STCW CONVENTION’S CERTIFICATION PROVISIONS
FOR SAFETY AND EMERGENCY RESPONSE TRAINING:
ANALYSIS OF APPARENT AMBIGUITIES
Kevin O. OKONNA
Head of Maritime Safety Department
Maritime Academy of Nigeria, Oron
E-mail: [email protected]
Mobile: +2348037092237
ABSTRACT
The provisions of the STCW Convention appear to present some ambiguities regarding the
certification of safety and emergency response trainings in Chapter VI. Such provisions include the
non-indication of the exact format for provision of evidence of having achieved the required standard
of competence in basic safety tasks, duties and responsibilities (Section A – VI/1 par. 2). This
ambiguity of intent is collaborated by the non-mention of the word “certificate” in neither Reg. VI/1
nor Section A-VI/1, leading to the question, whether the evidence of competence refers to certificate
for basic safety training? Also, the conditions for demonstrating the required standard of competence
“within the previous five years” for all the safety and emergency trainings, excepting medical first aid
and medical care, particularly lead to many questions concerning the conditions for renewal of these
certificates. In practice therefore, the interpretation and conditions for renewal of these certificates vary
greatly from administration to administration. This paper analysis the apparent ambiguities in the
certification provisions of Chapter VI of the STCW Convention and present the sampled opinions of
industry stakeholders on this situation with the view to proposing necessary changes in the text of this
chapter of the very important Convention.
Keywords: STCW 95, Certification, Ambiguities
1. INTRODUCTION
The benefits of safe operation of ships and capability for responding to shipboard emergencies are numerous.
Safe operations ensure the prevention of both unsafe conditions and acts that have the potential to cause harm
or death to people, damage to assets, company/industry reputation as well as environment and ultimately
assure the profitability of investment. The International Management Code for Safe Operation of Ships and
for Pollution Prevention (ISM Code) was therefore established and requires the development and
implementation of a safety management system which addresses all of a company’s activities onshore and on
board its ships including procedures to prepare for and respond to emergency situations (LR, 2002). It
demands the commitment, competence, attitudes and motivation of individuals involved in matters of safety
and pollution prevention starting from the top management (IMO, 1997). The International Convention on
Standards of Training, Certification and Watchkeeping for Seafarers 1978 as amended (STCW Convention)
provides the standards for training and certification of shipboard personnel on safety and emergency response
mainly in Chapter VI titled “Emergency, occupational safety, medical care, and survival functions”. The
details of minimum standards and guidance to assist parties to give the convention full and complete effect in
a uniform manner are contained in part A and part B of the STCW Code respectively (IMO, 2001). This
chapter contains;
i) the mandatory minimum requirements for familiarization and basic safety training and instruction for all
seafarers (reg. VI/1 and section A-VI/1 of the STCW Code);
ii) the mandatory minimum requirements for issue of certificates of proficiency in survival craft rescue
boats and fast rescue boats (reg. VI/2 and section A-VI/2 of the STCW Code);
iii) the mandatory minimum training in advanced fire fighting (reg. VI/3 and section A-VI/3);
iv) and mandatory minimum requirements related to medical first aid and medical care (reg. VI/4 and
Section A-VI/3).
However, the provisions of the Convention in the above mentioned sections, taken separately and compared
with other relevant provisions of the convention appear to present ambiguities regarding the certification of
these safety and emergency response trainings. These ambiguities include, amongst others:
i) Lack of clarification of the format for provision of evidence of having achieved required standard of
competence to undertake the tasks, duties and responsibilities under personal survival techniques, fire
prevention and fire fighting, elementary first aid and personal safety and social responsibilities leading to
questions such as, whether demonstration of required standard of competence refers to a certificate?
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ii) The uncertainties about the conditions for renewal of safety and emergency response certificates arising
from the requirement for seafarers to provide evidence of having achieved the required standard of
competence “within the previous five years …” either before assignment of any shipboard duties or
certification at different sections of chapter VI of the STCW Code.
Such unclear provisions of the Convention have lent themselves to differing interpretations and
implementation giving rise to variations in administrative practices which are against the fundamental
reasons for the 1995 amendments of the STCW Convention. One of the defects of the original annex to the
1978 STCW Convention was the use of broadly-worded requirements capable of wide interpretations, the socalled “compromise drafting”. Another defect was training and assessment being left “to the satisfaction of
the Administration”.
