On the 22nd of November, Vice Admiral Sir Alan Massey, delivered a unique paper on IMIF’s lunch meeting hosted my member Watson, Farley & Williams in their City HQ’s auditorium. Nearly thirty member/attendees where present representing almost all stakeholders of the maritime industry.
Vice Admiral Sir Alan Massey became the Maritime Coastguard Agency’s Chief Executive in July 2010. This followed a career in the Royal Navy where he commanded four warships including the aircraft carriers HMS Illustrious (2001) and HMS Ark Royal (2003). Sir Alan went on to become Assistant Chief of Naval staff and assumed office of Second Sea Lord in July 2008, and was appointed Knight Commander of the Order of the Bath (KCB) in 2009.
The Maritime Coastguard Agency works to prevent loss of lives at sea and co-ordinates search and rescue at sea through Her Majesty’s Coastguard 24 hours a day. It ensures that ships meet the UK and International safety standards, monitors coastal water pollution, responds to pollutions from shipping and offshore installations. The MCA registers vessels and issues Certificates of Competency for ship’s officers and crew to STCW requirement.
Here is what Admiral Massey, the head of the MCA said:
“Thank you very much indeed for this opportunity to talk fairly briefly about what the MCA is and does. I’ve given this talk the title of ‘Managing Risk Sensibly’, because after over 2 years in post now, I believe that’s fundamentally what the Agency is here for, and what I’m paid to do. Perhaps most important – I also think it’s what our main customers – the maritime industries and the public -actually want us to do.
We all know that the maritime environment is pretty replete with risks. Some of them are entirely natural and rather beyond our immediate control, leaving us at best to try to help contain or mitigate their effects. But of course the vast majority of the risks we’re talking about are man-made, or at least ably man-assisted. These are the ones we must concentrate our efforts on.
The MCA’s is the UK’s maritime regulator, and is the national competent authority for stewarding pretty much every aspect of safety at sea and on the coast. We are required to address 4 broad types of risk: those that apply to commercial shipping and seafaring; those pertaining to recreational activities on the water or coast; those affecting the well-being of the marine environment; and finally, those risks that threaten the safety of my own workforce.
But what about this notion of ‘sensible’? If resources were not an issue, we could in theory probably screw right down and significantly reduce the likelihood of bad things happening by dramatically increasing regulation, exerting far greater control of access to and use of the sea, insisting on use of the newest technologies in every marine application, and scrutinising to the nth degree the competences and behaviours of those whose business or pleasure pursuits take them anywhere near water.
You’ll be pleased to know that I don’t see myself pushing those kinds of boulders uphill whilst I’m in this job.
On the contrary. For a start, we just don’t have those resources. But even if we did, it would not be the right way to act. We know there has to be a judicious balance between being governed by strict rules on the one hand; and being steered by good practice, rational standards and common sense on the other. And finally of course, our current government already considers that we are over-regulated, to the disbenefit of commercial competitiveness and national economic well-being. So they are actively seeking to reduce regulatory burdens, not increase them.
And so in response, our approach has to be more nuanced, more discriminating, and sensible.
Let’s start with commercial shipping, which is of course where most maritime regulation has its focus. Since its election, the Govt has been aggressive in reviewing the laws that bite on business, and in seeking to thin down the number and complexity of rules and regulations in our national life, under the so-called ‘Red Tape Challenge’ initiative. They see this as central to removing barriers to economic growth and increasing individual freedoms. Many of you will be aware of the work that’s been going on.
Of course this doesn’t mean chucking everything over the wall, willy-nilly. There are obvious reasons to have good quality, effective regulation in the maritime sector. For starters, to operate internationally, shipping must comply with agreed international standards. The alternative would be confusion and massive administrative burdens emanating from different regulations in different countries. So we do have to keep up with the way laws are made internationally, as well as nationally.
But does this mean that all of our current 200 UK maritime regulations are fit for purpose? No – it doesn’t.
