![COLUMN | The Nautical Institute, IMCA and continuing professional development: outcry from seafarers at mandatory new costs [Offshore Accounts]](http://media.assettype.com/bairdmaritime%2Fimport%2Fwp-content%2Fuploads%2F230424-Offshore-Accounts1.jpg?w=480&auto=format%2Ccompress&fit=max)
Last week, we looked at how four decades of bad government by a megalomaniac managed to ruin Libya and leave the resource-rich country in tatters. This week, we look at a dollars and cents issue that is a lot closer to home for many seafarers: new continuing professional development (CPD) requirements for dynamic positioning operators (DPOs), both deck officers and engineers.
Previously, seafarers who were certified DPOs and could document sufficient ongoing sea time using DP could renew their DP certificates with the Nautical Institute (NI) every five years for a small fee. Those who lacked the minimum amount of time on the DP consoles at sea could undertake a multi-day DP refresher course at an NI-accredited training centre to maintain the validity of their certification. That simple system changed last week, when the NI announced (here) that, in order to renew their certification, all DPOs will need to undertake annual CPD modules online and pass annual online CPD exams every year from 2024 onwards.
The reaction by seafarers to the changes threatens to undermine the reservoir of goodwill that the NI has built up amongst offshore crew since it began certifying DPOs in 1983. In fact, it threatens to leave the reputation of the charity in tatters amongst its core membership base offshore. It is rare for there to be such a consensus amongst serving seafarers online, but to say that the reception to the plans was unpopular would be an understatement. Below are some of the 46 comments on the charity's Linkedin announcement at the time of writing:
"It is complete[ly] insane and nothing to upgrade the seafarer's knowledge, but just to make money." (DPO second officer)
"This will drive so many competent DPOs away from the industry. Particularly agency or part time seafarers. A shameful money grabbing exercise from the NI." (Senior DPO)
"NI is out of its depth… They are like all other institutions just adding bullsh*t courses to keep themselves employed." (Master Mariner)
"Got to take more money from the mariner. What a scam to begin with!" (DPO)
"CPD is useful for NI to print out more money out of nothing and absolutely good for nothing – useless/ time consuming for DPOs." (DPO)
"Absolute disgraceful money grabbing rip off, pure and simple" (rigmover)
One of the 46 posts pointed out the CPD is applicable in many other professions such as medicine, law, and civil aviation. But nearly all lawyers and medics are better paid than junior DPOs. And there appears to have been no consultation with those seafarers who will be paying the fees for the new CDP on the material they must study, the online courses they must take, and the relevance to their work.
This is not a voluntary CPD system; this is a mandatory system. If you want to remain a DPO, you must pay for this CPD. The whole way the change has been communicated is flawed, in my opinion. I would point out that in law, actuarial studies, and accountancy, mostly employers provide the CPD at the employer's cost. In this case, it is clear that many seafarers will be paying from their own pockets, often on top of their existing NI memberships. Currently, the NI's most common grade of membership is "MNI", the cost of which is £150 (US$180) per year besides a one-off joining fee of £35 (US$42), with a reduction of almost 50 per cent for those seafarers who live in an economically Less Developed Countries.
The NI has performed invaluable work across the maritime institute for decades, please don't misunderstand me. Its conferences, seminars, and industry lobbying are invaluable. Its magazine Seaways is a superb resource on safety. Its trustees work without salaries.
Now, however, it has unleashed a firestorm of criticism and a lot of this revolves around the costs associated with the CPD.
At the moment, there are only two approved CPD providers: the International Marine Contractors Association (IMCA) and Keelson Marine Assurance in Houston, as per the NI website. The NI has made it clear that any employer who wishes to accredit their own in-house CPD will have to, er, pay the NI to have the course accredited.
With an amazing lack of consideration, in the tin-eared press release announcing the changes, IMCA's Technical Adviser – Marine made an attempt at reassurance.
"We're pleased to share our FAQ document outlining what is now expected of DP Operators and how best to meet the new requirements," the technical adviser said. "Published for free on our website (my emphasis), this is one way IMCA is supporting the industry to understand the new rules from the NI."
Publishing for free on your website the exciting news that seafarers will have to pay a triple digit fee every year for the rest of their professional lives is not exactly something to boast about. Strangely, "how best to meet the new requirements" involves downloading an app from IMCA and making a payment to the NI.
The IMCA FAQ at least answers the mystery of how much seafarers will be paying for the new CPD modules:
"How much does the IMCA Key personnel DP App cost?
It normally costs £50/US$60 per module, or £100/US$120 a year. Fees are charged at registration by the NI – and payment is made through the NI's Alexis Platform and excludes VAT (taxes)."