The following sections of this paper present elements of international treaty law with particular reference to
interpretation of international conventions before analysing the apparent ambiguities in the provisions of the
STCW Convention with respect to the conditions for certification of shipboard personnel in safety training
and emergency response training. The paper also presents the analysis of the sampled opinions of some
industry stakeholders obtained with a questionnaire about the adequacy or otherwise of these provisions in
Table 2 before concluding. The summary of recommendations of this paper is presented in Table 1.
2.INTERPRETATION AND IMPLEMENTATION OF INTERNATIONAL CONVENTIONS
The purpose of international treaties, including conventions, is to ensure uniformity of practice
internationally. In accordance with the definition adopted in Article 2 of the Vienna Convention on the Law
of Treaties, a treaty may be defined as “an agreement whereby two or more states establish or seek to
establish between themselves a relationship governed by international law”. The general term “treaty” may
in practice be given one of a variety of titles, the most significant of which is the “Convention”.
Since international conventions seek to establish international uniformity of practice, uniformity in
interpretation is prerequisite for the uniform implementation. Scholars of treaty interpretation law point to
three schools of thoughts; namely, the “intentions” approach which is characterised as subjective, the
“textual” approach which is characterised as objective, and the so-called “teleological” or “object and
purpose” approach, an expression which has been incorporated into Article 31(1) of the Vienna Convention
on the Law of Treaties. However, Sinclaire (1984) stated that these approaches are not by any means
mutually exclusive. He states that
… the most rigid adherent of the textual approach would scarcely argue that a tribunal
should deliberately seek to establish a meaning which was not within the contemplation, or
intention, of any of the parties to the dispute; and the most rigid adherent of the intentions approach
would not seek to deny that the text of the treaty will constitute evidence of what was the intent of
the parties.
He refers to McNair (1961) who attempts to synthesis the three approaches by proposing that
… the main task of any tribunal called upon to construe or apply or interpret a treaty is to
give effect to the expressed intention of the parties, that is ‘their intention as expressed in the words
used by them in the light of the surrounding circumstances.
Although in pursuing the uniformity of interpretation and implementation of regulatory maritime conventions
such as STCW, SOLAS and MARPOL we cannot possibly desire total uniformity in terms of national legal
regimes, the provisions of such conventions should be drafted to bring about not only unification of
substantive law but also uniformity in procedure in order that matters such as port state control are facilitated.
Consequently, to appraise the interpretation and implementation of the provision of the STCW Convention
for certification of safety and emergency response trainings, it is important to have insight into the intentions
of the drafters and why certain provisions were included in the 1995 STCW amendments. In this regard, the
publication titled “Competent crews = safer ships: An aid to understanding STCW 95” by W.S.G. Morrison
has been useful in providing insight into the intentions of the drafters of the provisions in Chapter VI of
STCW 95.
The differing flag – state interpretations of the STCW Convention has been noted as a problem though the
problem has sometimes arisen out of attempt to solve the problem of respect for differences in the way
parties interpret and enforce convention requirements (the so-called differences in details). The STCW-ISM
Sub-committee of the International Association of Drilling Contractors also noted this problem as follows;
“The continual problem (or sometimes solution) of differing interpretations being provided by various
302
Regional Examination Centers was discussed with some recent examples provided. The suggestion remains:
when it sounds good – get it in writing” (IADC, 2002).
3.ANALYSIS OF APPARENT AMBIGUITIES
The following subsections provides the analysis of the provisions of chapter VI of STCW 95 identified to
present unclear intentions (or ambiguities) regarding the certification of safety and emergency response
trainings. The analysis combines the prevalent industry practices, opinion of industry stakeholders and the
insight gained into the intentions of the drafters of the provisions and draws conclusion on whether the
amendments of those sections are desirable.
3.1. Requirements for Familiarization
Paragraph 1 of section A-VI/1 of the code to the STCW Convention requires that “before being assigned to
shipboard duties, all persons employed or engaged on a seagoing ship other than passengers, shall receive
approved familiarization training in personal survival techniques or receive sufficient information and
instruction, taking account of the guidance given in part B, to be able to communicate with the persons on
board on elementary safety matters and understand safety information symbols, signs and alarm signals;
know what to do if a person falls overboard, fire or smoke is detected, or the fire or abandon ship alarm is
sounded, . ….. etc”.
