We have not asked Captain Alvils --- of the Philippine Maritime Service --- who is clearly a master mariner of long service and high integrity, for permission to reprint his comments on maritime education and training. We do not wish to violate international copyright laws, but we found his remarks so compelling and heartfelt, and so relevant to our own message, that we are taking the liberty of reproducing his latest writings here as an example of what can happen when a country does not carefully monitor its standards of training and certification for maritime personnel, in the hope and expectation that he will grant us reprint permission after the fact .
We are confident that his public comments, reproduced below with very minor editing, will serve as a beacon of light for those concerned with maritime education and training everywhere :
The Philippine seafaring industry is in a precarious situation. The country stands to lose not only millions of dollars of annual remittances but also employment opportunities for hundreds of thousands of Filipino seamen hired by European flagged vessels unless corrective measures on maritime standards are complied with, particularly the elimination of schools and training institutions offering inferior-quality maritime education.
March 7 to 14 2012, European Maritime Safety Agency (EMSA) officials conducted an inspection visit, the fourth one of this kind since 2006, to check the compliance of Philippine maritime schools, training centers and government measures with standard rules. The results were very alarming, not only for our shipping and seafaring industry but for the entire nation as well. The majority of our maritime schools and training institutions continue to incur deficiencies, some --- especially those located outside metropolitan Manila and outlaying provinces --- operate in substandard conditions, i.e. inadequate equipment, incomplete facilities, lack of academic systems and standards, instructor’s guide, teaching aids, books, unqualified teaching staffs, etc.
March 7 to 14 2012, European Maritime Safety Agency (EMSA) officials conducted an inspection visit, the fourth one of this kind since 2006, to check the compliance of Philippine maritime schools, training centers and government measures with standard rules. The results were very alarming, not only for our shipping and seafaring industry but for the entire nation as well. The majority of our maritime schools and training institutions continue to incur deficiencies, some --- especially those located outside metropolitan Manila and outlaying provinces --- operate in substandard conditions, i.e. inadequate equipment, incomplete facilities, lack of academic systems and standards, instructor’s guide, teaching aids, books, unqualified teaching staffs, etc.
The Department of Labor and Employment (DOLE) explained that the failure of the Philippines to rectify deficiencies pointed out by EMSA will trigger the European Commission’s withdrawal of the European Union's recognition of certificates issued by the Philippine government to Filipino seamen that will result in the refusal of EU flagged vessels to hire Filipino seafarers.
It also follows that the withdrawal of EU’s recognition could threaten the position of the Philippines in the International Maritime Organization (IMO) “white list” countries that are compliant with the International Convention on Standards of Training, Certification and Watchkeeping (STCW) for Seafarers and will definitely have a detrimental effect not only on the country’s reputation in the international maritime community but also on the nation’s economy.
Labor Secretary Rosalinda Baldoz said, “We welcome this follow up visit of EMSA as an opportunity for the Philippine government to prove its efforts to continuously improve its maritime education, training and certification system,” . Adding, “We have already met and coordinated with all concerned parties involved in the follow up visit to ensure the corrective actions previously reported to EMSA are being implemented.”
But her statement is more of a lip service to appease the EU inspectors rather than genuine measures to address the deteriorating system of Philippine maritime education.
As early as 2006, EMSA audit findings already showed that Philippine maritime schools were non-compliant with STCW 78 (as amended). Government agencies alluded to the proliferation of “fly-by-night” maritime schools due to high demand of seafarers abroad. Any schools can offer maritime related courses so long as they can complete documentary requirements and meet the minimum standards set by Commission on Higher Education (CHED). They are often allowed to exist despite operating below the minimum standard, albeit under provisional status, provided they can rectify their deficiencies by next inspection. More often than not, no one does; they simply request an extension of deadline from the CHED . The latter, for so long, have continuously tolerated this blatant disregard and circumvention of rules lest they displace thousands of students, whose only ambition in life is to one day be a seaman, if they close down a non-compliant maritime institution.
“They operate with impunity, prioritizing income more than academic standards and without fear of reprisal from CHED, the lone government agency that regulates maritime education”, said one maritime educator.
While EMSA inspectors confirmed that the authorities and maritime education institutions did take appropriate actions to correct the presumed deficiencies, the actions taken were unsatisfactory.