If you are going to force seafarers to pay additional annual fees for CPD for the entirety of their careers as DPOs, you better have some very good reasons to justify the charges, and you better communicate them clearly. NI and IMCA have failed this test, based on the barrage of criticism they unleashed upon themselves when they announced the plans. In the interests of transparency, perhaps they could explain how the revenue from the IMCA Key Personnel App relates to the cost of developing and maintaining it, and how the revenue is split between the two bodies.
Details are very thin on the ground. Looking into the information online is a frustrating exercise. How long will the CPD take to complete every year?
"The NI's standard for the revalidation course states 'not less than 34 hours'. Logic would then suggest that an NI-approved CPD programme should not be less than 34 hours spread over five years. This equates to not less than seven hours a year."
For those less than seven hours, Keelson will charge a DPO US$150 for a year if they enroll independently of their employers, and with a 30 per cent discount if you sign up this month. Strange that the only two accredited DPO CPD centres in the world are charging such similar amounts…
The CPD requirement has been tacked on the end of the 225-page Certification and Accreditation Standard released by the NI in January, which is mainly a consolidation of IMCA Guidelines. It was mentioned as a likely development in the May 2022 DP conference organised in the Netherlands by the IMCA (here).
Unfortunately, the news of mandatory CPD being implemented in 2024 came as an unwelcome surprise to most seafarers.
In the NI's strategic plan for 2021 to 2026, the charity set itself the ambitious goal ("key deliverable") on page seven, a goal of generating "£2 million (US$2.4 million) annual income from qualifications, courses and accreditation services," a 10 per cent increase on the 2021 revenues from this area.
How then is it possible to meet this goal that the organisation has set itself? It is hard to avoid the conclusion that imposing CPD would be one obvious route. When an organisation that has a monopoly over a qualification and is notionally a not-for-profit sets itself a revenue target, its members and all who need those qualifications to practice their profession should be very afraid.
The NI has begun to certify ice navigators and the sudden appearance of mandatory CPD for DPOs should perhaps have these frost-bitten mariners also checking their email to see when the NI will be charging them for the privilege of doing their jobs. Maybe containerships need additional CPD for stowage planning? This is a very slippery slope and a major publicity goal for the NI.
The trustees should not be letting the NI management pull a random number out of the air as a key deliverable and then impose additional charges on the holders of all its accredited qualifications to achieve it. It is not as if DPOs can tell the NI to go stuff itself (although many appear to have done just that on Linkedin) and then go to another provider. DPOs have no choice but to pay what the NI's accredited training providers demand, and at the moment there are only two of them, with fees that are remarkably similar.
The NI has a monopoly over the creation of DP training standards and over the accreditation of DP training providers, and I feel that these new CPD charges are an abuse of the monopoly position it was granted in 1983 (See the history of DP certification below.).
Let's be clear: the NI does not appear to need the extra money. Based on its audited Annual Report for 2021, which it filed with the United Kingdom Register of Charities six months ago and published in Seaways in June 2022, the NI had a net income of over US$1 million on revenue of over US$4 million (see page 16 of the PDF).
At the end of 2021, the charity also had over US$1 million cash in hand and total assets of over US$4 million. It is not clear from the fact that the NI collects the payment from those who use the IMCA training modules through its Alexis platform, how much of that revenue it will receive from this source, either.
In the report, the charity even acknowledged the hardship many DPOs and other members have faced in recent years.
"Conscious of the difficulties many members have faced during the pandemic, membership fees for 2021 were frozen at the 2020 level," CEO John Lloyd wrote on the first page of the report. "Fees have again been frozen for 2022 and will next be reviewed at the beginning of 2023."
But now it suddenly decides its members who are DPOs must pay an extra annual fee on top of their membership dues, forever.
IMCA's accounts do not seem to be published in the public domain – please correct me if I am wrong here, and Baird Maritime will happily publish a link to the audited financial accounts of this important industry body. But I am not convinced that the cost of the online training to the seafarer is in any way related to the cost of the online app IMCA provides to deliver it or the accreditation the NI charges to Keelson and IMCA.
Happy to be corrected, of course.
IMCA also does wonderful work to raise industry standards. We have no complaints with its mission, its history, and its admirable achievements. IMCA is excellent at publishing DP incident reports – "events" as it describes them. Its online archive suggests that the number of DP events has been falling in recent years, not rising. The training requirements for DPOs have increased and the standards for certification and operation are arguably higher than they have ever been.
The reasons for the CPD are not very well explained in the "Important News" section of the NI Alexis website:
"The Nautical Institute works with Industry Stakeholders who recognise the importance of the mandatory CPD for the DPOs and DPVMs for their DP Certificate revalidation to improve their DP knowledge through a systematic approach to continuing professional development.