The first observation is that there is no entry on familiarization training in Section B of the code to STCW 95.
The following questions may also arise in the interpretation and implementation of this provision of the
convention.
i)
Since the tasks and responsibilities to be learnt through the familiarization training are all covered in
the basic safety training, can the competence demonstrated in basic safety training be taken as sufficient for
familiarization training?
ii)
Can familiarization training be completed ashore?
Although the text of the convention did not specify that familiarization training cannot be completed ashore,
in answer to the first question, Morrison (1997) points out that “although much preparatory instruction and
training can be given prior to joining the ship, the final training or instruction and assessment of those
concerned has, of necessity, to be conducted on board. Conversely, since basic safety training is first required
to be completed ashore, the first question is also answered that basic safety competence is not sufficient for
familiarization training. In addition, it should be noted that the main targets of paragraph 1 of section A –
VI/1 are people, other than the master, officers and crew, employed directly or indirectly to provide any
service of any nature on board during a seagoing voyage. This includes maintenance and repair personnel,
shop assistants, hairdressers, entertainers, etc. Familiarization of the master, officers and crew in their
specific duties and ship installations, procedures, and emergency duties, etc is dealt with under reg. 1/14.
Consequently, for clarity and uniformity of interpretation and implementation, the need to complete
familiarization training only on board specific ship could be introduced into paragraph 1 of section A-VI/1 or
presented as guidance in part B of the code.
3.1. Certification of Basic Safety Training
The intention of STCW 95 for Chapter VI certificates not to be subject to the five yearly revalidation
conditions is stated unambiguously in regulation I/11 (revalidation of certificates). However, section A-VI/2
of the STCW Code states that seafarers engaged in any capacity onboard ship on the business of that ship as
part of the ship’s complement with designated safety or pollution-prevention duties in the operation of the
ship before being assigned to any shipboard duties shall, before being assigned to such duties have to
undertake appropriate approved basic training or instruction in:
i)
ii)
iii)
iv)
personal survival techniques as set out in table A-VI/1-1;
fire prevention and fire fighting as set out in table A-VI/1-2;
elementary first aid as set out in table A-VI/1-3; and
personal safety and social responsibilities as set out in table A-VI/1-4,
and be required to provide evidence of having achieved the required standard of competence to undertake the
tasks, duties and responsibilities listed in the tables mentioned for the respective subjects within the previous
five years. The seafarers are required to provide evidence of having achieved the required standard of
competence through demonstration of competence, in accordance with the methods and criteria set in the
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respective tables and examination or continuous assessment as part of an approved training programme in the
listed subjects.
The following sections present the questions which may arise in the interpretation and implementation of this
section of the convention. The opinions of industry stakeholders obtained by questionnaire and the
application of intent by the convention drafters are also presented.
3.1.1. Evidence of Competence Vs Certificate
The questions that may arise with respect to the interpretation of certification requirements of paragraph 2 of
section A-VI/1 of the STCW Convention are;
i)
What is the motive of avoidance of the word certificate as a format for providing the
evidence of required standard of competence?
ii)
Is “evidence of competence” referring to a certificate?
The respondents to the questionnaire Item No. 1 (presented in Table 2 of this paper) on whether section AVI/1, paragraph 2 of the STCW Convention was considered ambiguous for not stating the format required for
providing evidence of demonstration of competence in tasks duties and responsibilities in basic safety
training were equally split in agreeing and disagreeing with this question. However, all the respondents stated
that a certificate is issued in their country in evidence of demonstration of this competence and that record of
service is also accepted as evidence of achievement of required standard of competence. Two (2 No.) and one
(1 No.) respondent(s) respectively indicated that record of instruction and other documents are accepted as
evidence of achievement of required standard of competence. Morrison (1997) pointed to the definitions of
certificate in article II and regulation I/1 and the provisions of article VI, regulations 1/2 and 1/9 and opined
that all or none of these requirements apply in respect of competence required to be produced by section AVI/1 paragraph 2, otherwise the defined term “certificate” is assigned a different meaning according to the
location it appears in the convention or code. This author agrees with Morrison (1997) that the treatment of
evidence of having achieved the basic safety training standards of competence as a non-certificate is
incompatible with the definition of certificate in article II and requires to be amended.
