Review of Fishermen s Training. Role and Financial Investment by Seafish.

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1 Review of Fishermen s Training. Role and Financial Investment by Seafish. Context Fishing is the most hazardous activity in the UK with 67 deaths per 100,000 employees (5 year Moving Annual Total , MAT) (Marine Management Organisation, 2012). This compares to the UK average employment death rate of 0.6 per 100,000 employees for 2011 (HSE provisional data). This problem is not unique to the UK or indeed the marine sector and it is estimated that world wide that the loss of fishermen could be running at per annum or 65 per day. (Intenational Labour Organisation 1999) Seafish has played a significant role for at least the last 25 years in the role of fishermen s safety and the training of fishermen. Our work in this field is varied and covers three main fields: 1. Marine Survey: vessel construction standards, vessel survey, registration of vessels, commissioning reviews of hazardous equipment and design proposals to minimise hazards operated through a delegated arrangement with the Maritime and Coastguard Agency (MCA) 2. Hazard Awareness (Kingfisher): hazard mapping, coordination of fishing hazard alerts, dissemination of alerts through electronic means and charts in partnership with the Oil, Gas and cable industries 3. Fishermen s Training: training course development, encouraging a competent training network, audit and performance of that network, promotion and stimulation of training by coordinating available grants, record-keeping of all mandatory training for fishermen working on UK-registered commercial fishing vessels. Marine Survey and Kingfisher are operated as part of our Marine Services Operation and are broadly cost neutral to levy. A separate paper is being prepared for the board to review risks, options and opportunities for Marine Services. Seafish has established a new process for determining the work that we undertake by forming three industry led panels. These panels are made up of stakeholders from the Domestic and Processing Sector, the Import and Processing Sector and the Supply Chain Panel. Our levy funding derives from all three of these sectors, and is collected at the point of first sale. Unsurprisingly, the domestic panel was strongly in favour of maintaining Fishermen s Training, whilst the Importers and Supply panels both challenged the quantum of spend and the method of disbursement through subsidies (part funded by levy) directly to fishermen to encourage training uptake. These panels expressed a view that Fishermen s safety training should not be funded by levy, as it was not a prime duty of Seafish. As a budget had to be struck, the chairs of the three panels agreed for status quo budget on training for 12 month period whilst a fundamental review was undertaken. It should be stressed that the importers and supply chain panels are not against Fishermen s Training and indeed recognise it as a serious reputation issue. The issue is primarily about the use of levy to subsidise training and what is the role of Seafish in training of Fishermen. Page 1 of 13

2 Proposed Scope of Review To undertake a review of Role of Seafish and activities in support of training. Objectives define the role(s) of Seafish in the training of fishermen to identify the appropriate cost to levy in support of training of fishermen by Seafish. to identify alternative sources of funding to replace levy expenditure on subsidising Fishermen's training to identify other activities/initiatives that Seafish could support to improve fishing safety. Current financial outlay: (secured under the current panel agreement until September 2013) Annualised spend training: 1.67m Sources of funds: Seafish Levy MCA EFF 700k (of which 400k used to match fund grants from MCA and EFF) 250k (formerly provided by Dept of Transport) 650k (claimed retrospectively in arrears) Fishermen s Trusts & Others 50k Industry 20k (certificates and learning materials) Use of Funds: Seafish Staff Costs 165k (coordination, administration, development, project management) Seafish Other Costs 35k (overheads, office, travel, etc.) Procured services Sub Total: Training Promotion 250k (external contracts, projects, membership fees, meetings, printing) 450k 1,220k (full grant subsidy for Refresher Safety Training, New Entrant Training, Under 16.5m Skipper's Certificate and partial subsidy for Certificates of Competency). Seafish Training is staffed by full time by Keir Day and Sharon Burke. We currently have one vacancy which we are waiting for permission to fill. This gap has been filled in the interim by a combination of time (equating to one FTE) from Richard Wardell and Simon Potten. This team is responsible for the coordination Page 2 of 13

