D-D2.2 WORK PROCESS ANALYSIS (incl. European Manning Review)

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1 Project contract number: TIP5-CT FLAGSHIP European Framework for Safe, Efficient and Environmentally-friendly Ship Operations Instrument type: IP Specific programme: Making rail and maritime transport safer, more effective and more competitive WORK PROCESS ANALYSIS (incl. European Manning Review) Start date of project: Duration of project: 48 months Due date: December 2008 Actual delivery date: 26 th February 2009 Lead contractor: UoC, NTUA Revision: Draft 0.7

2 Document summary information Authors and contributors Initials Author Organisation Role PA Paul Allen University of Cardiff Author GR Gary Randall BMT Contributor HM Herman de Meester ECSA Contributor GB Giuseppe Balzano CONSAR Contributor RG Rocco Gargiulo CONSAR Contributor RK Rune E. Karlsen NSA Contributor HNP Harilaos N. Psaraftis NTUA Author NPV Nikolaos P. Ventikos NTUA Author SC Stefanos Chatzinikolaou NTUA Author TV Takis Varelas DANAOS Contributor AK Alexander Bjørn Kleiman Carnival Contributor TR Tony Rose Containerships Contributor UA Umberto D Amato Perseveranza Contributor ES Evert Staal KVNR Contributor AB Alfonso Balzano SEMA2 Contributor ER Eljas Rahikainen Containerships Contributor TMV Theodoor M. Vollaard KVNR Contributor Revision history Rev. Who Date Comment 0.1 PA st Draft of section I for comments. 0.2 PA / HM Amended version following comments. 0.3 PA Amended version with additional country reviews added. 0.4 PA Final Version of section I. Glossary of terms added 0.5 SC/NPV/HNP st Draft of Deliverable for comments. 0.6 SC/NPV/HNP Final version of Deliverable for comments 0.7 PA Final version with comments from the reviewer Quality Control Who Date Checked by lead partner PA, CARDIFF Checked by SP GB, CONSAR Checked by internal reviewer Richard Eastham, Regs4Ships Main responsible Company internal coding (if any) Internal reference number 2 of 153

3 Project co-funded by the European Commission within the Sixth Framework Programme ( ) Dissemination Level PU Public PP Restricted to other programme participants (including the Commission Services) RE Restricted to a group specified by the consortium (including the Commission Services) CO Confidential, only for members of the consortium (including the Commission Services) Confidential Disclaimer The content of the publication herein is the sole responsibility of the publishers and it does not necessarily represent the views expressed by the European Commission or its services. While the information contained in the documents is believed to be accurate, the authors(s) or any other participant in the FLAGSHIP consortium make no warranty of any kind with regard to this material including, but not limited to the implied warranties of merchantability and fitness for a particular purpose. Neither the FLAGSHIP Consortium nor any of its members, their officers, employees or agents shall be responsible or liable in negligence or otherwise howsoever in respect of any inaccuracy or omission herein. Without derogating from the generality of the foregoing neither the FLAGSHIP Consortium nor any of its members, their officers, employees or agents shall be liable for any direct or indirect or consequential loss or damage caused by or arising from any information advice or inaccuracy or omission herein. 3 of 153

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5 Table of contents 1. Glossary of terms Introduction Method Countries reviewed Review questions and template The Literature Review International legislation and guidelines Overview of International guidance on safe manning Review of IMO Resolution A.890 (21) European legislation / guidelines Individual European flagstates legislation / guidelines Cyprus Finland France Germany Greece Italy Malta Netherlands Norway Spain Sweden Turkey UK Conclusions Current manning regulations Future developments Observations Introduction to Work Process Analysis Scope Methodology for Work Process Analysis The Case Study Approach Brief Description and Scope of the Methodology General Description of Adopted Methodology Analysis Comparative Assessment Synthesis - Results of 153

6 7.4 Implementation of the Methodology Implemented Analysis Inputs from Questionnaire Comparative Assessment (incl. weight factors estimation) Implemented Synthesis Results Case Studies Case study #1 (container vessel) Ship information Work Processes considered in the analysis Technology onboard Analysis Results Case study #16 (ROPAX ferry) Ship information and technology onboard Analysis results Case study #9 (chemical tanker) Ship information Work Processes considered in the analysis Technology onboard Analysis results Case study #4 (Cruise vessel) Ship information Work Processes considered in the analysis Technology onboard Analysis results Conclusions from Work Process Analysis Summary of findings Watchkeeping Voyage planning Log Book & other reporting requirements ISM reporting On-board accounting Arrival and cargo related documentation Planned maintenance management Ship authorities, agencies relationship Ship office communication & data exchange Safety/security Future Work References ANNEX A (Flagship D2.2 Questionnaire) ANNEX B (Case Studies Results) CASE STUDY # of 153