3.1.2. Expiry of “evidence of required standard of competence”
In respect of expiry of “evidence of required standard of competence”, the following question may be asked;
Does the criterion for demonstration of required standard of competence “within the previous five years”
imply that the evidence of competence in basic safety expires?
No categorical explanation of intent of the drafters was obtained for this question and it could appear more
confusing considering the fact that the same phrase of “within the previous five years” has been used with the
requirements for proof of evidence of achievement of required standard of competence for other chapter VI
certificates where such certificates are not considered to expire by using the unwritten intent of the drafters in
the interpretation of the provisions. (Please see sections 3.3-3.5 of this paper). In agreement with McNair
(1961), this author believes that the intent of the provisions of a regulatory international convention should be
unambiguously and clearly represented in its text in order to facilitate uniformity of interpretation and
implementation.
3.1.3. Approved Training Programme
In respect of the requirement to complete an approved training programme the following questions may be
asked.
i)
ii)
After receiving the first appropriate approved basic training for demonstration of
competence to undertake the relevant tasks, duties and responsibilities before engagement,
is the seafarer expected to undertake another appropriate approved basic training in order to
be qualified for demonstration of achievement of competence after five years from the date
of last demonstration of achievement of required standard of competence (“certification”)?
Is evidence of sea service sufficient demonstration of competence for renewal of basic
safety certificates?
The text of the Convention in paragraph 2.2 of section A – VI/1 appear to require that before any seafarer is
engaged onboard ship on safety and pollution prevention duties he/she should provide the evidence of
achievement of required competence in accordance with other provisions of the Convention and shall be
required to provide this evidence again on expiry of the initial certificate after five years before renewal.
Consequent upon this unclear text, different maritime administrations have specified different requirements
for renewal of basic safety certificates. Some require complete repeat of approved training ashore, others
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accept refresher ashore only in some courses for renewal of all certificates while others accept sea service of
varying time length.
The divergence in interpretation and implementation of basic safety training/certification provisions was
clearly characterized in the responses obtained for the questionnaire Item No. 3 bordering on question 3.
2.3(i) as presented in Table I to this report. Of the six responses obtained, three agreed and the other three
disagreed that the (text of the) requirement for the evidence of having achieved the required standard of
competence “within the previous five years …..” for most of the safety and emergency response trainings
implies that those certificates must be renewed through completion of approved training programmes after
every five years. However five of the six respondents disagreed in Item No. 4 that the STCW Convention
(actually) requires the completion of approved training programme before every renewal of certificates. All
two respondents that completed Item No. 5 agreed that sea service (or approved in-service experience in Item
No. 7) is used in their countries for renewal of all the basic safety certificates excepting elementary first aid
which possibly requires completion of approved training ashore before renewal of certificate.
Morrison (1997) explains that in view of the scope and depth of the required training that can be carried out
on board ships being limited and also for consideration of safety of ship and trainees as well as interruptions
and delays to ship operations, the drafters of the 1995 amendments to the STCW Convention intended that
the required training be completed ashore at a training institution properly equipped for practical training in
various types of appliances and equipment commonly found on board ship.
3.1.4. Renewal of basic safety certificates for holders of advanced safety certificates
The following is another question which frequently arises in respect of certification of ship’s officers in basic
safety competences.
Are seafarers with advanced training certificates (such as in advanced fire fighting, medical first aid,
medicare and proficiency in survival craft and rescue boats) still required to undertake basic safety training in
fire prevention and fire fighting, elementary first aid and personal survival techniques before renewal of those
basic safety certificates?
The respondents to this question in questionnaire Item No. 6 were unanimous in answering “No” in respect of
their countries, meaning that holders of advanced safety certificates are not required to undertake refresher
basic safety training before renewal of basic safety certificates in their respective countries.
3.2. Certification of Proficiency in Survival Craft and Rescue Boats
Paragraph 4 of section A-VI/2 requires every candidate for certification in proficiency in survival craft and
rescue boats (other than fast rescue boats) to provide evidence of having achieved the required standard of
competence within the previous five years through demonstration of competence to undertake the relevant
tasks, duties and responsibilities listed in column 1 of table A-VI/2-1 through examination or continuous
assessment as part of an approved training programme.