3 and maintenance of the training network, coursework development, audit, collaboration and partnerships. Sharon deals with the many enquiries we receive (from fishermen, training providers, MCA, etc.) on training and the certification/database management. Simon Potten has operational responsibility for this area of work as well as other key duties in the organisation. Importantly he assembles and successfully overseas the EFF grant application as well as interfacing with main partners at senior level. Paper 2 reviews the income and expenditure on Fishermen s Training 2008/9 through to 2011/12. It is important to note that Seafish activities were virtually at a standstill from March 2009 to June 2011, but Seafish was able to maintain Fishermen s Training due grant funding. This paper also summarises the outputs delivered in each period, in terms of the number training places. Should we be focussing on accident/incidents or fatalities? The common wisdom is that any actions to reduce accidents and incidents will have an impact on fatalities. A step change in fatality reduction occurred in the 1980 s in Iceland when accident reporting was introduced in order as part of a package for fishermen to qualify for government sick pay. Subsequent iterative review of accidents in Iceland, combined with a package of other measures has helped to reduce fatalities to virtually no fishing fatality incidents in the last three years. The yr MAT per 100,000 fishermen in Iceland is 22 per 100,000, compared to the UK at 67 per 100,000. The Iceland fatality rate compares favourably with UK Merchant Seafarers rate of 25 fatalities per 100,000 employees (5yrMAT at 2011). Commercial fishing is one of the most dangerous occupations in the United States. Many commercial fishing operations are characterized by hazardous working conditions, strenuous labour, long work hours and harsh weather. During , an annual average of 46 deaths occurred (124 deaths per 100,000 workers), compared with an average of 5,466 deaths (4 per 100,000 workers) among all U.S. workers. (NIOSH 2011) A possible inherent problem with the statistics in the UK is that we appear to under report fishing accident and incidents and this is in part symptomatic of the culture of the sector. Figure 1 shows that the accident reporting rate per 1000 vessels is roughly half that of UK merchant vessels (Marine Accident Investigation Board 2011), this seems very unlikely and therefore this paper uses fatality rate as an assessment tool. Page 3 of 13

4 Figure 1 UK Accident Rate Merchant and Fishing Vessels per 1000 vessels (MAIB Annual Report 2011 adapted) Merchant Accidents per 1000 vessels Merchant 5 year MAT Fishing Accidents per 1000 vessels Fishing 5 year MAT Do we have data issues? The use of non EU foreign nationals on some types of fishing vessels has increased over the last 10 years, the industry also utilises EU nationals. Is the data collection system robust enough to ensure it includes these individuals? Inclusion of these fishermen in the workforce will further reduce the rate of fatalities. This is a practice that has developed within the industry in the last years. We also need to ensure that fatalities are restricted to commercial fishing operations and do not include sports angling. Has training made a difference? Figure 2 shows the fatality rate expressed as per 100,000 employees for fishermen and merchant seafarers. The trendline and 5 yr MAT both show an improving situation for fishermen, whilst the merchant vessels show a slight increase driven in part by the incident figure in Analysis of this type of event data will always be subject to one off catastrophic incidents. Page 4 of 13

5 Fatalities per Fatalities per 100,000 Fishermen and Merchant Seafarers Merchant Fatilties per/ Merchant 5 year MAT 124 Fishermen Reg+PT per/ Fishermen Reg+PT 5 Yr MAT Trendline Seafarers Trendline Fishermen Whilst it is not possible to make a categorical statement that the fishermen fatality rate improvement is due to training, it is difficult to attribute to other reasons. The average age of the fishing fleet continues to increase, though a series of decommissioning schemes has perhaps removed the more unsuitable vessels, and the economic performance of whitefish, shellfish and small boat operations continue to be challenging. In some respects we should be applauding the progress made in reducing fatalities by around 40% since Is training cost effective? The Health and Safety Executive publish appraisal values for workplace fatalities (HSE 2011), which estimate that land work-based fatalities cost approximately 1.59M per fatality, it is likely marine based incidents will be more expensive as Search and Rescue deployment will significantly add to costs. Using the HSE appraisal value estimates and the reduction of fatalities based on the 5yr MAT suggests that 5.6 lives may have been saved over 10 years, reducing costs to society by 8.9M. The review group may consider this a spurious assertion. Who has responsibility for safety in the Marine Environment? The responsibility for maritime safety in the UK lies with the Marine and Coastguard Agency, an executive agency of the Department for Transport. The MAIB, also an agency of the Department of Transport reviews and reports on accidents and serious incidents. What funding does government supply The MCA receives funding from the Department of Transport for Support for Maritime Training (SMarT) of 12m per annum. SMarT aims to facilitate an adequate supply of UK maritime expertise to meet the nation s economic and strategic requirements. Page 5 of 13

