UK Chamber's response to the consultation on changes to MCA Survey and Inspection Marine Office locations
The chamber has submitted its response to the consultation on changes to MCA Survey and Inspection Marine Office locations.
The Chamber welcomes the MCA’s commitment to improving the standard of service it provides to its customers, and welcomes this consultation exercise as a step towards that objective. We share the aim of the MCA that the Survey and Inspection service should provide a service comparable with that provided by highly-regarded Flag Administrations overseas so that operators of ships under the UK flag are in a position to compete on an equal footing with operators of ships flagged elsewhere and that further tonnage can therefore be attracted to the register.
Similarly, the Chamber sees clear scope for improvement in the examination and certification service the MCA provides to UK seafarers. Such individuals (unlike shipowners who can choose to register their ships in the UK) are captive customers, and the MCA therefore has a special duty towards them.
Our comments relate to the MCA’s role as a service provider to owners of UK-flag ships and to British seafarers. We do not seek, on this occasion, to comment on the MCA separate policing role under Port State Control given that these two functions are distinct, notwithstanding the fact that the MCA currently uses the same set of personnel to perform them both.
It is also our view that insufficient prominence has been given in the review to improving the level of service provision by delegating additional powers to Classification Societies. The retention of a monopoly position by a public body is perceived by both Government and industry to be undesirable and a move towards a mixed public/private model for delivery is therefore thought to be essential.
1. To what extent do you need to have direct access to a Marine Office; for what activities; and how frequently?
Collectively, the operators of UK-flag ships whom which the Chamber represents need access to the entire network of Marine Offices for the full range of Flag State services they provide: from routine statutory surveys and audits to ad hoc call-outs of surveyors when particular questions arise on board ship, and consultation and advice on the interpretation of law and the application of generic requirements to specific circumstances.
The need for access to a local office, rather than a national service, reflects the fact that surveyors based in Marine Offices have customarily developed special expertise relating to the ships that are based in (or call regularly at) ports that are geographically nearby. Thus, for example, surveyors in the Marine Office in Dover have developed special expertise relating to ferries and those at Aberdeen have developed special expertise relating to OSVs. Access to the Dover office for instance, is very important for UK-flag ferries operating from Dover: this office provides considerable assistance dealing with queries regarding the complexities and survey requirements of passenger vessels, so as to not delay the vessels in the short port turnaround timeframes available. The Marine Offices in Belfast and Liverpool perform the same function in relation to UK-flag ferries operating on the Irish Sea and, for the same reasons, access to those offices is similarly important.
Such specialist expertise is based on personal familiarity with the ships in question and is not replicated across the MCA nationally. For the shipping company, both specialist expertise and personal familiarity (and continuity) with individual surveyors are highly valued. Providing such ship-specific or ship-type-specific specialist expertise across all Marine Offices is probably uneconomical. Similarly, there is a risk of dilution of expertise and service levels if the MCA seeks to maintain too great a number of regional offices. The analysis available to us as respondents, does not allow us to judge whether or not 10 offices is the correct footprint for the future.
Separately, UK seafarers employed by those shipping companies and the UK cadets in training with them need access to Marine Offices for their oral examinations.
The UK Chamber itself engages with the MCA principally through its Head Office in Southampton, rather through individual Marine Offices.
2. What alternative estate laydowns within the UK would, in your view, enable the MCA to deliver more efficient services to customers?
The Chamber has no definitive view about where Marine Offices should be located, or how many of them should exist, and therefore expresses no preference for the current or the proposed estate laydown or indeed for any alternative.
The network of Marine Offices should be whatever is necessary to enable the MCA to deliver a high-quality and responsive service to operators of UK-flag ships and to UK seafarers. The value of any individual Marine Office does not derive from its existence or its location, but from the quality of the service it provides. This will be a function of the expertise of its personnel, their responsiveness to the requirements of shipowners and seafarers, and the accessibility and opening hours of the office, etc.
The Chamber offers a number of suggestions for specific measures of service quality, in response to Question 5 below. In our view, it would be more appropriate to decide upon an optimum network of Marine Offices after those standards of service and indeed methods of delivery have been defined. For example, if Marine Offices are in future to rely more heavily on improved IT, and, for example, virtual inspections then fewer Marine Offices will be required. Consistency of advice and the manner in which regulations are interpreted between the offices, however many remain, will remain key.