7 12.2 CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # CASE STUDY # of 153

8 List of Tables Table 1: Comparison of criteria importance...53 Table 2: Case study #1, ship details...58 Table 3: Case study #1, work processes excluded from the analysis...58 Table 4: Case study #1, basic technology onboard...58 Table 5: Case study #1, supporting technology per work process...59 Table 6: Case study #1, normalised results per work process matrix...59 Table 7: Weight factors vector used for ranking calculations...61 Table 8: Case study #1, ranking of work processes according to technology performance...61 Table 9: Weight matrices and factors for criterion c 1 (added efficiency)...62 Table 10: Weight matrices and factors for criterion c 2 (added safety)...63 Table 11: Weight matrices and factors for criterion c 3 (deployment level)...65 Table 12: Weight matrices and factors for criterion 4 c (satisfaction by use)...66 Table 13: Case study #16, ship details...70 Table 14: Case study #16, work processes excluded from the analysis...70 Table 15: Case study #16, basic technology onboard...70 Table 16: Case study #16, supporting technology per work process...71 Table 17: Case study #16, normalised results matrix per work process...71 Table 18: Case study #16, ranking of work processes according to technology performance...72 Table 19: Case study #9, ship details...76 Table 20: Case study #9, work processes excluded from the analysis...76 Table 21: Case study #9, basic technology onboard...76 Table 22: Case study #9, supporting technology per work process...77 Table 23: Case study #9, normalised results per work process matrix...77 Table 24: Case study#9, ranking of work processes according to technology performance...78 Table 25: case study #4, ship details...82 Table 26: case study #4, basic technology onboard...82 Table 27: Case study #4, supporting technology per work process...83 Table 28: case study #4, normalised results matrix per work process...83 Table 29: Case study#4, ranking of work processes according to technology performance of 153

9 List of Figures Figure 1: Generic tree of the Analytical Hierarchy Process (AHP)...46 Figure 2: The hierarchical tree for the FLAGSHIP approach...49 Figure 3: The contributing questions from the questionnaire relating to the criterion added efficiency...51 Figure 4: Case study#1. Technology performance per criterion...60 Figure 5: Case study #1, overall performance based on sensitivity of added efficiency...62 Figure 6: Case study #1, overall performance based on sensitivity for added safety...64 Figure 7: Case study #1, overall performance per process based on sensitivity on deployment...66 Figure 8: Case study #1, overall performance per process based on sensitivity on satisfaction...67 Figure 9: Case study #1, overall performance per work process compared with best case scenario...68 Figure 10: Case study#1, remaining efficiency per work process...68 Figure 11: Case study #16, Technology performance per criterion...71 Figure 12: Case study #16, overall performance based on sensitivity for criterion of added efficiency...72 Figure 13: Case study #16, overall performance based on sensitivity for criterion of added safety...73 Figure 14: Case study #16, overall performance per work process compared with best case scenario...74 Figure 15: Case study#16, remaining efficiency per work process...74 Figure 16: Case study #9, performance per criterion...78 Figure 17: Case study #9, overall performance based on sensitivity for criterion of added efficiency...79 Figure 18: Case study #9, overall performance based on sensitivity for criterion of added safety...79 Figure 19: Case study #9, overall performance per work process compared with best case scenario...80 Figure 20: Case study#9, remaining efficiency per work process...80 Figure 21: Case study #4, technology performance results per work process...84 Figure 22: Case study #4, overall performance based on sensitivity for criterion of added efficiency...85 Figure 23: Case study #4, overall performance per work process compared with best case scenario...86 Figure 24: Case study#4, remaining efficiency per work process...86 Figure 25: Watchkeeping, recorded range of overall performance...89 Figure 26: Voyage planning, recorded range of overall performance...89 Figure 27: Log Book, recorded range of overall performance...90 Figure 28: ISM reporting, recorded range of overall performance...90 Figure 29: Onboard accounting, recorded range of overall performance...90 Figure 30: Arrival and cargo related documentation, recorded range of overall performance...91 Figure 31: Planned maintenance management, recorded range of overall performance...91 Figure 32: Ship-authorities, agencies relationship, recorded range of overall performance...92 Figure 33: Ship-office communication & data exchange, recorded range of overall performance...92 Figure 34: Safety/security, recorded range of overall performance of 153

10 1. Glossary of terms AIS BHP ECDIS ENC GMDSS GPS GRO GT IMO REO ROC SOLAS STCW UMS / AUT-UMS DWT wp(s) AHP PMM ISM Automatic Identification System Brake Horsepower Electronic Chart Display and Information System Electronic Navigational Chart Global Maritime Distress Safety System Global Positioning System General Radio Operator Gross Tonnage International Maritime Organization Radio Electronics Officer Restricted Operators Certificate Safety Of Life At Sea Standards of Training, Certification and Watchkeeping Unmanned Machinery Space Deadweight work process(es) Analytical Hierarchy Process Planned Maintenance Management International Safety Management Code 10 of 153