6 This is achieved through allocating financial assistance to organisations which provide merchant navy training. The majority of this money is focused on supporting initial training for cadets studying at junior officer level (SMarT 1). It is estimated that this will enable the MCA to contribute to the training of up to 925 new cadets starting their training each academic year. The fishing industry has always been denied access to SMarT. However, in 2008 the Department for Transport secure an annual contribution from the Department which is matched with Seafish funds of 400,000 to draw down additional EFF monies, allowing subsidies to be given for Refresher Safety Training, New Entrant Training, Under 16.5m Skipper's Certificate and partial subsidy for Certificates of Competency. There are 27,000 Merchant Seafarers and 12,405 registered fishermen in the UK (UK National Statitics 2011) (Marine Management Organisation, 2012). The levy payers from the supply chain and importers panel have strongly indicated that levy funds should not be used to subsidise fishermen s training and if required should be sourced from central funds. Page 6 of 13

7 What are the duties of Seafish in Fishermen Training? This is determined by the 1981 Fisheries Act which states: Powers of the Authority. (1) The Authority shall have power (a) to carry out research and development with respect to any matters relating to the sea fish industry; (b) to give advice on any such matters; (c) to provide training in such matters or to assist in the provision of such training by making grants or by exercising supervisory or coordinating functions; (2) The Authority may charge fees for any services which it provides and may accept voluntary contributions to its expenses or to its expenses in respect of any particular matter. (3) In determining its policy with respect to the provision of training or the making of grants under paragraph (c) of subsection (1) above the Authority shall consult with such bodies as may be designated for the purpose by the Ministers; and the Authority shall not without the approval of the Ministers exercise supervisory or co-ordinating functions under that paragraph (prior acts for The White Fish Authority and Herring Industry Board make little or no reference to training) As such there is no statutory duty for Seafish to undertake training or safety support unless it is covered under the term any matters relating to the sea fish industry. There could be several interpretations on the meaning and intent of the Act, as whilst it indicates that we shall provide training, is this on any such matters or only relating to research and development. Similarly the word shall could be interpreted as non-obligatory. Seafish does however have a statutory obligation under Statutory Instrument 1989 No. 126 The Fishing Vessel (Safety Training) Regulations 1989 as amended by SI 2004 No The Fishing Vessels (Safety Training) (Amendment) Regulations 2004, fishermen are required to hold Seafish certificates evidencing their attendance on basic safety training courses. We fulfill this duty through the issue of certificates against the attendance at approved Seafish courses provided by approved Associated Training Providers. Seafish operates under an MOU from the MCA covering the co-ordination, delivery, administration, certification and record-keeping of fishermen's training. The duties of Seafish under this MOU are: Maintain records of all Seafish-certificated fishermen's training Record details of any non-seafish certificated training, deemed acceptable by the MCA as meeting mandatory requirements, which it is able to verify Page 7 of 13

8 Provide information to the MCA, MAIB, police and insurers on the compliance of named fishermen with training requirements Provide information to fishermen on their records held and their compliance with training requirements Issue certificates to fishermen on satisfactory completion of training and/or compliance with mandatory requirements Review and update the content and delivery of Seafish-certificated training courses at least every five years Approve and monitor training providers to organise the delivery and certification of Seafishcertificated fishermen's training, ensuring that they have sufficient insurance in place to cover their activities Take action to ensure reasonable geographical access to training by fishermen from all parts of the UK Approve and monitor instructors to deliver Seafish-certificated fishermen's training courses, maintaining records of their qualifications and experience Actively seek funding to support the development and delivery of fishermen's training Support the MCA's Fishing Industry Safety Group (FISG) and organise meetings of (and provide secretariat services for) it s Training Sub-Group These duties are largely funded from levy (circa 350k per annum, offset partially by certificate and course income of 20k) Does Seafish Activities in the field of Fishermen s Training and Safety have any reach outside of the UK? We have an informal working relationship with FAO Rome. Ari Gudmundsson Fishery Industry Officer (Vessels) has stated First I would like to say that the Seafish products related to safety at sea in the fisheries sector are recognized of being of excellent quality. In this regard, I would like to mention that your construction standards for fishing vessels < 12m are being referred to by the new FAO/ILO/IMO Safety Recommendations for decked fishing vessels of less than 12 metres in length and un-decked fishing vessels There is also scope to that FAO should seek funding for a global campaign which would mobilise relevant institutions throughout the world to generate training and awareness materials at all levels. In this regard, I think the existing safety-at-sea related material prepared by Seafish would provide a good basis, from which training and awareness materials for less developed countries could be developed. What are other organisations doing? Against the current backdrop of better regulation and central government cutbacks it is difficult to engender a new regulatory approach, in any event it is likely that a package of measure may be required combining regulatory, cultural and industry organisational changes. The MCA are leading with a campaign to Page 8 of 13

