Consultation outcome

Responses to Consultation Feedback

Updated 18 July 2023

Deck - Marine Engineering Systems

Role	Senior Maritime Manager and Marine Pilot
Organisation	Regulatory Body
Module	Deck - Marine Engineering Systems
Your Feedback - Outcome 1	Proposed changes in 1.2 and addition of 1.3 are welcomed.
SG 1.2 Response	Many thanks for your feedback.
Your Feedback - Outcome 2	modification to 2.3 is possible BUT it is not possible to contextualise except with respect to current regulations (and those already in the pipeline) impact on the operation of the use of current auxiliary machinery. No attempt should be made to attempt to forecast future legislation but it should be stressed that existing regulations need to be understood and that these may vary between Port states costal states and flag states.
SG 1.2 Response	Many thanks for your feedback, it has been noted. We are in agreement with your overarching comments, we are not suggesting that within this outcome we should attempt to forecast future legislation. Our rationale was only referring to current legislation and legislation that is in the pipeline and how this incoming legislation would impact day to day operations moving forward. This should ensure that seafarers are trained to understand how legislation currently impacts their day to day work and the impact that any impending changes will have.
Your Feedback - Outcome 3	Outcome 3 Whilst ‘modern’ technologies should be included It is difficult to mandate the inclusion of ‘future technologies’ Both actions required can be accepted with respect to modern technologies only.
SG 1.2 Response	Many thanks for your feedback, it has been noted. Modern technologies may be a more appropriate terminology as we can, of course, not predict the future technological developments and once they are here they are purely modern and not future technologies. However, the intention of including future technologies was to raise seafarer awareness of technology that is on the horizon as well as those currently in use.
Your Feedback - Outcomes Above and Beyond	In general I agree with placing items in a relevant context as this aids learning, I also agree that the Human Element factors should be linked for the same reasons. I do not agree that ‘Data Science Skills’ should be either examinable or form part of the cadets assessment during their studies. Whilst the subject can be included in passing where relevant to the subject being taught, any introduction of any new ‘topic’ which is either examinable or assessible should await formal adoption within STCW. British Cadets should not risk failing their CoC based on a topic which has not yet been accepted internationally.
SG 1.2 Response	Thank you for feedback, it has been noted. This is a topic which we are looking to introduce above an beyond the requirements of STCW, in order to future proof the skills of seafarers. It will be included as a UK recommendation as part of the IMO’s comprehensive review of STCW.
Your Proposed Outcome	#N/A
Your Rationale for this outcome	#N/A
Your Action for this outcome	#N/A
SG 1.2 Response	#N/A

