Recommendation Date
Recipient Name
Maritime New Zealand
Text
On 13 March 2025, the Commission recommended that the Director of Maritime New Zealand review their competency frameworks for STCW-F-aligned certificates, to ensure they include the basic principles to be observed in keeping a navigational watch as set out in Chapter IV of the Annex to STCW-F.
Reply Text
Maritime NZ reject this recommendation
Maritime NZ considers changing the competency framework is unlikely to resolve this issue. The competency frameworks for STCW-F aligned certificates align closely with international requirements. The rules around what is required for watch (including at a competency level) are, in our view, very clear as outlined in our position statement on watch keeping https://www.maritimenz.govt.nz/media/rpkbjmn5/lookout-position-statement.pdf. We do not consider that a review of competency frameworks would have a significant impact on the factors above.
Our strong view, based on ongoing discussions with the sector, are that the drivers of poor lookout and watchkeeping practice are complex; relating to economic constraints (particularly for smaller operators), interactions with other drivers of harm such as fatigue, embedded historical practice, attitudes to government / compliance and a range of other factors. These drivers require an equally multi-faceted harm prevention approach in partnership with the sector and others over time. We would suggest that TAIC considers and encourages work on the wider factors that contribute to poor watchkeeping.
Maritime NZ notes that the STCW framework is being reviewed which will not be complete until around 2030 and the STCW-F framework have just completed a review at the IMO. We are engaging as a priority in this work. If the reviews identify any changes to the conventions or competency requirements we would consider how any changes apply domestically at the appropriate time.
Maritime NZ has had a significant focus on lookout and watchkeeping in the fishing sector for a considerable period of time. As TAIC has noted, this is because good watchkeeping and lookout practice is essential to prevent a range of harms; including collisions, strandings, groundings and safe navigation. However, ensuring good practice remains a challenge.
Maritime NZ is confident that our current framework, work with the sector, and position statement are closely aligned with STCW-F in regards to watch keeping. As such, Maritime NZ do not support the recommendation.
Maritime NZ considers changing the competency framework is unlikely to resolve this issue. The competency frameworks for STCW-F aligned certificates align closely with international requirements. The rules around what is required for watch (including at a competency level) are, in our view, very clear as outlined in our position statement on watch keeping https://www.maritimenz.govt.nz/media/rpkbjmn5/lookout-position-statement.pdf. We do not consider that a review of competency frameworks would have a significant impact on the factors above.
Our strong view, based on ongoing discussions with the sector, are that the drivers of poor lookout and watchkeeping practice are complex; relating to economic constraints (particularly for smaller operators), interactions with other drivers of harm such as fatigue, embedded historical practice, attitudes to government / compliance and a range of other factors. These drivers require an equally multi-faceted harm prevention approach in partnership with the sector and others over time. We would suggest that TAIC considers and encourages work on the wider factors that contribute to poor watchkeeping.
Maritime NZ notes that the STCW framework is being reviewed which will not be complete until around 2030 and the STCW-F framework have just completed a review at the IMO. We are engaging as a priority in this work. If the reviews identify any changes to the conventions or competency requirements we would consider how any changes apply domestically at the appropriate time.
Maritime NZ has had a significant focus on lookout and watchkeeping in the fishing sector for a considerable period of time. As TAIC has noted, this is because good watchkeeping and lookout practice is essential to prevent a range of harms; including collisions, strandings, groundings and safe navigation. However, ensuring good practice remains a challenge.
Maritime NZ is confident that our current framework, work with the sector, and position statement are closely aligned with STCW-F in regards to watch keeping. As such, Maritime NZ do not support the recommendation.
Related Investigation(s)