3. What technology-based channels should be made available to enable you to conduct your business more effectively with the MCA?
Greater electronic working will clearly be an important
element in any strategy for improving the service that the MCA provides to
operators of UK flag ships and to UK seafarers.
The Chamber is pleased to see the list of tools (in section 3.3.1 of the
consultation document) that are being developed, and would urge the prompt
introduction of all of them. To modernise
and provide greater electronic support tools to the surveyors to support their
remote working will be hugely beneficial.
Several of the proposed new tools, such as online portals
for booking surveys and examinations and digital certificates, have been the
subject of specific requests from shipowners at meetings with the MCA hosted by
the Chamber over the last couple of years.
The MCA is to be commended for acting on those requests.
Clearly, however, those tools are a means to achieve a
higher standard of service and, on their own, they do not constitute a higher
standard of service. Their usefulness
will depend on the processes they support and on the expertise of the personnel
using them. Your consultation document
acknowledges that the proposed system for electronic scheduling of surveyor
resources (presumably through the online portal for booking surveys?) needs to
be supported by a database of surveyor competence. It is equally essential for the MCA to ensure
that it has access to the full array of such competence and expertise that it
needs in order to meet the requirements of operators of UK-flag ships, whether
from within its pool of in-house surveyors or from elsewhere.
Similarly, an online booking portal for oral examinations
will be really useful only if it operates across all examination venues. An electronic version of the current
arrangements whereby would-be candidates must contact individual Marine Offices
in turn to see whether they have an available slot would be of limited value.
The usefulness of any booking system will depend on what is available for booking. Whether in respect of surveys of ships or examinations of seafarers, the MCA should define fixed standards for the availability of slots. Suggestions accordingly are set out in response to Question 5 below.
There is a view, at the moment, that the functionality of
the MCA website may be constrained by being hosted on the gov.uk site. In any event, there would be merit in a
debate about whether the MCA, as a service provider to operators of UK-flag
ships and to UK seafarers should have a standalone website – as its competitors
do – where it is able to determine the online facilities it will offer and how
these will be presented.
The Chamber would also welcome a high-quality helpline where
seafarers and operators of ships can get prompt access to reliable and
authoritative advice. Again, however,
the creation of a technical channel will only be part of the provision of such
a helpline: sufficient expert personnel need to be on hand to provide reliable
and authoritative answers to enquiries in a timely manner.
4. What alternative working practices do you believe could be adopted by the MCA to improve our support to the industry whilst meeting our statutory and regulatory obligations?
The Chamber’s view in relation to working practices is the
same as its view in relation to Marine Offices: namely, that the MCA should
adopt whatever working practices are necessary to enable it to deliver a
high-quality and responsive service to operators of UK-flag ships and to UK
In regards to services for operators of UK-flag ships, your consultation document indicates that the MCA intends to make greater use of Classification Society and other surveyors in order to perform surveys and inspections. This is welcome. It appears, however, that this intention is confined to surveys and inspections of ships overseas – with an implication that surveys and inspections of ships in UK ports will be reserved for MCA’s in-house personnel. It is not clear why such a distinction should be drawn, and the Chamber can see no good reason for managing the function differently depending on where the ship may be at the time when its survey due.
At the moment, the MCA reserves certain surveys of UK-flag ships for its in-house employees. If this practice is to continue, the MCA should make clear (by formal notice) which surveys are reserved for its directly-employed surveyors, which are formally delegated to Classification Societies and other surveyors, and which may be performed by either depending on availability and any option expressed by the operator. There clearly needs to be a rational basis for reserving any surveys for in-house MCA personnel, and the Chamber would wish to participate fully in the consultation process that would need to precede the adoption of a formal policy of reservation.
In the Chamber’s view, the assignment of a surveyor to undertake any particular survey should be based on his/her competence/expertise, availability and cost. The Chamber sees no good reason for the MCA to give preference to its in-house personnel (or indeed to surveyors employed by Classification Societies or other Flag Administrations) simply because of the identity of their employer. The MCA should accordingly be willing to assign any surveyor who is a suitably qualified and an authorised expert to carry out a Flag State survey (wherever the survey is to be carried out). If a service can be delivered more quickly or at a lower cost by a private sector service provider then the customer should be given the option of choosing that provider.