11 2. Introduction The aim of sub-project D2 is to analyses and investigate how new technology is impacting upon work processes onboard ship. Of particular concern is how health and safety is considered when work processes are changed and new equipment introduced. In this context, the first part of the project, D2.1, used a survey of seafarers to help identify the greatest sources of current resistance to new technology at sea. Despite largely positive perceptions of onboard technology, training was identified as the biggest area of current resistance. The human element was therefore highlighted as the key issue of concern: not the equipment per se, but how seafarers interact with it. A key concern in the next part of the project, D2.2, was therefore to investigate the role of the human element further. The survey in D2.1 highlighted that seafarers widely report feeling under-trained in terms of using technology onboard ship, with many having to learn on the job. When investigating the role of training, however, it is essential to also consider the integrally linked issue of crewing. Training can not be considered without investigating how crew numbers and compositions are determined and what impact new technology is having on decisions in this area. Technology D2.2 D2.1 Crew Numbers Training A literature review was therefore conducted of European countries in order to determine which criteria are currently used to determine appropriate manning numbers, and to what extent technology and new advances are affecting safe manning calculations. 11 of 153

12 3. Method 3.1 Countries reviewed A template was designed for partners of the D2.2 project to complete for different European shipping registers. For logistical reasons countries selected were determined by the availability of data to project partners. Language was also a necessary consideration. Where feasible, however, additional countries were also added to increase the scope of the review. The countries included in the review, as assigned to partners, are as follows: Country Cyprus Finland France Germany Greece Italy Malta Netherlands Norway Spain Sweden Turkey UK EU Crewing guidelines IMO Crewing guidelines Partner to review NTUA, Danaos Kursiu (now Containerships) CONS.A.R. KVNR NTUA, Danaos CONS.A.R, Perseveranza ECSA KVNR NSA/ECSA NTUA ECSA NTUA Cardiff, BMT ECSA, CESA Carnival As well as specific countries to review, partners were assigned the task of collating European and International crewing legislation and guidelines. These guidelines (e.g. IMO Resolution A.890 Principles of Safe Manning) largely set the parameters within which individual flag states define their own national regulations. 3.2 Review questions and template The review template contained four questions. Partners were asked to answer the questions in as much detail as possible for the countries assigned. The review had two distinct goals which are reflected in the questions chosen: Goal 1: Review how safe manning levels are calculated for European shipping registers Goal 2: Investigate how manning regulation is taking account of the impact of technology and the way it can impact on work processes. Based on these aims, four questions were asked in the review as follows: (1) How does the flag state currently calculate minimum crew sizes for vessels? (i.e. is there a formula? What factors are considered?) 12 of 153

13 (2) To what extent is the level of technology onboard a ship accounted for in the crew size calculations? (3) To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? (4) Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? 13 of 153

14 4. The Literature Review 4.1 International legislation and guidelines Overview of International guidance on safe manning IMO provisions on manning levels are covered by a regulation in Chapter 5 of the International Convention for the Safety of Life at Sea (SOLAS), 1974, whose requirements are backed up by resolution A.890 (21) Principles of safe manning, adopted by the IMO Assembly in 1999, as amended by Resolution A.955(23) Amendments to the Principles of Safe Manning (Resolution A.890(21)). None of the IMO provisions contain a particular formula to determine the minimum crew size for vessels. This is left to the discretion of Flag Administrations SOLAS 74 Chapter 5 - Regulation 14 Ships manning states that Contracting Governments undertake, each for its national ships, to maintain, or, if it is necessary, to adopt, measures for the purpose of ensuring that, from the point of view of safety of life at sea, all ships shall be sufficiently and efficiently manned. Furthermore, the Regulation states Every ship shall be provided with an appropriate minimum safe manning document or equivalent issued by the Administration as evidence of the minimum safe manning considered necessary to comply with the provisions. IMO Resolution A.890 (21) adopted on 25 November 1999 Principles Of Safe Manning, adopts the Principles of safe manning, the Guidelines for the application of principles of safe manning and the Guidance on contents and model form of minimum safe manning document, set out respectively in the Annexes to the resolution. It recommends that Governments, in establishing the minimum safe manning levels for ships flying their countries' flag, observe the Principles set out in Annex 1 and take into account the Guidelines set out in Annex 2; and urges Governments to ensure that minimum safe manning documents contain, as a minimum, the information given in Annex 3. The Resolution urges further Governments, when exercising port State control functions under international conventions in force with respect to foreign ships visiting their ports, to regard compliance with such documents as evidence that such ships are safely manned. In addition to SOLAS and IMO Resolution A.890 (21), the International Safety Management (ISM) Code 2002 sets out requirements regarding safe manning focused on crew competence and training: ISM Code section 6.2: The Company should ensure that each ship is manned with qualified, certificated and medically fit seafarers in accordance with national and international requirements. 14 of 153