Also, paragraph 8 of section A-VI/2 requires every candidate for certification in proficiency in fast rescue
boat to provide evidence of having achieved the required standard of competence within the previous five
years through demonstration of competence to undertake the relevant tasks, duties and responsibilities listed
in column 1 of table A-VI/2-2 through examination or continuous assessment as part of an approved training
programme.
Again, the phrase “within the previous five years” in both requirements is not clear on whether after the
initial certification, the certificate expires and whether the seafarer needs to repeat the approved training
leading to the provision of the evidence of having achieved the required standard of competence? These
therefore open these requirements to varying interpretations and implementation. Morrison (1997) however
explains that for both qualifications, the five years limitation only applies in respect of the initial certification,
and once the certificate is issued the Convention does not require the holder to undergo periodic refresher
training, it being assumed that the holder will participate regularly in shipboard drills. If Morrison is correct,
then the construction of the texts failed to convey the exact intention of the drafters and the Convention also
contained no such explanation in the corresponding section B of the Code meant to provide guidance
regarding provisions of the annex to the Convention. For greater uniformity in the implementation of these
provisions, it is therefore necessary to either appropriately amend the texts of section A-VI/2 or introduce
appropriate explanations in the corresponding section of part B of the Code.
305
3.3. Mandatory minimum requirement for training in advanced fire fighting
Paragraph 4 of Section A-VI/3 requires every candidate for certification in advanced fire fighting to provide
evidence of having achieved the required standard of competence within the previous five years, in
accordance with the methods of demonstrating competence and the criteria for evaluating competence
tabulated in columns 3 and 4 of table A-VI/3. Again, the construction of that section of the Convention was
not clear on the meaning of the phrase “within the previous five years” and allows varying interpretation and
implementation of the provision thus not providing for uniform standard. Here also, Morrison (1997)
explains that the five year limitation applies only in respect of initial certification and certificate holders are
expected to participate regularly in shipboard drills. This section should consequently be amended to reflect
the requirement with clarity or appropriate explanations introduced into part B of the STCW Code.
3.4. Mandatory minimum requirements relating to medical first aid and medical care
Section A-VI/4 paragraph 1 requires that every candidate for certification to provide medical first aid on
board under the provisions of regulation VI/4, paragraph 1 shall be required to provide evidence that the
required standard of competence has been achieved in accordance with the methods for demonstrating
competence and the criteria for evaluating competence tabulated in table A-VI/4-1.
Paragraph 6 of Section A-VI/4 requires that every candidate for certification to take charge of medical care
on board under the provisions of regulation VI/4 paragraph 2 shall be required to provide evidence that the
required standard of competence has been achieved in accordance with methods for demonstrating
competence and the criteria for evaluating competence tabulated in table A-VI/2.
Noticeably, the provisions of both paragraphs 1 and 6 of section A-VI/1 do not contain any time limitation to
the validity of the certificates. Morrison (1997) explains that the provision of evidence that the required
standard of competence has been achieved may have been completed at any time in the past and no time limit
is imposed such as the five year limitation in section A-VI/1 to 3. It would certainly be more beneficial to the
industry if the text of these provisions expressly indicated these intentions or at least enter the explanations in
the corresponding sections of the part B of the STCW Code for guidance in the interpretation and
implementation of these provisions.
Ironically, though the few respondents to the survey of opinions generally noted the existence of some
confusion with some provisions of the STCW Convention (Item No. 10), half of these respondents did not
desire for the amendment of any section of the Convention. Neither did those who desired amendments
indicate the areas of concern.
4.
CONCLUSION
This paper has stated the several benefits of safe operations especially in the risky marine environment and
related the objectives of the ISM Code and the STCW Convention to the achievement of these objectives.