Deck - Passage Planning

Role	Senior Maritime Standards Manager and Marine Pilot
Organisation	Regulatory Body
Module	Deck - Passage Planning
Your Feedback - Outcome 1	Outcome 1.3 : I do not think that the importance of planning on Paper Charts should be degraded or Electronic resources be prioritised. Both are of equal validity. 1.4 The importance of tidal heights during a voyage remains key to providing an effective Great Circle route. If this is accepted there is no need to re-teach tidal calculations.
SG 1.2 Response	Many thanks for your feedback, it has been noted. While we agree that both paper charts and electronic resources should be covered within outcome 1.3, the indication from the working group and industry feedback is that electronic resources are now the primary means of navigation for the majority of the industry and, as such, should be taught with this in mind. We completely agree that tidal calculations remain an important part of the Deck syllabus. However, it is covered in more detail in outcome 2.3, “Use, and the understanding of the implication, of Tidal heights, times, and streams to ensure the passage is made safely” and does not need to be duplicated.
Your Feedback - Outcome 2	2.1 there should be no reduction in the importance of being able to plan a composite or rhumb line route using Paper charts, this knowledge remains of equal importance to the ability to utilise ECDIS, use of ‘calculation software’ needs to be carefully considered as the software taught may not be that carried aboard. 2.3 whilst new standard ENC’s (S-100) MUST be taught, manual calculation of TIDES must remain important and cannot be given lesser importance than electronic methods. Use of Tidal Software other than ATT needs to be carefully considered as the software taught may not be that carried aboard. 2.7 Inclusion of spoofing and Jamming and how to identify and counter is a necessary addition 2.9 Documentation of passage plan : needs to be retained unchanged as it remains a key factor and is subject to PSC inspection.
SG 1.2 Response	Many thanks for your feedback, it has been noted. While we agree that both paper charts, manual calculations and electronic resources should all be covered within outcome 2.1 and 2.3, the indication from the working group and industry feedback is that electronic resources are now the primary means of navigation for the majority of the industry and, as such, should be taught with this in mind. We are in agreement with your comments on outcomes 2.7 and 2.9.
Your Feedback - Outcome 3	3 I disgaree with the reduce focus on paper charts, the Cadet MUST be fully capable of using both Paper charts and ECDIS and evaluating a passage plan in either format.
SG 1.2 Response	Many thanks for your feedback, it has been noted. While we agree that both paper charts and electronic resources should be covered within outcome 3, the indication from the working group and industry feedback is that electronic resources are now the primary means of navigation for the majority of the industry and, as such, should be taught with this in mind.
Your Feedback - Outcome 4	Outcome 4 I do not agree with a reduced focus for paper charts in pilotage. Many vessels are still using paper charts as the primary means of navigations and in some cases for cargo vessels under 300GT approved ECDIS is not fitted. Both methods must retain equal importance.
SG 1.2 Response	Many thanks for your feedback, it has been noted. While we agree that both paper charts and electronic resources should be covered within outcome 4, the indication from the working group and industry feedback is that electronic resources are now the primary means of navigation for the majority of the industry and, as such, should be taught with this in mind.
Your Feedback - Outcome 5	Outcome 5. I do not agree with the reduced focus on paper charts they must retain equal importance with ECDIS and ECS until all vessels are carrying duel ECDIS 5.1 Astronomical observations should continue to be assessed
SG 1.2 Response	Many thanks for your feedback, it has been noted. While we agree that both paper charts and electronic resources should be covered within outcome 5, the indication from the working group and industry feedback is that electronic resources are now the primary means of navigation for the majority of the industry and, as such, should be taught with this in mind. While we appreciate your point of view regarding astronomical observations, the feedback from the working group and industry consultation has indicated that they would agree with our suggestion .
Your Feedback - Outcomes Above and Beyond	Contextualisation of outcomes and inclusion of Human Factors in all areas is desirable I do NOT agree with the inclusion of an examinable or assessable specific topic entitled ‘Data Science Skills’ unless and until adopted by IMO and included in STCW. Data Science skills can be touched on where relevant and helpful in individual areas but should not be assessed
SG 1.2 Response	Thank you for feedback, it has been noted. This is a topic which we are looking to introduce above an beyond the requirements of STCW, in order to future proof the skills of seafarers. It will be included as a UK recommendation as part of the IMO’s comprehensive review of STCW.
Your Proposed Outcome	#N/A
Your Rationale for this outcome	#N/A
Your Action for this outcome	#N/A
SG 1.2 Response	#N/A

ETO - Electronic Fault Finding

No feedback requiring a response was received for the module ETO - Electronic Fault Finding.

Marine Engineering - Heat Engine Principles (Management Level)

Role	Marine Surveyor (former Ship Engineer)
Organisation	Classification Society
Module	Marine Engineering - Heat Engine Principles (Management Level)
Your Feedback - Outcome 1	#N/A
SG 1.2 Response	#N/A
Your Feedback - Outcome 2	#N/A
SG 1.2 Response	#N/A
Your Feedback - Outcome 3	#N/A
SG 1.2 Response	#N/A
Your Feedback - Outcomes Above and Beyond	#N/A
SG 1.2 Response	#N/A
Your Proposed Outcome	Heat at management level includes steam turbine geometry calculations. I don’t believe these are of use so should be removed from the syllabus Steam & nozzle geometry may be of use but from personal experience the steam turbine material is of little use in the workplace for most.
Your Rationale for this outcome	Experience of completing heat course at management level.
Your Action for this outcome	Remove
SG 1.2 Response	Many thanks for your feedback, it has been noted. While we agree that heat is an important part of this module, the working group have indicated that turbine geometry is still required to be known as, although steam is not regularly used for propulsion, on modern vessels the concepts of turbine geometry are still relevant wherever steam is used as a prime mover, such as cargo pumps on large tankers.