15 ISM Code section 6.3: The Company should establish procedures to ensure that new personnel and personnel transferred to new assignments related to safety and protection of the environment are given proper familiarization with their duties Review of IMO Resolution A.890 (21) IMO Resolution A.890 (21) Principles of Safe Manning is a non-mandatory IMO instrument that is used by flag administrations as a guide only. As with many IMO resolutions, it is open to different interpretations, which can vary widely from administration to administration. This can result in the minimum safe manning requirements differing, sometimes significantly, by flag administration even for similar sized and designed ships. Where IMO resolution A.890 (21) is entitled principles of safe manning, the key concept to understand is principles : the document goes little further than laying out some very fundamental first principles in terms of what should be understood by safe manning. The guidance given is broad and non-specific as illustrated by the examples below: Example from Annex 1 of IMO resolution A.890 (21) Principles of safe manning. The following principles should be observed in determining the minimum safe manning of a ship. The capability to: maintain safe navigational, engineering and radio watches in accordance with regulation VIII/2 of the 1978 STCW Convention, as amended, and also maintain general surveillance of the ship; moor and unmoor the ship safely; manage the safety functions of the ship when employed in a stationary or nearstationary mode at sea; perform operations, as appropriate, for the prevention of damage to the marine environment; maintain the safety arrangements and the cleanliness of all accessible spaces to minimize the risk of fire; provide for medical care on board ship; ensure safe carriage of cargo during transit; inspect and maintain, as appropriate, the structural integrity of the ship; Example from Annex 2 of IMO resolution A.890 (21) Principles of safe manning. The minimum safe manning level of a ship should be established taking into account all relevant factors, including the following: size and type of ship; number, size and type of main propulsion units and auxiliaries; construction and equipment of the ship; method of maintenance used; cargo to be carried; 15 of 153

16 frequency of port calls, length and nature of voyages to be undertaken; trading area(s), waters and operations in which the ship is involved; extent to which training activities are conducted on board; applicable work hour limits and/or rest requirements. 4.2 European legislation / guidelines Specific EU Crewing guidelines do not exist, however there are regulations which are of clear relevance to this issue. In particular there is the EU Working Time Directive. To stay within these regulations it is necessary for shipping companies to employ sufficient qualified crew so that no individual seafarer exceeds the legally stipulated maximum hours of work. Current working time directives (enforced in September 2002) as they apply to seafarers employed on board EU registered vessels state that maximum hours of work shall not exceed either 14 hours in any 24-hour period and 72 in any 7-day period.. (clause 5, 1a) or minimum hours of rest shall not be less than 10 hours in any 24-hour period and 77 hours in any 7-day period (clause 5, 1b). Furthermore, that Hours of rest may be divided into no more than two periods, one of which shall be at least 6 hours in length, and the interval between consecutive periods of rest shall not exceed 14 hours (clause 5, 2). The Working Time Directive therefore has relevance to the issue of safe manning in EU waters - although only to the extent that vessels in these waters are registered in the EU. 4.3 Individual European flagstates legislation / guidelines Manning regulations for individual European flagstates were investigated. The findings of this review are reported below, in alphabetical order of country. 16 of 153

17 4.3.1 Cyprus How does the flag state currently calculate minimum crew sizes for vessels? New regulations, in force since 2006, included tables for the calculation of crew sizes. Under these regulations the crew is divided into bridge personnel and machinery space personnel. The calculation of the minimum bridge personnel requirements is based on ship type, gross tonnage (GT) and voyage type. The minimum number of machinery space personnel is dependent on ship type, propulsion power, voyage area and the existence or not of an UMS. Ship types considered: 1. Cargo ships (all categories) 2. Passenger ships (all categories) 3. Tug ships Ship types not considered are: navy vessels, state vessels of no commercial purpose, pleasure vessels not used for commercial purposes and traditional vessels (primitive marine structures) To what extent is the level of technology onboard a ship accounted for in the crew size calculations? The level of automation onboard a vessel is considered as part of Cyprus regulations. The existence of an UMS affects the number of machinery space personnel. The presence of a GMDSS system may also reduce the number of bridge personnel To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? Technological training is not considered in the calculation of minimum manning levels. The only exception to this is the introduction of the GMDSS. The installation of this system under Cyprus regulations may reduce the crew size if specific requirements (concerning the technological training of personnel onboard) are met Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? a) GPS There was no change in the calculation of safe manning levels following the introduction of GPS. 17 of 153