The fact that international treaties, including conventions, are meant to achieve uniformity of practice in the
party states has been stated. The implication that the drafters of the conventions should clearly represent the
intentions of the parties to the convention in the texts has been emphasised and supported with references to
scholars and jurists of international treaty law. The apparent ambiguities in the provisions of chapter VI of
the STCW Convention have been identified and questionnaires used to obtain some industry stakeholders’
opinions in support and against the author’s hypotheses. Finally, the identified ambiguities have been
analysed against the background of the combination of other relating sections of the convention and
secondary data sources including responses to personally constructed questionnaire items and, particularly, a
source which afforded this author an easy insight into why certain provisions were included in the 1995
amendments to the STCW Convention. This paper has also presented a list of recommendations that mainly
require the amendments of the texts of the ambiguous provisions of chapter VI and sections A-VI/1 to 4 of
the STCW Code or inclusion of appropriate explanations in the appropriate sections of part B of the code to
provide guidance for the uniform interpretation and implementation of safety and emergency response
training certification in order to give full and complete effect to the provisions of the STCW Convention.
5.
RECOMMENDATIONS
The recommendations of this paper are presented in Table 1 below showing the section of the STCW
Convention, considered ambiguity and the recommendations.
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Table 1: SUMMARY OF RECOMMENDATIONS
S/No.
Section of STCW
Convention
Section A-VI/1,
paragraph 1
Considered Ambiguity
Recommendations
Non-specification of the location (e.g
specific
ship)
where
required
familiarization training must be completed.
2.
Section A-VI/1,
paragraph 1
There is no guidance on familiarization
training in Part B of the code to STCW 95
as stated in Part A.
3.
Section A-VI/1,
paragraph 2
Non-specification of the format(s) for
presentation of evidence of achievement of
required standard of competence
4.
Section A-VI/1,
paragraph 2
5.
Section A-VI/1,
paragraph 2
6.
Section A-VI/2,
paragraphs 4 & 8
7.
Paragraph 4 of
Section A-VI/3
8.
Section A-VI/4,
paragraphs 1 & 6
Unclear intent of the requirement for
demonstration of required standard of
competence “within the previous five
years” especially, vis-a-vis application of
the same phrase in other sections.
Uncertainty about requirement to repeat/or
not appropriate approved basic training in
order to be qualified for renewal of basic
safety certificates after five years from the
date of last demonstration of achievement
of required standard of competence. There
is no guidance in Part B of the Code to this
effect.
The phrase “within the previous five
years” in both requirements is not clear on
whether after the initial certification, the
certificate expires and whether the seafarer
needs to repeat the approved training
leading to the provision of the evidence of
having achieved the required standard of
competence. No guidance in Part B of the
Code to this effect.
The requirement to provide evidence of
having achieved the required standard of
competence within the previous five years
is not clear on whether this is limited to the
initial certification or requires renewal of
the certificate. There is also no guidance in
part B of the code.
Both paragraphs do not contain any time
limitation to the validity of the certificates
and there is no explanation in Part B as
guidance.
Should be
amended
provided in
Code
Should be
amended
provided in
Code
Should be
amended
provided in
Code
Should be
amended
provided in
Code
1.
appropriately
or
guidance
Part B of the
appropriately
or
guidance
Part B of the
appropriately
or
guidance
Part B of the
appropriately
or
guidance
Part B of the
Should be appropriately
amended
or
guidance
provided in Part B of the
Code
Should be appropriately
amended
or
guidance
provided in Part B of the
Code
Should be appropriately
amended
or
guidance
provided in Part B of the
Code
Should be appropriately
amended
or
guidance
provided in Part B of the
Code
6. REFERENCES
(2002). STCW-ISM Sub committee meeting minutes, Access Date: 29.07.08,
http://www.iadc.org/committees/training/ISM-STCW/20020115%20Approved%20Minutes.PDF.
IMO (2001). International Convention on standards of training, certification and watchkeeping for
seafarers, 1978, as amended in 1995and 1997, Author, London.
IADC
307
IMO (1997). International management code for the safe operation of ships and for pollution prevention
(ISM) code, Author, London.
Lloyd’s Register (LR) (2008). International safety management (ISM) code: Managing risks and improving
performance, Access Date: 29.07.08, www.lr.org/Standards/Codes/ISM+code.htm
McNair, I. (1961). The Law of Treaties, Oxford University Press, London.
Morrison, W. S. G. (1997). Competent crews = safer ships: An aid to understanding STCW 95, WMU
Publications, Malmo, Sweden.
Sinclair, I. (1984). The Vienna convention on the law of treaties, 2nd Edition, Manchester University Press.
