document 4 – Proposed TP 2293 Qualifications for the Certification of Seafarers. The MPRs address the certificates which are to be issued under the new regulations and TP 2293 will address the qualifications/training/ experience required before certificates can be issued. TP 2293 makes numerous references to the STCW Convention (and other IMO) requirements so you may need to refer to those documents if you are interested in the qualifications required for any particular certificate.
CIMarE wrote to Transport Canada in February 2019 expressing our general concerns as details of the proposed regulations were not available at the time. Our general concerns at that time were
• The changing requirements for direct entry candidates, i.e. those outside of recognized cadet programs.
• Renewal requirements for existing certificates.
• Qualifying sea service for certification including “sea-time”, power requirements, service and ship type – especially where ship type may impact safety requirements.
• Exchange, recognition and endorsement of foreign certificates.
• Levels of certification for engineering personnel on various ship types an voyage classifications.
• The detailed development of TP 2293 and other necessary Standards.
I encourage all members to take time to review the proposed regulations and TP 2293 in their areas of interest and to advise us of their concerns. A submission from CIMarE will be seriously considered by TCMSS.
Please note that we intend to provide regulatory updates in the near future in order to keep members apprised of changes that could impact.
Thanks for your interest in our industry and the Institute.
For those who are not CIMarE members (i encourage you to be) Below are some of the documents referred to above.