In relation to the maritime administration, some corrective actions have not been taken. These are:
1. The quality of standards system in place at the MTC, TESDA and CHED;
2. The program and course review procedure in place at CHED;
3. The implementation and monitoring of on-board training;
4. The validation of the training record book; and
5. The implementation of the management level courses (MLC).
The MLC had been approved in 2005 but not implemented at the time of the 2006 inspection. During the inspection, EMSA inspectors established that the content of the programs did not fully comply with the relevant standards of competence required in tables A-II/2 and A-III/2 of the STCW Code. Considerable numbers of items of the code were omitted. Furthermore, the EMSA inspectors confirmed that the majority of the candidates were exempted from completing the program, the reason being that the MTC and PRC consider seagoing service as equivalent to education. For this purpose, the MTC has approved, through Resolution No 5, series 2009, a table of equivalency that was used to exempt candidates from attending the full program. However, the STCW Convention does not permit such equivalence.
In relation to maritime institutions, the EMSA inspectors established that some corrective actions had not been taken or were not satisfactory. These are:
Philippine Maritime Institute
Ø Quality Management System (QMS) - With the exceptions of internal audits and management reviews, no action taken;
Ø Training equipment - Still missing, not adequately used, or creating safety hazards;
Ø Simulators - Insufficient number of exercises, inappropriate training objectives and performance criteria, no evidence that testing and validation of training exercises had been conducted.
University of Cebu
Ø Training equipment - The equipment installed in the laboratories used by the regular students (those not enrolled in the Norwegian program) in electrical, electronic, and control engineering did not allow them to acquire the skills and to demonstrate competence in those domains. This was the same equipment that was in use at the time of the 2006 inspection.
University of Visayas
Ø Training equipment - Preventive maintenance was not conducted;
Ø The equipment used in the electronic and electro technical laboratory, that was in use at the time of the 2006 inspection, was inadequate for basic understanding and gaining practical skills;
Ø The system implemented in the steam plant machinery workshop was intrinsically unstable, with a dangerous risk of uncontrolled over-speed;
Ø Simulators - The number of Radar/ARPA exercises was still insufficient to cover training in the necessary skills -– only two exercises with two and three targets, respectively –- and there were no exercises developed for the GMDSS simulator.
Had the EU inspectors visited maritime schools outside Metropolitan Manila, they would have been horrified by their findings.
CHED, MTC , TESDA, POEA and other government institutions involved in maritime training, education and employment continue to be headed by government appointees who have no knowledge whatsoever about shipping and seafaring. The implication is that seafarers and the STCW itself are chiefly an employment matter. Exporting labor may be essential to keep the economy going but placing seafarers' concerns under the auspices of government administrators, and equating shipping, seafaring, and maritime affairs with an ordinary government office is a misguided policy.
If the government continues to group seafarers together with land-based migrant workers, the result will be catastrophic for the country. The merchant marine profession and the shipping industry in general have a technological dimension that is beyond the field of expertise of a labor secretary or a highly regarded political appointee.
For many years, concerned seafarers have been imploring the government to set politics aside and to leave shipping and seafaring to experts. It is a proven fact that for many decades CHED and MTC could not function without the aid of expert mariners from the private sector whom they continue to engaged as volunteers to constitute its technical working group (TWG).
For the nth time, I wish to reiterate to our lawmakers the following solutions (perhaps the only solutions) to completely eliminate the cause of malaise that afflicts this seafaring and maritime nation:
1) Create a “Maritime Department” section under CHED composed of Master Mariners, Chief Engineers and Marine deck and engine officers with Masters and Doctorate degrees. It is obvious that the people who have these qualifications are the members of its technical working group;
2) Amend the existing laws on Filipino Migrant Workers Act (RA 10022). It has remain detrimental and unfavorable to the business of manning and seafaring. It was passed into law without considering its negative effect on the maritime industry;
3) Separate/segregate sea-based from land-based employment. Because of the stringent requirements of the International Maritime Organization (IMO) Convention on STCW, where the Philippines is a party to this convention, not to mention the time spent on maritime education, rigorous training, and the complex process of licensing and certification, sea-based education needs to have its own identity, different from that of ordinary Overseas Foreign Workers (OFW). To attain this objective, we need to revive the defunct National Seaman’s Board (NSB), formerly in charge of deployment of seafarers, and managed by people knowledgeable in shipping and seafaring.
4) Replace the head of MARINA, MTC and TESDA with people who have extensive sea experience and full knowledge of various international conventions, rules, and shipping laws, particularly an experienced Master Mariner with excellent supervisorial and managerial skills.
