In a written submission to IMO, ICS has suggested that IMO Member States might give consideration to the possibility of an extended “grace period” with respect to Port State Control enforcement of the new certification required under STCW 2010.

STCW 2010, Regulation VI/6, stipulates mandatory minimum requirements for security-related instruction for all seafarers, which, where relevant – such as for Ship Security Officers as defined by the ISPS Code – requires certificates of proficiency to be issued by administations to seafarers from 1 January 2014.

Since the amendments were adopted, ICS has gone to great lengths to advise shipping companies of the transitional measures for these new requirements, as set out in Section A-VI/6 of the STCW Code, which are different to those concerning the transitional measures that apply to other changes introduced by STCW 2010 and which are being phased in between now and 2017.

ICS is concerned that any certification that STCW requires governments to issue might not be fully in place by the 1 January deadline and that ships could potentially encounter difficulties during Port State Control inspections.

ICS Secretary General, Peter Hinchliffe, explained “We understand that the training and familiarisation required by STCW 2010 has only just recently been approved by some maritime administrations, whilst others may not yet even have these arrangements in place. This could present serious difficulties for companies that need to ensure that the seafarers they employ are trained and certificated as required by STCW 2010.”

He added “For the most part this is really just a technicality since most existing seafarers have already undergone necessary levels of training and instruction as required by the ISPS Code. Given that certification is entirely a government responsibility we think that a short delay in PSC enforcement can be justified.”

The ICS submission to IMO, which suggests the possibility of an extended “grace period” with respect to Port State Control enforcement of the new secuirity training certification, has been made to the first session of the new IMO Sub-Committee on Human Element, Training and Watchkeeping (HTW) which supersedes the STW Sub-Committee within the new IMO Committee Structure. The HTW Sub-Committee will meet in the week of 17 February.

Notes
Advice to shipping companies about the STCW security training requirements is contained in the ISF Guidelines on the STCW Convention including the 2010 ‘Manila Amendments’ published in 2011.

The ISPS Code is the International Ship and Port Facility Security Code, which is mandatory under the SOLAS Convention and was adopted in 2002 in response to the ‘9/11’ terrorist attacks.