18 b) ECDIS ECDIS has been accepted (2006) as meeting the nautical charts and nautical publications carriage requirements stipulated in Regulation V/ and V/27 of SOLAS 74 as amended. No changes in crew size calculations have so far been made following the acceptance of this system. c) UMS Theoretically, there are differences in minimum machinery space manning levels for UMS and non UMS vessels. These are subject to the total engine s power (BHP in Kw), the ship type and the area of operation. It has to be stated, however, that the theoretical model stipulated within the national regulations is not always followed. This is because a case by case approach to manning is preferred by the Cyprus Administration. The following tables show minimum machinery space manning requirements for cargo ships under different voyage categories. Table 1: Voyage in restricted areas. Cargo ships. BHP (kw) < >8000 UMS no no no no no no 1 st engineer nd engineer rd engineer crew (A) crew (B) total Table 2: Medium voyage. Cargo ships. BHP (kw) < >8000 UMS no no no no no no 1 st engineer nd engineer rd engineer crew (A) crew (B) total Table 3: Global voyage. Cargo ships. BHP (kw) < >8000 UMS no no no no no no 1 st engineer nd engineer rd engineer of 153

19 crew (A) crew (B) total of 153

20 4.3.2 Finland How does the flag state currently calculate minimum crew sizes for vessels? There is no formula for calculating crew sizes, but there is a formal manning procedure. A ship owner needs to apply to the Finnish Maritime Association for a Certificate of Minimum Safe Manning indicating the minimum safe manning of the ship and the composition and competence of the crew for different traffic areas. When confirming the manning of the ship the following factors are taken into account: Safe watchkeeping, the size and type of the vessel, the cargos carried on board, the propulsion power of the ship, the degree of automation of the machinery, the general standard of equipment, service and maintenance of the ship, the traffic area, the number of passengers, catering, sanitation and training given on board To what extent is the level of technology onboard a ship accounted for in the crew size calculations? Level of technology is not directly considered except in the engine room, but generally the relationship between technology & crew size is dealt with through competence requirements as crew members must have the competence required for their respective positions. Positions link back to safe manning of the vessel. The degree of automation of the machinery clearly has an effect on engine room crew size (e.g. UMS) To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? Technology available onboard is included in issuing certificates of competence. This may or may not Weight crew size directly, but is seen as means of ensuring safe manning. As maritime has its traditions both good and bad- the hierarchical position of crew member may have more of an impact than the actual level of technological training he/she possesses. Hierarchy / structure might therefore be preferenced over ability in this context. In order to have an effect on crew size the roles/positions of crew members would need to be more loose. In short there is no effect on crew size Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? Historically, only UMS had an affect on crew size in terms of a smaller number of crew in the engine room. It could be argued that communication technology also has changed crew sizes as vessels no longer carry a Radio Officer on board anymore. 20 of 153

21 4.3.3 France How does the flag state currently calculate minimum crew sizes for vessels? The French system for determining minimum crew sizes is primarily based on IMO Res.A890 (21) and does not involve a particular crew composition formula. The State regulation is old and dates back to 1967 (Decree of May 26th 1967). Generally the ship owner suggests to the Administration the composition of crew that he/she considers to be appropriate by taking into account the technical requirements of the ship and it s commercial purposes. This manning proposal may have been previously discussed by the ship owner and representatives of the seafarers. If the Administration considers the proposal insufficient, the ship owner has to modify the composition of the crew. The following are the main parameters considered when proposing an appropriate crewing level: - Stakeholders have to respect legal rest periods; - The number of crew must be sufficient to cope with emergency situations To what extent is the level of technology onboard a ship accounted for in the crew size calculations? There is no mention in French regulation concerning level of technology as a determinant of appropriate crewing levels. The only reference to technology relates to the level of automation onboard the ship To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? Technological training is again another matter not specifically mentioned in French crewing regulations Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? The introduction of new technologies such as GPS, ECDIS and UMS has not Weightd manning level regulations. The degree of automation onboard a ship is considered to some extent, but even this notion is now somewhat outdated. 21 of 153

22 4.3.4 Germany How does the flag state currently calculate minimum crew sizes for vessels? Legislation for Germany is similar to that of the Netherlands To what extent is the level of technology onboard a ship accounted for in the crew size calculations? If there is clear evidence of reduction of workload onboard a German vessel the administration might take this into consideration To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? If there is clear evidence of reduction (or handling) of workload onboard a German vessel the administration might take this into consideration Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? From agenda discussions at IMO: Regarding mandatory ECDIS requirements, in 2015 it is expected that the majority of ships will be equipped with this system. The present hard copy port folio of charts will disappear, resulting in a corresponding change in working patterns. In many cases this will result into a substantial reduction of work related to voyage planning. 22 of 153