We’ve actually identified that about half of those current regulations could be safely removed or amended to help reduce costs for the maritime sector, without compromising competitiveness or safety. So we’ll be inviting Ministers to scrap around 30 and improve another 70 regulations to that end. We’ve also identified a range of ways in which other regulations could be improved, and we will be discussing with Ministers what powers we could use to speed up the regulatory process. This is so that we can implement international convention changes, on time and in the simplest possible way. So that, in turn, UK ship operators can have the right certification early and only need to refer to the international conventions themselves, to know what they should be doing to trade unhindered around the world.
For smaller types of commercial vessel, we already try to manage risks in a less heavy-handed way, having regard to those vessels’ often more limited exposure to danger and their constraints in size, manning and ambition. That’s not to say that the sea is in principle any less hostile to them. But by limiting their voyage scope and the time of year that they can operate, the chances of such ships getting caught out by bad weather, or the heaviest seas, or icebergs – God fobid, are generally smaller.
In this area of business we have had a lot of success in developing codes, for example, for superyachts and for passenger yachts which may carry up to 36 passengers. These codes exist as equivalent standards to international maritime Conventions. They are recognized as such, internationally, by safety authorities, and they enable smaller businesses to avoid the full gamut of technical standards and equipment fits that apply to bigger ocean-going vessels. All this is obvious enough.
But I think there are opportunities to make more of this approach – especially if we can increase the degree to which the industry itself gets involved in drawing up such codes. So we’re taking this collaborative approach ever further. The Government likes it; it fits with the modern civil service approach to ‘open policy making’, and it seems thoroughly sensible both to us and to the industry we regulate.
For example, we led the way in establishing equivalent accommodation standards for vessels under 200 gross tons to comply with the Maritime Labour Convention. MCA brought together industry stakeholders to put in place appropriate standards that provide decent living and working conditions within the spirit of the MLC, but without allowing this to lead to disproportionate and frankly impracticable consequences for those types of vessel and their mode of operation.
We’re also quite pro-active in seeking to improve the way people think and act when they’re out at sea. This is reasonable, given that 8 out of 10 accidents are the result of purely human factors, rather than technical failures or acts of God. The MCA has developed a code of safe working practices, which has become the de factointernational standard and can be found on the bridge of any ship, irrespective of their flag. We’re quite proud of that. Similarly, a book that we published on the Human Element in the shipping industry has now sold over 60, 000 copies worldwide. And in the same vein, MCA marine surveyors and inspectors now focus most of their effort on systems and behaviors, rather than hardware and materials, because that is where the bigger risks actually lie.
I should speak briefly about the sporting, recreational and leisure sector of maritime activity. In contrast to many nations, the UK has a very light touch in this area. In truth, it is largely unregulated, or perhaps better: self-regulating. As regulators, we could do a lot more and – to be sure – plenty of bad things happen out there. But I’m fairly certain there is very little appetite either in Government or amongst the public to insist, for example, that every pleasure craft be registered, every skipper be trained and certificated, every vessel carry a standard pack of minimum equipment. Even though those steps may appear, on the face of it, to be logical ones to take. Instead, the MCA puts a lot of effort into education; we do encourage formal training (and we work very closely with the RYA in this regard); and we also operate a voluntary, free of charge registration service with the Coastguard. I sense that the insurance business may soon also be doing more to influence behaviors in the direction of more training and better equipment in the pleasure vessels they cover. That would be good, in my view. We do take this sector seriously. And so we should, when the majority of our search and rescue activity is squarely down to pleasure seekers in one guise or another.
What about other ways of managing risks at sea and on the coast? Until recently, the MCA had 4 big ocean-going tugs stationed around the UK to mitigate the prospect of a ship’s grounding and potentially polluting the environment in some catastrophic way. We took those tugs away last year, on the basis that there are plenty of commercial tugs around UK waters, and that such ‘insurance policy’ arrangements for towage and salvage should properly be a commercial matter for shipowners, and not for the taxpayer. In the event, the Government has reinstated one tug N of Scotland, because commercial availability is currently not as certain there as it is around England, Wales and N Ireland. That strikes me as a very pragmatic response. In the meantime, we are trying to broker a longer term solution that would potentially draw on existing commercial assets around Scotland.