"The Nautical Institute revalidation requirements will help reduce skill fade and help continuously upgrade skills to provide for safer DP Operations."
Who are these industry stakeholders exactly? IMCA, perhaps? Could this be a circular process between the two main beneficiaries of the move? Surely not! The online reaction suggests that many seafarers are cynical as to the motives for imposing these extra requirements, which simply add hours more of online training time and exams.
So, is there any evidence that skills fade is a problem within the offshore industry?
For seafarers using DP every day in their shipboard operations, it is not clear to me why DP skills would fade. For those not doing actual DP work, the NI already demands refresher training before renewing DP certification, which seems eminently reasonable and fair.
There's very limited evidence that online training modules will actually "upgrade skills". Most research suggests that hands-on, shipboard training is best – in order to become DPOs, seafarers already have to undergo rigorous theoretical training, and hours and hours and days and days of documented sea time performing DP operations. The academic evidence of the efficacy of online training is little studied – most studies are based on self-reported data and are very subjective, and the NI and IMCA completely fail to make an evidence-based case for needing CPD.
IMCA's own accident database suggests that the main causes of serious accidents are the usual suspects of falls from height, slips and trips, dropped/falling objects, muscle stress and repetitive movement, and, especially, line of fire incidents.
No one would argue if IMCA and the NI could point to accidents where dynamic positioning skills fade had been an issue, but they have not made the case at all. If you wanted to make one area of offshore safer, you would focus on line of fire, which caused the most injuries in recent years.
Indeed, IMCA reports that the rise in fatal accidents offshore in 2021 was driven by vessels capsizing or being lost in bad weather (which have nothing to do with DP).
Mixing mandatory safety training with mandatory payment to the bodies that demand the training is never a good idea from a reputational point of view. Many seafarers are of the opinion that the new CPD is simply a way for IMCA and the NI to generate extra revenues. The existence of training and accreditation revenue targets in the NI suggests that such cynicism may be warranted. The NI and IMCA have done nothing to assuage those fears.
We all want the industry to be safer and we all want the NI and IMCA to have the funds to continue their valuable work. The NI has set itself the target of having 10,000 members by 2026 in its Strategic Review. I would suggest that in order to generate goodwill in the seafaring community, the NI and IMCA should sit down together and reverse their ill thought-out plan for the NI to charge US$120 every year to every DPO from 2024 onwards for the IMCA app.
Instead, CPD in DP should be provided free of charge to all NI members worldwide through the Alexis platform. That would boost membership and remove the obvious (and possibly ill-founded) insinuation that this is just an exercise to demand money from seafarers with the menace of removing their DP licences if they do not comply and pay up. If IMCA and Keelson want to provide DP CPD to non NI members and to companies, I don't think anyone would object to that, either.
The NI was granted a remarkable monopoly over DP accreditation in 1983. Now, in 2023, it should be seen to be doing the right thing for DPOs everywhere. CPD should stand for "continuing professional development", not "continually paying dollars".
Until then, the suspicion will remain that "This is how the NI make money," as one commentator on Linkedin succinctly put it.
Background to DP certification
The Nautical Institute was founded in 1971. The charity developed DP Accreditation and Certification schemes in association with flag states, the oil industry, the diving industry, and offshore contractors to establish internationally accepted standards.
In September 1983, the NI accreditation scheme was adopted as an internationally accepted standard for any dive support vessel or other DP-operated vessel working within any designated 500-metre zone at any offshore installation by 105 out of 110 oil industry and major oil company representatives at a working conference in Aberdeen, Scotland. It was rapidly recognised by the oil industry on a worldwide basis. At the time, very few vessels were dynamically positioned and most worked in the North Sea, concentrated in the diving and offshore construction industries, with a few dynamically positioned drillships.
According to the NI's website, less than a month after the Aberdeen conference, the scheme was accepted as an official guideline by the then Minister of Energy for the UK North Sea operations, and the scheme was then also adopted by other North Sea operating flag states.
Since the 1980s, however, the number of vessels using DP and the number of accredited DPOs have increased exponentially. More than one hundred DP drillships and semi-subs are currently working in ultra-deep waters and there are more than one thousand DP-certified offshore support vessels in service.
The NI doesn't release numbers of certified DPOs, only of new logbooks issued (over two thousand in 2021) but I would estimate that there are over 15,000 active DPOs in the world today. The move to implement mandatory CPD thus impacts thousands.
The Nautical Institute's Twitter feed is here.
IMCA's Twitter feed is here.