23 4.3.5 Greece How does the flag state currently calculate minimum crew sizes for vessels? The country s competent authorities calculate minimum crew sizes based on IMO Resolution A.890. Therefore, theoretically, the factors considered are those indicated in the Resolution. Passenger ships The review has revealed that in terms of calculating crew sizes, a specific formula is only used in practice for one class of vessel: passenger ships. This crewing formula was introduced in Despite technological improvements since then, no major changes have been made to the formula over this time. The factors considered in the calculation of crew sizes for passenger ships does not include the existence (or not) of automation in machinery space. The factors included in the calculation of crew numbers are: 1. Type of vessel (conventional passenger vessel, high speed vessel); 2. Voyage extent (hours of continuous voyage); 3. Domestic/International voyages; 4. Vessel s BHP (in Kw); 5. Vessel s GT (weight/size); 6. Number of engine rooms; 7. Number of passengers onboard; 8. Number of passenger cabins or number of beds; 9. Type of restaurant facilities onboard; and 10. Period of operation (summer or winter). It should be also stated that the Greek Authorities approach the safe manning of passenger ships from a political perspective due to the importance of the domestic passenger ship sector. This has resulted in increased crew numbers compared with those of other flag states. Cargo ships The formulae for calculating crew sizes onboard cargo ships introduced in 1987 are now of no practical use. The new rules followed do not contain specific tables for the calculation of minimum manning levels. Currently, the safe manning of cargo ships does not follow a specific formula and crew composition is worked out on a case-by-case basis. The owner of a ship will submit a proposal for the ship s manning to the National Authority (namely the Ministry of Mercantile Marine) who will then accept it as it is or propose appropriate amendments. In general, the key factors used to calculate crew sizes onboard cargo ships are: 1. Vessel s GT; 2. Vessel s BHP; 3. Type of cargo; 23 of 153

24 4. Area of operation; 5. Machinery space automation (UMS) To what extent is the level of technology onboard a ship accounted for in the crew size calculations? Technologies affecting crew size calculations are as follows: 1. UMS. To what extent this technology is accounted for in crew size calculations is not known due to the case-by-case approach that the Greek flag applies. The standard rules are that for UMS ships of GT or more the employment of 1st, 2nd, and 3rd Engineer is mandatory. For UMS ships of GT a 3rd Engineer is not mandatory. No standard rules are applied for lower machinery space personnel. 2. GMDSS. Generally there is a reduction in crew size due to the introduction of this system. The reduction is dependant on the technological training of the onboard personnel and is therefore described in more detail below. 3. Centralised Cargo Control Room (for tankers). In tankers equipped with a centralised cargo control room the employment of a pump room dedicated person is not mandatory To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? On ships in which a GMDSS system is used there can be changes in crew size dependant on the technological training of the personnel onboard. For sea area A1, if one of the crew members holds a Restricted Operator s Certificate (ROC), a Radio Officer may not be employed. For sea areas A2, A3, and A4, if two of the crew members hold a General Operator s Certificate (GOC), or a Radio Electronic Officer s (REO) certificate, a Radio Officer may not be employed. In case maintenance is required on the radio system during a voyage, at least one of the crew members should hold a REO certificate Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? a) GPS No changes were made to crewing calculations following the introduction of GPS. b) ECDIS The Flag of Greece accepts the use of ENCs in ECDIS for primary navigation on all its registered vessels when used in accordance with the provisions set out in IMO s A817(19) Resolution. Back-up arrangements include the use of either a second ECDIS device using ENCs, maintained by an independent power supply, or sufficient paper charts covering the operating area. No changes in the crew size calculations were introduced following this acceptance. 24 of 153

25 c) UMS In general, the introduction of UMS has resulted in reductions in machinery space personnel. The national regulations for minimum manning levels (prior to the introduction of UMS) contained specific formulas for the calculation of crew sizes. However, the new regulations which adopt IMO s Resolution for the Principles of Safe Manning do not clearly specify the level of reduction leaving the field open for a case-by-case approach which is widely adopted for cargo ships. There are some standards related to engine officers (see above). 25 of 153

