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[Operator's] marine pilot training program

Reporter's deidentified concern

The reporter has raised concerns regarding the standard of training for [Operator] marine pilot trainees at [Location]. 

The reporter states there is a significant gap in the standard of training between existing training programs to that of the [Operator's] marine pilot training program and provided the following examples: 

Cape size licence comparison – standard [commodity] bulk carrier size 185 / 210K Deadweight tonnage (DWT)

The reporter provided an example of an [Operator] marine pilot trainee completing a Cape size licence (<210K DWT) in as little as 3.5 months on-water training. This comprised of approximately 40 on-water jobs (supervised/solo/observations) which is significantly less than other training standards whereby trainees can take up to 16 months to complete, corresponding to approximately 600 on-water jobs (supervised/solo/observations).

[Commodity] tanker licence comparison (50K DWT)

The reporter states [Operator's] pilots can achieve a 50K licence ([Operator] Pilot first licence) and potentially pilot tankers as their very first solo job. In an example provided, a trainee pilot piloted a tanker on the trainee's third ever solo job. This is also significantly less than other training standards requiring some 180 on-water jobs which can include a total of 70+ supervised jobs and 14 solo jobs on an introductory licence (30K DWT) before piloting tankers (50K DWT). 

The reporter also states there is an over-reliance on simulator-based training and that there is well documented industry concern, as ships operate in a three-dimensional space whereas simulators only operate in two dimensions. The skills a pilot develops on the water are significantly more substantial than those developed in the artificial environment of a simulator. This on water experience takes into account actual environmental factors over and above simulation, but also allows for an in-depth training on local knowledge of the port and its many safety considerations.

The reporter is further concerned of the significant consequence should an incident occur as the result of reduced training standards which could compromise port infrastructure, the integrity of the [Location] shipping channel as well as the potential for pollution in the marine environment.

Named party's response

Preamble "The reporter states that there is a significant gap in the standard of training between existing training programs to that of the [Operator's] marine pilot training program...

[Operator] acknowledges that there is a significant difference between the training regime of the [Operator 2] and the [Operator] pilots. However, we will not accept that this significant difference is in any way a lowering in training standards or resulting pilot competency. To the uninformed observer the difference may be interpreted as a difference (a gap) in standards. [Operator's] recently developed, and more scientific pilot training regime is a significant improvement in training which has introduced measurable competency markers based on evidence rather than personal opinion and in the fullness of time we will insist that any contracted pilots adopt, meet, and maintain these higher standards.

The [Operator] under the [Regulatory Act] is responsible for the efficient and safe operation of the port, by extension that creates an obligation to the Port Users (some of Australia's largest [industry] and export operators) and to the Government, both State and Federal, to nurture, protect and facilitate port trade, which for many years has generated millions of dollars for each of these parties and hence the Australian nation.

Such a heavy responsibility has resulted over the years in the development of a finely focused culture on risk. We do not believe that there is a person working in the port that doesn't understand the incredible consequences of an incident in the shipping channel, none more so than the Board of Directors, the CEO, and the senior management. None of whom would knowingly allow any situation to exist or develop that could potentially increase the port's risk and jeopardise the wellbeing of our stakeholders. 

[Operator] engaged two senior, highly experienced marine pilots to work with senior mariners within our management team to develop a suitable operating structure, training and assessment regime along with a safety management system to ensure that the [Operator] could supplement the contracted marine pilots in the event of their absence through illness, fatigue or any other cause, with marine pilots of equal or greater competency than those they were relieving. It was clear that our training regime could not afford to cut any corners if the risk we were trying to address was increased through lower standards than has traditionally been the norm.

We are very confident that the [Operator] marine pilot training and assessment process can stand up to any scrutiny and in fact is superior to most traditional pilot training schemes.

Before addressing the provided examples, it may be helpful to understand some of the features of the [Operator] training regime.

  • [Operator's] regime is designed for both experienced and new pilots.
  • The training plan is tailored to the individual trainees needs. As a part of the recruitment process, candidates are exposed to intense simulator assessment, not necessarily to determine how good they are but to how teachable they are and in what areas they may need special instruction, combined with an 'on the water' assessment. This information is used to develop an individual training program.
  • The training and assessment are competency and proficiency based, so experience is taken into consideration and not ignored as is the case in the contractors' training regime.
  • The training utilises both technical and non-technical (human behavior) markers removing subjective personal assessment of a candidate's competency.
  • The training, while mostly on-water, makes extensive use of full mission ship simulators to enhance the exposure and understanding of cognitive overload resulting from high-workload environments that can be experienced when things are not going as well as they might, such as in an emergency.
  • The marine pilots forming our senior training cohort have over 160 years of large ship piloting experience.

The significant gap in standards highlighted in the REPCON report appears in fact to be more about the duration of training than the standard of training.

Taking the examples provided in turn:

Cape size licence comparison 185 / 210K DWT

Under the incumbent's training regime, a pilot will have approximately 600 on water jobs, whereas an [Operator] pilot achieved this with 3.5 months of on water training. To focus on the 3.5 months on the water training includes 4 weeks intensive simulation assessments undertaken and recognises the 36 years' pilotage experience with similar sized vessels in similarly large tidal ports.

If there is actual evidence that the [Operator] pilots' performance standards are lacking, we would appreciate being provided with specific facts as we do not want to issue pilots a licence until they are proficient in every way.

[Commodity] tanker licence comparison (50K DWT)

[Operator] evaluated the existing licence levels and through risk assessment, including simulation work, deemed that the step up to 50K for a first license from 30K posed no additional risk (both groups utilise the same number of tugs) once the pilot demonstrates his/her competency within the assessment regime. This example also appears to insinuate that the job numbers alone create competency.

[Operator] believes that it is unfortunate that the reporter does not understand the value and use that we make of simulators. [Operator] is aware of the limitations but also aware of the immense value they provide in developing muscle memory beneficial to addressing and reducing mental overload in high workload situations. [Operator] is certain that recent past incidents in the port might have enjoyed better outcomes had there been training systems based on technical markers and increased use of simulators.

[Operator] appreciates the reporter's concerns in relation to the importance of the integrity of the port infrastructure, the channel and the environment. These matters are in fact close to the heart of the [Operator] Board and senior management as a direct result of our personal liability in the event of compromise resulting from any negligence or dereliction of duty and through this exchange invite them to raise at any time, their concerns with the Harbour Master or if necessary, the CEO.