Marine Engineering - Applied Thermodynamics (Management Level)

Role	Marine Surveyor (former Ship Engineer)
Organisation	Classification Society
Module	Marine Engineering - Applied Thermodynamics (Management Level)
Your Feedback - Outcome 1	#N/A
SG 1.2 Response	#N/A
Your Feedback - Outcome 2	#N/A
SG 1.2 Response	#N/A
Your Feedback - Outcome 3	Can push other facets of heat over the turbine geometry. Of little use to most in the industry.
SG 1.2 Response	Many thanks for your feedback, it has been noted. While we agree that heat is an important part of this module, the working group have indicated that turbine geometry is still required to be known as, although steam is not regularly used for propulsion, on modern vessels the concepts of turbine geometry are still relevant wherever steam is used as a prime mover, such as cargo pumps on large tankers.
Your Feedback - Outcomes Above and Beyond	#N/A
SG 1.2 Response	#N/A
Your Proposed Outcome	#N/A
Your Rational for this outcome	#N/A
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SG 1.2 Response	#N/A

Deck - Management of Bridge Operations

Role	Senior Maritime Standards Manager and Marine Pilot	Captain
Organisation	Regulatory Body	Motor Yacht
Module	Deck - Management of Bridge Operations	Deck - Management of Bridge Operations
Your Feedback - Outcome 1	Outcome 1 Care must be taken in spending time teaching about ‘future’ technologies as opposed to those just entering service.I agree with the use of case studies to contextualise this subject. 1.1 we need to stress compliance with current regulations, and those which are already moving towards implementation at IMO. I have an issue with ‘future’ as opposed to the latest current technologies being included.	#N/A
SG 1.2 Response	Many thanks for your feedback. While we agree with the message of your feedback, we believe that what you have suggested is already covered. The intention of our suggested action is to ensure that Cadets understand how these concepts are actually implemented on board and how it will impact their work. The inclusion of future technologies and practices was purely to ensure that this outcome is kept up to date as these practices do change. Overall, we want to ensure that Cadets are being taught these topics in a context relevant to what they will experience on board.	#N/A
Your Feedback - Outcome 2	Proposed amendments are beneficial providing that the rebalancing of study to include additional simulator time is not at the expense of other learning outcomes.	Outcome 2: Although more simulator time is always going to be beneficial I feel it would be more beneficial at the Chief Mates level when the candidate has had time to consolidate their knowledge learnt in their cadetship. That being said an OOW unlimited is also a Chief mate <3000 without any further formal training. Perhaps an additional recommendation would be to include simulator training in addition to the HELM and sea time requirements for the Chief Mate <3000 Outcome 2.5: Without viewing the current syllabus i might be making a null comment however in practice new OOW’s in my experience know enough about anchoring to say that the wind and tide is a factor in anchoring and know a rule of thumb on how much chain to put out, but when probed further they do not understand the factors at play in deciding which anchor to use. with that in mind i feel that the anchoring section should be more thorough and brought up to date. the knowledge on HHP vs stocked anchors is great but an OOW is not going to be involved in the decision of which anchor should be bought for a new vessel.
SG 1.2 Response	Many thanks for your feedback, it has been noted. Please be assured that no other outcomes that are being kept in the module will look to be downgraded to make way for simulator time, this is purely looking to be used as a learning aid to augment current teaching.	Many thanks for your feedback, it has been noted. Please be advised that this module, while part of the Cadetship syllabus, is actually aimed at the STCW II/2 standard as many Cadets complete the learning required to get them to Chief Mate and Master’s level during their Cadetship. As such, we feel this is an appropriate point to include additional simulator time. With regards to outcome 2.5, we can confirm that the indicative content of this module does cover the factors you have mentioned and will continue to do so. Further, we are aiming to improve practical utilisation of this outcome through the introduction of more simulation exercises. In addition, NAEST (M) also covers two simulated anchoring exercises.
Your Feedback - Outcome 3	deservedly unchanged as all skills remain relevant	#N/A
SG 1.2 Response	Many thanks for your feedback.	#N/A
Your Feedback - Outcomes Above and Beyond	Contextualisation and Human Element inclusion is a necessary enhancement. No new specific topic which is either examinable or assessible should be included unless/until IMO approved and included in STCW . Data Science Skills can be covered informally where relevant. No British Cadet should fail their CoC examinations or be otherwise disadvantaged on the basis of performance in a ‘specific topic’ that is not recognised in STCW	#N/A
SG 1.2 Response	Thank you for feedback, it has been noted. This is a topic which we are looking to introduce above an beyond the requirements of STCW, in order to future proof the skills of seafarers. It will be included as a UK recommendation as part of the IMO’s comprehensive review of STCW.	#N/A
Your Proposed Outcome	#N/A	#N/A
Your Rationale for this outcome	#N/A	#N/A
Your Action for this outcome	#N/A	#N/A
SG 1.2 Response	#N/A	#N/A