26 4.3.6 Italy How does the flag state currently calculate minimum crew sizes for vessels? Main ship crewing Italy follows IMO Resolution A.890 (21) modified by Resolution A.955 (23). In addition, the Legislative Decree n.108 of May 27th 2005 specified that crew sizes for merchant ships should be calculated by taking into account: a) the need to avoid or reduce to a minimum level the tiredness of the seafarer, so that adequate rest periods are ensured in conjunction with ship type and type of trade. b) the need for a sufficient number of personnel onboard to ensure the safety of navigation and compliance with minimum manning tables as issued by the Government. In order to insure that a ship s crew is sufficient in number and quality to properly operate a vessel, the ship owner must: a) make an assessment of the duties, functions and responsibilities of crew members in order to appropriately manage the ship s operations, particularly during emergency situations. b) ensure a proper quantitative and qualitative level of crew to manage both normal and emergency periods of operation. c) ensure periods of rest are respected as defined by Decree 108/2005. d) determine the required number and qualification of all crew components. One of the key parameters in defining minimum safe manning levels is fatigue, both relating to the ship (level of automation, reliability of devices, life and work conditions, etc.) and the crew (training, experience, qualification). Cadets The Italian Flag has a history of protecting the employment of cadets (who are, of course, the next generation of officers). The Italian International Register of ships was first introduced in 1998 and made it possible to employ foreign crew, even from outside the EC, onboard. It was still required, however, that Italian Flagged vessels had a minimum of one deck and one engine cadet of Italian nationality. This was encouraged by government subsidies up until the year In 2002, when subsidies from the Italian Government were no longer granted,"tonnage Tax" was introduced in EC countries which granted tax benefits on the basis of employing at least one cadet on board (either deck or engine) of the same nationality as the EC Flag of the vessel. Cadets are normally considered extra crew members as they cannot perform any safety duties To what extent is the level of technology onboard a ship accounted for in the crew size calculations? Level of technology is accounted for primarily in terms of the management of fatigue. The degree of automation and reliability of onboard devices is also considered. 26 of 153

27 To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? Level of training in general, not only in connection with technology, is most important in terms of the management of fatigue. Suitability for a task, appropriate qualifications, work experience and characteristics of a crew member also have to be considered in this context Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? AUT-UMS certification theoretically allows a reduction in crew numbers, but this does not happen in practice following trade union discussions. Similarly, fitting ECDIS and/or AIS, both aids to navigation, does not automatically translate into a reduction in crew numbers. 27 of 153

28 4.3.7 Malta How does the flag state currently calculate minimum crew sizes for vessels? The safe manning of ships registered in Malta is regulated by the Merchant Shipping (Safe Manning and Watchkeeping) Regulations of , as amended by Legal Notice 350 of These regulations do not lay down minimum crew sizes but requires that every sea-going Maltese ship of over 500 GT (except fishing vessels and pleasure craft) carries a valid safe manning certificate. A safe manning certificate is issued by the Registrar-General of Shipping & Seamen and stipulates a minimum number of crew necessary for the sufficient and efficient manning of the ship from the point of view of safety of life at sea and pollution prevention. The principles and guidelines used by the Malta Maritime Authority to determine the minimum safe manning of a ship are in accordance with IMO Resolution A.890 (21) and the STCW Code To what extent is the level of technology onboard a ship accounted for in the crew size calculations? In issuing a safe manning certificate account is taken of the technology available on board the vessel (e.g. GMDSS and UMS) only to the extent that this is covered by the principles and guidelines of the IMO resolution and the STCW code. For example, on a vessel carrying an UMS Certificate, one engineering officer may be omitted. The local regulations (Legal Notice 29 0f 2003) give authority to the Registrar of Shipping, at the request of the shipowner, to exempt certain ships from certain requirements. In doing so, however, the Registrar is still required to follow the guidance of IMO directives, rules and recommendations. In practice, departures from the normal standards are rarely made To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? No detail available. Most likely not at all Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? See under 1, subject to IMO rules & guidelines. 28 of 153

29 4.3.8 Netherlands How does the flag state currently calculate minimum crew sizes for vessels? The manning legislation for Holland is goal-based and relates to IMO legislation (Resolution A ). Factors considered include: - Region (of sailing) - Type of ship - Type of cargo - Level of technology To what extent is the level of technology onboard a ship accounted for in the crew size calculations? If there is clear evidence of reduction of workload onboard a Dutch vessels the administration might take this into consideration To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? If there is clear evidence of reduction (or handling) of workload onboard a Dutch vessel the administration might take this into consideration Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? From agenda discussions at IMO: Regarding mandatory ECDIS requirements, in 2015 it is expected that the majority of ships will be equipped with this system. The present hard copy port folio of charts will disappear, resulting in a corresponding change in working patterns. In many cases this will result into a substantial reduction of work related to voyage planning. At present many Dutch ships are already equipped with a dual fuel ECDIS system. A positive impact is generally reported from crew members working on such vessels. 29 of 153