Such an approach would enable the MCA to draw on a much broader resource than just its in-house employees, and thereby to provide a more responsive service to the operator of the ship. Clearly, all surveyors carrying out UK Flag State surveys need to have full delegated authority: an arrangement where surveys carried out by a Classification Society surveyor (for example) need to be signed off by an MCA employee would have limited merit.
The MCA should also adopt a structure for charging for surveys that does not leave operators of ships facing different costs depending on whether the surveyor is directly employed by the MCA or is employed by a Classification Society (or other organisation) that is acting under contract for the MCA. In particular, the MCA should terminate its extant and unpopular practice of requiring operators of ships to pay the cost of gold-plated travel perks (like business class airfares and unduly expensive hotel accommodation) or inflexible working conditions.
As regards services to UK seafarers, the MCA should review the requirement for oral examinations to be held at Marine Offices. It is unusual for an examining body to require candidates to attend its own premises in order to be examined. Although there may be value in holding the examination in a setting that it is intimidating, there is no obvious value in requiring a candidate to travel to a location that is inconvenient to him/her. The MCA should consider adopting the practice of most examining bodies and holding its exams at various premises around the country, close to (or in) colleges and major towns and easy to reach by public transport.
5. Do you have any further proposals for enhancing the MCA’s support to the shipping industry and the attractiveness of the UK Ship Register for ship owners and operators?
Yes. The MCA should define some clear standards that it guarantees for routine elements of its core service to shipowners and seafarers, so that those companies and individuals know what they will get and plan accordingly. Many examples of excellent service, from the MCA corporately and from individual surveyors, have been reported to the Chamber, but it is equally reported that the standard of service varies and that no-one can rely upon always receiving that high standard of service.
The establishment of service standards for routine core functions will ensure consistency of service for customers, thereby enabling them to plan their business (in the case of shipowners) and career path (in the case of individuals) with confidence. It will also establish a fixed point around which the Survey and Inspection service can be organised – so that it is resourced, equipped, and located to ensure that it can deliver that defined standard of service.
At the moment, the quality of the MCA’s output is determined by the resource available to the Survey and Inspection service; the latter is fixed, and former is therefore variable. This is neither satisfactory nor customer-focussed. A re-orientation is required, so that delivery of service to the customer defines everything else. Defined standards of service are the starting point for determining what resources the MCA requires (chiefly in skills and expertise) in order to deliver those services, how those resources should be organised (whether through in-house personnel or through service contracts with Classification Societies) and where they should be located.
As a starting point, the Chamber proposes the following standards for the MCA’s core routine services:
- a surveyor to attend a UK-flag ship within six
hours of a request from the shipowner;
- ships’ certificates to be issued immediately on
successful completion of a survey/inspection;
- notices of seafarers’ examination eligibility to
be issued within 10 working days of an application (by an applicant who is
- oral examination slots to be always available
within a month;
- certificates of competency to be issued within
ten working days of passing an oral exam;
- letters of initial assessment to be issued with
six weeks of application; and
- automatic and immediate reimbursement of any
application fee, in all cases where these standards are not met.
Clearly, the MCA needs to provide a high standard of service in response to all its customers’ requirements, not simply those of a routine nature. For example, it is vitally important that, when approached for specialist advice on the interpretation of a particular IMO requirement or on how a generic provision applies to the specific circumstances of a given ship, the MCA provides such advice promptly and accurately. The Chamber would be pleased to contribute to a discussion with the MCA to define standards for such qualitative elements of its overall service, alongside those for the performance of routine tasks.
The attractiveness of the UK Ship Register would be enhanced by removing more “red tape” and administration. Additionally, the alignment of standards and survey requirements to gain consistency by all of the Red Ensign Group shipping administrations would be welcome. The UK Ship Register would be more attractive if the transposition of IMO Conventions, such as the Maritime Labour Convention, were transposed into UK law in their entirety without any MCA interpretations, which although well-intentioned, bring about unintended consequences.
In conclusion, the Chamber welcomes the specific proposals in the consultation document and urges the MCA to realise them expeditiously. The Chamber also urges the establishment of defined standards for MCA services, so as to provide reassurance to operators of UK-flag ships and to UK seafarers of the quality of service they will receive. Those standards should match those provided by well-regarded Flag Administrations, in order to demonstrate to existing customers and to prospective new ones that the service provided by the MCA is world-class.
MCA Consultation Document on improving its Survey and Inspection service
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