Still time to tackle Manila amendment requirements

Oct 24, 2016 by Capt. Brian Luke

There are about two months left before the full implementation of the Manila amendments. Last year, I devoted a column to this subject. Now that we are down to the wire, it’s befitting that we revisit those requirements and a few others.

The United Kingdom’s MCA puts out M notices to help inform the UK maritime community about regulatory requirements and changes. MIN 520 states the following and should be read in conjunction with MSN 1865;

2.1 Seafarers serving onboard ships who are qualified in any of the following, must, as of Jan. 1, 2017, have documentary evidence of either having completed the training course or updated their training within the last five years:

(a) Proficiency in Personal Survival Techniques (PST) STCW A-VI/1- 1,
(b) Proficiency in Survival Craft and Rescue Boats other than Fast Rescue Boats (PSC & RB), STCW A-VI/2- 1
(c) Proficiency in Fast Rescue Boats (PFRB) STCW A-VI/2- 2;
(d) Proficiency in Fire Prevention and Fire Fighting (FP & FF), STCW A-VI/1- 2
(e) Proficiency in Advanced Fire Fighting (AFF) STCW A-VI/3

Yacht crew only need to update or revalidate the above elements with which they are currently certified. The MCA goes on further to conclude that they may perform some of the required training onboard their current vessel. If they have completed some of the training onboard, then they may reduce the amount of time required in a training center. Crew can find the required training onboard in the “self-declaration” form found in the annex of MSN 1865.

Advanced Sea Survival
The MCA, by way of MIN 520, allows for certification of non-STCW Advanced Sea Survival (AdvSS) instead of Proficiency in Survival Craft and Rescue Boats (PSCRB) for yacht Certificates of Competency (CoC) only.

Non-STCW AdvSS may be accepted in lieu of PSCRB. However, the notice does add that those going down this route will have the following limitation on their certificate: “Not for use on ships equipped with davit-launched lifeboats”.

However, I would like to highlight the problems this certificate could cause in areas outside of UK waters. The MCA recommends that all seafarers hold an STCW PSCRB Certificate of Proficiency. This is due to potential problems of Port State Control officers outside of the UK not accepting the non-STCW AdvSS.

Additionally, those holding AdvSS will need to update this certificate every five years, just like PSCRB. The good news is that the MCA will allow those with AdvSS to take the PSCRB refresher course to meet this requirement. The full PSCRB and AdvSS are almost identical courses with the exception that PSCRB requires one additional day of training on the safe launching and operation of davit-launched lifeboats. The PSCRB refresher, however, does not require the launching of lifeboats so the two refresher courses are almost identical in their requirements. The MCA has stated that a new M notice will be issued shortly confirming refresher training for AdvSS.

Efficient Deck Hand
For crew members working toward their Officer of the Watch Yachts <3000gt CoC, one of the required courses is Efficient Deck Hand (EDH). After Jan. 1, the MCA will no longer issue OOW CoCs until 18 months after the completion date of the EDH course certificate. The recommendation would be to take EDH first in the OOW modules in order to start the clock ticking ASAP on the 18-month requirement.

Security training
The question referencing which security course is required for yacht crew is still misunderstood. It is my recommendation that superyacht crew take the full Proficiency in Designated Security Duties course, rather than the Proficiency in Security Awareness course, due to the fact that all yacht crew are usually engaged in security duties as part of the vessel’s security plan.

I continue to have captains approach me and ask “Why are we issuing the later certificate in lieu of the full Proficiency in Designated Security Duties course?” My only response is that many in our industry are still incorrectly guiding yacht crew toward the Proficiency in Security Awareness course.

The reason for the confusion is that the Manila amendments require Proficiency in Security Awareness as a minimum requirement for the new STCW code. Again, this minimum requirement will most likely not work for yacht crew as they will almost always have a security duty as part of the vessel’s security plan.

Next month we will visit the requirements for HELM and ECDIS and expand on what is needed to help keep your career on course.

Capt. Brian Luke is president of Bluewater Training USA (formerly ICT) in Ft. Lauderdale ( Comments are welcome at [email protected].