30 4.3.9 Norway How does the flag state currently calculate minimum crew sizes for vessels? Norwegian manning regulations are based upon a report from a manning committee with representation from the government, the seafarers organisations and the shipowners organisations. It is based on safety functions to be carried out (see below) and a 3 or 2 watch system. Former regulations used fixed manning scales based on Gross Tonnage. All ships have to apply for a manning report on an individual basis. This is the basic structure of the regulation with the aim to take into consideration the development of technical, organisational and other issues. To be operational on a general basis, some "standard" manning guides have developed over the years. To deviate from these "standards" the company has to support their application by proving that the alternative manning arrangement will be able to cope with all safety related tasks (see below). 5. Regarding basic manning levels the evaluation will take into consideration the technical standard of the ships, the effect of the mechanical propulsion, administrative and organizational arrangements, alternations, job combinations or/and overlapping competence, tonnage, trade areas and the working hours arrangements to be applied in each case. The circumstances shall be adapted with the view to achieving the highest possible degree of wellbeing on board both in work and leisure. 6. The minimum safe manning level determined in accordance with this section shall cover such safety related tasks as are appropriate to the vessel, including: 6.1. Compulsory watchkeeping at sea and in port as stipulated by the current regulations concerning watchkeeping on passenger and cargo ships Use and survey of life-saving and fire-fighting equipment, including compulsory drills Use, operational/technical survey and inspection of machinery, automation, supervision and control systems Use, operational/technical survey and control of navigational equipment and communication installations Mooring of the ship Catering requirements of the crew. 30 of 153

31 6.7. Monitor the loading and securing of the cargo with regard to stability, trim, fire prevention, pollution, etc Supervise loading and securing of the cargo with regard to stability, trim, fire, pollution, etc Making the ship ready for the voyage (ship shape) Inspection of the intake of bunkers, supplies, equipment, etc Required cleaning Other safety operations To what extent is the level of technology onboard a ship accounted for in the crew size calculations? More or less based on "state of the art" on modern well equipped ships (UMS, autopilot, addressing systems, rational mooring and other technical arrangements) To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? None Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? a) GPS None. b) ECDIS None. c) UMS UMS, when it was introduced in the 70 s, reduced the number of engine ratings, due to reducing engine watch keeping duties. 31 of 153

32 Spain How does the flag state currently calculate minimum crew sizes for vessels? The Spanish Regulation on safe manning, theoretically still in force, is from It is not, however, applied in practice. It was based on objective criteria such as GT, BHP, etc. but allowed for a case-by-case application, taking into account the degree of automation. There is also a very short article in Law 27/1992, on Ports and Merchant Marine, which states that the Maritime Administration will determine the safe manning level and produce the corresponding certificate on the basis of a proposal from the ship-owner. In practice, the owner or operator submits a proposal which is normally accepted and occasionally slightly amended by the Administration To what extent is the level of technology onboard a ship accounted for in the crew size calculations? Not known To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? Not known Historically, how did crewing calculations change when the following technologies were introduced to the industry? (a) GPS (b) ECDIS (c) UMS? On two occasions since 1992 there have been attempts to review the 1964 regulations, to try and establish some objective criteria for calculating safe manning levels. In practice, however, the Weight of the introduction of GPS, ECDIS, and UMS on crewing calculations is not known. 32 of 153

33 Sweden How does the flag state currently calculate minimum crew sizes for vessels? There are two types of certificates which affect the number of crew. One is the safety manning certificate which states the minimum number of crew for taking the ship from A to B (cargoshipcondition with no passengers on board). The other concerns the safety organisation which is based on the number of passengers on board and the ship s capacity to evacuate in accordance with SOLAS requirements. This figure is variable depending on organisation and evacuation systems. The Administration s decision regarding a safety manning certificate is mainly based on the following factors: - Type of vessel (Passenger, tanker, dry cargo). - Size of the ship. - Trade area. (International or National). - Engine power To what extent is the level of technology onboard a ship accounted for in the crew size calculations? The case for a manning pay-off in terms of technological investment onboard ship is weak and therefore going down this route can be a difficult decision for ship owners to take. In general, ship owners tend to have to over convince both the administration and unions in this matter. There have, however, been some recent developments in this area: - The E0-certificate for the engine control room is in one concrete example of how level of technology onboard ship can reduce crew numbers. With an E0 certificate (periodically unmanned machinery space) there is a direct reduction in the number of engine crew in the safety manning certificate. - In the deck department one can see the same example with ships equipped with auto-mooring systems where the number of AB s [able seamen] can be reduced accordingly. Also automatic lashing devices reduces the number of deck crew required. - Evacuation systems. As mentioned above, the safety organisation size depends on the ship s capacity to evacuate in accordance with SOLAS requirements. If it can be proved that the ship s evacuation system demands a smaller number of crew then the number will be reduced on the certificate To what extent is the level of technological training onboard a ship accounted for in the crew size calculations? Not at all. 33 of 153