by F R Chowdhury
It was only about two weeks back the Director General of the Department of Shipping proudly announced that soon Bangladesh is going to earn much more foreign exchange through employment of seafarers than what it earns from export of ready-made garments. We were very delighted. We thought at last this sector was going to get its recognition and that the Government was going to do everything necessary on its part. Our dream was very short lived. Now we know that Bangladesh failed to send to IMO the periodic independent audit report of its training and examinations system. In this respect Bangladesh already received a warning note from IMO that unless the quality of training and certification is improved and all requirements of the STCW Convention are complied with, Bangladesh may lose its position in the IMO white list. If that happens, the certificates issued to seafarers by Bangladesh Administration shall lose its recognition by other Member States. The outcome will be disastrous – no employment of our seafarers on foreign ships. Their employment on Bangladesh ships will also be at stake because they would not be treated as duly qualified and as such our ships may not be able to visit foreign ports with our own seafarers. We may have to employ foreign seafarers. Forget, earning foreign exchange, there will be drainage of foreign exchange. What will our Director General have to say? Perhaps it does not matter much to him because officials in Bangladesh are used to making such statements.
I shall now write in brief all about it for the benefit of readers of this paper. Seafarers training and certification is done by each Party State in compliance with the provisions of the International Convention on Standards of Training, Certification and Watch-keeping, 1978, as amended. The Convention requires each Party State to submit to IMO (as depositor) copies of its national rules-regulations, system-procedures including names of competent persons conducting key functions. It obviously implies that after any amendment enters into force, the national legislation, syllabus, system and procedures have to be amended accordingly and submitted to the depositor afresh. It is understood that Party State will also have to satisfy that trainers and assessors for any newly introduced course are duly trained.
The Convention got a Quality Standard System. It is a two-tier system. Regulation I/6 states “Each Party shall ensure that all training courses and institutes shall be supervised, assessed, approved and monitored by the Administration”. This means to say that any training that counts towards the process of certification must be approved by the Administration; and once approved; they shall be inspected and monitored at random to ensure the continuation of the standard. Documentary evidence of such check, assessment, approval and subsequent monitoring must be available both with the institutes as well as the Department of Shipping.
The second part of the QSS is contained in regulation I/8 – “Where the Administration has any function in relation to certification of seafarers, it shall maintain a quality standard system which shall be periodically (not more than 5 years apart) audited by competent persons (conversant with the process of training and certification) who do not work for the Administration. A report of such independent audit shall be forwarded to the Secretary General of the IMO”.
There are certain things that one has to read between the lines. Arrangements may have to vary depending on each country’s system. In Bangladesh if the focal point of Administration is the Director General, then it is obvious that he cannot arrange for audit of his own work. The Director General will remain responsible for operation of day to day work and shall be answerable to the minister. In this case the minister will form the audit team and the team will report back to minister with their findings. The conventional decorum suggests that the minister should forward a copy of this audit report to the Secretary General of the IMO; and that completes the cycle. While working as a Consultant/ Adviser to the IMO, I suggested the above procedures to many developing countries that are successfully listed in IMO White list.
In the last part of this paper, I shall discuss in brief as to how the audit is done. Though it is primarily an audit of the administration, it may still have to visit training institutes for two reasons – firstly to see how the administration approved and monitored those courses and secondly to have an idea in general of the standard of education and training. With regard to audit of the administration, the team would like to see the documented procedures and criteria followed for approval of the institute and the courses and result of further visits and inspections. It shall inspect the syllabi and procedure for oral and any other test and examination conducted directly by the administration. It will see how the administration conducts its checks for other requirements such as – identity of the candidate (name, nationality, DOB/ age), medical fitness, record of sea-service (and workshop training where applicable), training records, results of other ancillary courses and finally the result of the main course for the grade of certificate. The team would certainly like to see how all information is compiled together and the process of issuing certificate. Finally the team would like to see the record-keeping and response to queries (bearing in mind that from 2017 the data-base should be directly accessible).
Quality assurance can be achieved through appropriate legislation, competent administration, documented procedures, record-keeping and periodical evaluation for further improvement. IMO does not need to send auditors when convention is fully complied with. The department needs a dynamic director general with knowledge and vision that will talk less and do more. I draw the attention of the Prime Minister and Shipping Minister to look into the matter urgently and save the maritime sector.
<fazlu.chowdhury@btinternet.com>
