Hydro Pilots do not operate with a self-managed approach. Our Pilots work to a structured roster. Our Pilots work to a 20 day on 10 day off cycle. This roster has been implemented and agreed upon between all pilots and management.
In addition to this Hydro Pilots in conjunction with Torres Pilots Pty Ltd have recently submitted an alternative FRMP to AMSA. This plan has been developed with the assistance of sleep/fatigue experts Sally Fergusson and Mathew Thomas from the Appleton Institute of Adelaide. You will be aware that their input and expertise has also been sought by AMSA on the issue of fatigue within coastal pilotage.
The main purpose of the new FMP is to increase the frequency of pilot rostered leave and to increase the certainty of pilot time off roster. The proposed FMP will not increase Mackay resident pilot’s work commitments. It will provide those pilots with more certainty regarding their time at home by increasing the number of days they enjoy off roster, that is, the proposed FMP will allow the use of a more efficient roster and more planned time at home for the pilot.
The 10-day rest period allows for more frequent periods of long breaks from work, and as such is seen as an important mechanism in reducing the likelihood of cumulative fatigue. The plan also looks at Risk Identification and Assessment taking into account many factors. The plan is based on a “safety-case” approach which is what AMSA have requested.
With regard to the inclusion of pilot travel and transfer times this is not the case within our operations. Prior to commencement of pilotage a “Job Risk Analysis” is completed which look at many factors including the pilots previous rest to ensure that the 12 hour rest has been complied with. Upon completion of the pilotage our pilots provide our operations with the completed “certificate of pilotage” where the landing time back at Mackay is recorded as the completion time. Marine Pilots do not allocate themselves to ships. This is done by operations and is based on compliance with the current FRMP.
In response to the above I can refer back to my time with Torres Pilots Pty Ltd where all pilots were encouraged to report on any issues encountered on board vessels be they technical, safety or near miss incidents. All of these reports were documented and made freely available during every audit completed by AMSA.
On many occasions we were thanked by the operator of the vessel for the reporting of vessel deficiencies as these had not been reported by the Master back to his management.
In looking at Risk Identification HP will be adopting and managing risk through the implementation of processes currently followed by our aviation operations. On many occasions I have heard that we should look to the aviation industry and the processes that are followed there in regards to the mitigation of risk and improvement to safety. To this end HP will be utilizing a system and processes currently used within our aviation operations.
This system is well known to CASA and allows for safety reporting, risk identification, hazard register, hazard actions and follow up.
In addition to the above and prior to any pilotage the vessel is forwarded the passage plan which not only includes waypoints but also checks for parallel indexing, reporting obligations for REEFVTS, emergency contact information and cross tracks error limits for GPS entry. All pilots follow the same Pilot/Master exchange procedures. In essence we have uniformity in our approach to passage planning and associated documentation and reporting. All of the documentation for each completed pilotage is sighted and filed upon completion of the pilotage just as do within our aviation model.
AMSA conducted a follow up audit of our systems on Monday 14th January 2013. The above procedures were shown to the audit team and I was advised upon completion of the audit that the proposed implementation of this system would meet the requirements under Marine Orders Part 54.
We hope the above provides sufficient evidence in supporting the changes we have made and continue to implement within our SMS.