And in parallel, we have at the same time adjusted the way that our Coastguards use their sensors and their experience to intervene with commercial tug providers at an earlier stage, when they see the potential indicators of vessels in – or approaching – difficulty around our coast.
The MCA has also been taking a pragmatic approach in modernizing the way we coordinate maritime search and rescue operations in UK waters. At present, we coordinate rescue assets from 18 Coastguard centres around the coast. These are manned, 24/7, by well trained professional officers who do an excellent job in responding to distress calls, compiling information, planning search operations and dispatching a variety of rescue assets, often under demanding and complex circumstances. Last year, they did so on about 23, 000 occasions; this year it will be more; and next year almost certainly more again. But despite their very good work, these Coastguard officers are forced by outdated technology and inflexible working arrangements to suffer long periods of inactivity, interspersed by occasional bursts of almost frantic pressure, with little prospect of relief or support from their colleagues around the coast in other, less busy stations. Because when you divide 23, 000 annual incidents between 18 centres, you get an average rate of just 3.5 incidents per station per day. But when one station deals with 77 rescue incidents in one day – as happened with Solent Coastguard during last year’s sailing race around the Isle of Wight – then its very slim pickings indeed for the rest.
So we’re reducing down from 18 coordination centres to 11; cutting the workforce of front-line rescue coordinators by a third; joining all the remaining stations together into an integrated, national network overseen by a large Operations Centre in Fareham, and enabling workload to be sensibly distributed around the whole of our national capacity at any time. This will improve both efficiency and effectiveness; it will give our officers more opportunity to practice their skills; and some of the money saved will be recycled into better pay. In the meantime we are not reducing any rescue assets or capabilities at all. My hope is that these things together will build both the competence and the morale of our Coastguards, thus again helping to better manage risks to life and limb in the maritime environment, in a sensible and proportionate way.
What else does the MCA do to manage risks? Well, we provide maritime weather forecasts through the Met Office, and we broadcast important maritime safety information to alert seafarers to new hazards. We organize the systematic updating of hydrographic surveys and charts around the UK, to keep ships and boats afloat rather than impaled on the earth’s crust. We maintain stockpiles of equipments and chemicals to deal with pollution at sea, and we hold contracts with aircraft providers to look for oil slicks and to deal with them as appropriate.
We run rescue helicopters from 4 bases in the UK, soon to increase to 10 bases. Bucking the trend almost everywhere else in the Western world, my air force is actually about to be getting bigger!
We also rescue dogs in trouble. Our 3, 500 volunteer Coastguards, dispersed in teams of about 10 around the UK coast, are equipped and trained to pluck dogs off cliffs and rocks, out of mud, or from the water. They did this on about 150 occasions last year. You may well find this a bit odd. But there’s an obvious calculation here – in most cases a dog rescued means a Dad or a Mum or a child who have therefore not had to put themselves in excessive danger. And anyway we rather like dogs. They rarely complain about the quality of rescue service, and they never seem to file claims for compensation if their fur gets scratched or their collars scuffed in the process.
Finally, a quite different kind of risk. You will be aware that during the Olympics a huge effort went into ensuring the security of individual venues around the country. You will recall the hoo-hah around surface to air missiles on the rooves of high-rise flats in East London, for example. It is perhaps less obvious that this activity extended also into the wider maritime approaches to the UK. As an island, we are of course quite vulnerable to approaches from the sea for nefarious purposes of many kinds. That is why the MCA has a significant part to play in contributing to the work of the National Maritime Information Centre in Northwood. The NMIC includes, besides us, representatives from the Home Office, the police, Navy, customs, borders and the Marine Management Organisation – amongst others. It aims to build a recognised picture of activity around UK waters and brings together most of the agencies who own bits of the jigsaw but have previously never had a common table on which to put the full puzzle together. MCA has lots of experience of watching vessel movements at sea, and a huge amount of knowledge about ships, cargoes and crews. So we have something quite useful to bring to the party. One last example of how we are trying to help manage risks – this time security risks – sensibly, and to make for more satisfied customers of our work. Thank you.”
An interesting question and answer session followed with the speaker giving some excellent and pragmatic replies and we look forward to your comments too on his presentation.