It is not so difficult to search for the right person for the job and to find the courage and political will to initiate reforms and replace these incumbent government officials.
Those who perceive and brag that Filipino seafarers are indispensable because of their dominant numbers should have their heads examine. We don’t own the ships, but only serve at the pleasure of its owners. We cannot continue to ignore and defy convention rules that ship owners themselves ratified and pledged to abide, nor will the ship owners compromise the safety of their vessels in exchange for numerical superiority.
The threat of EMSA and the dire consequences of being delisted from IMO’s “White List” are similar to the Fukushima nuclear meltdown. Unless an immediate solution is found, there will be chaos in Luneta Park and our supposedly productive seafaring industry will end up at the bottom of the pit.
It also follows that the withdrawal of EU’s recognition could threaten the position of the Philippines in the International Maritime Organization (IMO) “white list” countries that are compliant with the International Convention on Standards of Training, Certification and Watchkeeping (STCW) for Seafarers and will definitely have a detrimental effect not only on the country’s reputation in the international maritime community but also on the nation’s economy.
Labor Secretary Rosalinda Baldoz said, “We welcome this follow up visit of EMSA as an opportunity for the Philippine government to prove its efforts to continuously improve its maritime education, training and certification system,” . Adding, “We have already met and coordinated with all concerned parties involved in the follow up visit to ensure the corrective actions previously reported to EMSA are being implemented.”
But her statement is more of a lip service to appease the EU inspectors rather than genuine measures to address the deteriorating system of Philippine maritime education.
As early as 2006, EMSA audit findings already showed that Philippine maritime schools were non-compliant with STCW 78 (as amended). Government agencies alluded to the proliferation of “fly-by-night” maritime schools due to high demand of seafarers abroad. Any schools can offer maritime related courses so long as they can complete documentary requirements and meet the minimum standards set by Commission on Higher Education (CHED). They are often allowed to exist despite operating below the minimum standard, albeit under provisional status, provided they can rectify their deficiencies by next inspection. More often than not, no one does; they simply request an extension of deadline from the CHED . The latter, for so long, have continuously tolerated this blatant disregard and circumvention of rules lest they displace thousands of students, whose only ambition in life is to one day be a seaman, if they close down a non-compliant maritime institution.
“They operate with impunity, prioritizing income more than academic standards and without fear of reprisal from CHED, the lone government agency that regulates maritime education”, said one maritime educator.
While EMSA inspectors confirmed that the authorities and maritime education institutions did take appropriate actions to correct the presumed deficiencies, the actions taken were unsatisfactory.
In relation to the maritime administration, some corrective actions have not been taken. These are:
1. The quality of standards system in place at the MTC, TESDA and CHED;
2. The program and course review procedure in place at CHED;
3. The implementation and monitoring of on-board training;
4. The validation of the training record book; and
5. The implementation of the management level courses (MLC).
The MLC had been approved in 2005 but not implemented at the time of the 2006 inspection. During the inspection, EMSA inspectors established that the content of the programs did not fully comply with the relevant standards of competence required in tables A-II/2 and A-III/2 of the STCW Code. Considerable numbers of items of the code were omitted. Furthermore, the EMSA inspectors confirmed that the majority of the candidates were exempted from completing the program, the reason being that the MTC and PRC consider seagoing service as equivalent to education. For this purpose, the MTC has approved, through Resolution No 5, series 2009, a table of equivalency that was used to exempt candidates from attending the full program. However, the STCW Convention does not permit such equivalence.
In relation to maritime institutions, the EMSA inspectors established that some corrective actions had not been taken or were not satisfactory. These are:
Philippine Maritime Institute
Ø Quality Management System (QMS) - With the exceptions of internal audits and management reviews, no action taken;
Ø Training equipment - Still missing, not adequately used, or creating safety hazards;
Ø Simulators - Insufficient number of exercises, inappropriate training objectives and performance criteria, no evidence that testing and validation of training exercises had been conducted.
University of Cebu
Ø Training equipment - The equipment installed in the laboratories used by the regular students (those not enrolled in the Norwegian program) in electrical, electronic, and control engineering did not allow them to acquire the skills and to demonstrate competence in those domains. This was the same equipment that was in use at the time of the 2006 inspection.