United Nations (1980). Vienna Convention on the Law of Treaties, Access Date: 09.04.96,
http://www.greenpeace.org∼intlaw/vien-tr.html
Table 2: SUMMARY OF ANALYSIS OF QUESTIONNAIRES
1.
Section A – VI/1, Paragraph 2 of the STCW Convention Code is ambiguous for not stating the
format (certificate, record or other) required for provision of evidence of demonstration of
competence in tasks, duties and responsibilities in basic safety training.
Number
Questionnaires
distributed
40
2.
of
Number of respondents
YES
NO
6
3
3
What format(s) is/are used for providing evidence of demonstration of competence in tasks,
duties and responsibilities in basic safety training in your country?
Format
Certificate
Record of instruction
Record of service
Other documents
3.
NO
Nil
4
Nil
5
The requirement for the evidence of having achieved the required standard of competence
“within the previous five years ------” for most of the safety and emergency response trainings
in Chapter VI of the STCW Convention implies that those certificates must be renewed
through training after every five years.
Number of
Questionnaires
distributed
40
4.
YES
6
2
6
1
Number of respondents
YES
NO
6
3
3
For the five yearly condition of renewal of chapter VI certificates, the STCW Convention
requires the completion of approved training programme, before every renewal.
Number
Questionnaires
distributed
40
of
Number of respondents
YES
NO
6
1
5
308
5.
If you chose (“NO”) in Serial Number 4 (above) please specify the certificates which require
renewal and/or renewal training by completing columns 4, 5 and 6 of the table below:
Number of respondents: 2
S/N
Safety/Emergency
Response Training
Section of
STCW
Convention
Requires
Renewal Every
Five Years After
Initial
Certification
YES
1
2
3
4
5
6
7
8
9
10
6.
Familiarization
training
Personal
Survival
Techniques
Fire Prevention and
Fire Fighting
Elementary First Aid
Personal Safety and
Social Responsibilities
Proficiency in Survival
Craft and Rescue
Boats (other than Fast
Rescue Boat)
Proficiency in Fast
Rescue Boat
Advanced
Fire
Fighting
Medical First Aid on
Board Ship
Medical Care on Board
Ship
A
–
NO
2
A
–
2
A
–
2
A
–
A
–
2
A
–
2
Sect.
VI/2
Sect.
VI/3
Sect.
VI/4
Sect.
VI/4
A
–
2
A
–
A
–
2
A
–
2
possible
1
Requires
Completion of
Approved
Training
Ashore Before
Renewal
YES
NO
1
1
In your country, are seafarers with advanced training certificates (such as in Advanced Fire
Fighting, Medical First Aid, Medicare and Proficiency in Survival Craft and Rescue Boats) still
required to undertake basic safety training in Fire Prevention and Fire Fighting, Elementary
First Aid and Personal Survival Techniques before renewal of those basic safety certificates?
Number
Questionnaires
distributed
40
7.
Sect.
VI/1
Sect.
VI/1
Sect.
VI/1
Sect.
VI/1
Sect.
VI/1
Sect.
VI/2
Requires
Completion of
Approved
Training
Before Every
Renewal
YES
NO
of
Number of respondents
YES
NO
6
Nil
6
In your country, is evidence obtained from approved in-service experience utilized as a
method of demonstrating competence for certification of safety courses.
Number
Questionnaires
distributed
40
of
Number of respondents
YES
NO
5
4
1
309
8.
If Yes in No. 7, please specify the courses and format of documenting the certificates as
follows:
Number of respondents: 1
S/NO
SUBJECT
FORMAT OF DOCUMENTING
IN-SERVICE EXPERIENCE
1.
Radar/ARPA
Class ashore (every 5 yr)
2.
BRM
Class ashore-once
3.
Lifeboat man
Class ashore-once
4.
GMDSS
Class ashore-once
5.
Fire fighting
Class ashore-possible renewal
6.
Medical
“
“
“
“
9.
Do you wish for the amendment of any section of Chapter VI or any relating section of the
STCW Convention?
Number
Questionnaires
distributed
40
10.
of
Number of respondents
YES
NO
6
3
3
In view of the foregoing answers, please specify any sections of Chapter VI, or related sections,
of the STCW Convention you desire to be amended.
Number of respondents: 2 on general comment only.
Section of STCW Number of respondents
Convention
General comment: The STCW is getting more confusing.
310
Comment