University of Visayas
Ø Training equipment - Preventive maintenance was not conducted;
Ø The equipment used in the electronic and electro technical laboratory, that was in use at the time of the 2006 inspection, was inadequate for basic understanding and gaining practical skills;
Ø The system implemented in the steam plant machinery workshop was intrinsically unstable, with a dangerous risk of uncontrolled over-speed;
Ø Simulators - The number of Radar/ARPA exercises was still insufficient to cover training in the necessary skills -– only two exercises with two and three targets, respectively –- and there were no exercises developed for the GMDSS simulator.
Had the EU inspectors visited maritime schools outside Metropolitan Manila, they would have been horrified by their findings.
CHED, MTC , TESDA, POEA and other government institutions involved in maritime training, education and employment continue to be headed by government appointees who have no knowledge whatsoever about shipping and seafaring. The implication is that seafarers and the STCW itself are chiefly an employment matter. Exporting labor may be essential to keep the economy going but placing seafarers' concerns under the auspices of government administrators, and equating shipping, seafaring, and maritime affairs with an ordinary government office is a misguided policy.
If the government continues to group seafarers together with land-based migrant workers, the result will be catastrophic for the country. The merchant marine profession and the shipping industry in general have a technological dimension that is beyond the field of expertise of a labor secretary or a highly regarded political appointee.
For many years, concerned seafarers have been imploring the government to set politics aside and to leave shipping and seafaring to experts. It is a proven fact that for many decades CHED and MTC could not function without the aid of expert mariners from the private sector whom they continue to engaged as volunteers to constitute its technical working group (TWG).
For the nth time, I wish to reiterate to our lawmakers the following solutions (perhaps the only solutions) to completely eliminate the cause of malaise that afflicts this seafaring and maritime nation:
1) Create a “Maritime Department” section under CHED composed of Master Mariners, Chief Engineers and Marine deck and engine officers with Masters and Doctorate degrees. It is obvious that the people who have these qualifications are the members of its technical working group;
2) Amend the existing laws on Filipino Migrant Workers Act (RA 10022). It has remain detrimental and unfavorable to the business of manning and seafaring. It was passed into law without considering its negative effect on the maritime industry;
3) Separate/segregate sea-based from land-based employment. Because of the stringent requirements of the International Maritime Organization (IMO) Convention on STCW, where the Philippines is a party to this convention, not to mention the time spent on maritime education, rigorous training, and the complex process of licensing and certification, sea-based education needs to have its own identity, different from that of ordinary Overseas Foreign Workers (OFW). To attain this objective, we need to revive the defunct National Seaman’s Board (NSB), formerly in charge of deployment of seafarers, and managed by people knowledgeable in shipping and seafaring.
4) Replace the head of MARINA, MTC and TESDA with people who have extensive sea experience and full knowledge of various international conventions, rules, and shipping laws, particularly an experienced Master Mariner with excellent supervisorial and managerial skills.
It is not so difficult to search for the right person for the job and to find the courage and political will to initiate reforms and replace these incumbent government officials.
Those who perceive and brag that Filipino seafarers are indispensable because of their dominant numbers should have their heads examine. We don’t own the ships, but only serve at the pleasure of its owners. We cannot continue to ignore and defy convention rules that ship owners themselves ratified and pledged to abide, nor will the ship owners compromise the safety of their vessels in exchange for numerical superiority.
The threat of EMSA and the dire consequences of being delisted from IMO’s “White List” are similar to the Fukushima nuclear meltdown. Unless an immediate solution is found, there will be chaos in Luneta Park and our supposedly productive seafaring industry will end up at the bottom of the pit.
Captain Alvils is a third-generation Master Mariner (His Grandfather and father are master mariners) and, in turn, has raised two sons who are also now both Master Mariners. A graduate of PMI college (Class 67), he served 7 years with the Maritime Company of the Philippines (MCP) and 25 years with the Sanko Line, of which 6 years were as Master Mariner. He served as Port Captain and Operations Manager of various shipping companies, and is presently the Operations Manager of PVI. In addition , he is President of the Bataan Seaman's Association and Bukluran Marinong Pinoy. An author of books, including "International Regulations for Collision at Sea (explained and illustrated)", "Maritime English", "Chartering Terms and Abbreviations", and "Bulk Cargo Operations", he was awarded the prestigious honor of being named as one of the Most Outstanding Seafarers of the Year 2009.
Given the length of his maritime experience and the significance of his accomplishments, and as a citizen of one of the most seagoing nations in the world, we would think that his words and opinions should be given the attention, weight, and respect that they deserve.
No comments:
Post a Comment