9 To eliminate preventable fatalities Reverse the belief that fatalities and accidents are inevitable in the fishing industry. To help develop an industry philosophy under which owners, skippers and fishermen accept responsibility for safety of life i.e. developing a mature safety culture. To provide & support the education, training and certification of fishermen. The Federations are both mounting a PFD campaign utilising EFF funding. SFF have introduced a risk assessment audit using an internal audits which assist with raising standards for vessel guard duty. The Fishermen s Mission have a current campaign on flotation devices in addition to their welfare and emergency support services. RNLI are also promoting a PFD campaign and have historically provided MOB equipment and reosurces Seafish coordinating funding from various sources to provide subsidy for fishermen for a range of training activities. Even given 100% funding, uptake is well below target levels Whilst all these organisations work together through FSIG and there is pride in an individual organisations ability to initiate and deliver their own initiatives; there is perhaps a collective lack of assignment of responsibility for particular activities, particularly related to tolerance of non compliance. Do training subsidies work? The argument put forward by land based industries is that they do not receive subsidies for their H&S training requirements. If a fork lift driver requires training for H&S purposes, whether mandatory or non mandatory it must or should be provided by that company. As most fishermen are self employed, they lose wages for the time spent on training courses, it is therefore argued that they should be encouraged by a subsidy to be trained. Even with this subsidy uptake remains challenging. A similar problem faced the building industry, where self employed operatives were being employed without the right training, safety equipment, and contract status. A crack down by the inland revenue, HSE and employers has made significant cultural changes to the accident status over the last 20 years. What other things could be done? Could the 400k per annum subsidy that Seafish currently provide be better utilised for and indeed is it appropriate/feasible that levy should be used for supporting any these initiatives? Robust collective action to non compliance to safety (prosecution, suspension of membership, whistleblowing, insurance information, grant refusal, agency action, high risk audit status, licence review, quota review, days at sea review) VMS down to 6M Page 9 of 13

10 Vessel movement and activity reporting, leaving and entry to port, web based Improved crew database based on active vessel information (web portal) Improved statistics and data collection (non UK and EU nationals Mandatory safety refresher training Annual audits on vessel safety (on a cost recovery basis) Risk assessment reviews and training Personal locator beacons Schemes that could reduce insurance premiums Independent audit (eg RFS) Banning of single handed operations on vessels above a certain size Mandatory PFD and training for use Upskilling of workforce through apprenticeship promotion Professional improvement through STCW equivalence Target of 30%(?) of workforce to be deck officer or engineer trained Developing training materials that could be used internationally Developing safety materials that could be used internationally Codes of Practice Page 10 of 13

11 Other information Fishermen Numbers (Marine Management Organisation, 2012) Year Regular Part Time Reg + PT UK UK UK Fishermen Fishermen Fishermen ,436 3,453 17, ,864 3,032 16, ,399 3,250 15, ,145 2,813 14, ,442 2,763 14, ,204 2,918 13, ,023 2,430 13, ,492 2,339 12, ,358 2,576 12, ,305 2,566 12, ,028 2,586 12, ,129 2,083 12, ,172 2,531 12, ,040 2,365 12,405 Recommendations NIOSH (NIOSH 2011) NIOSH Recommendations to Fishermen NIOSH recommends that all fishermen should: Take a marine safety class at least once every 5 years Find a comfortable PFD and wear it on deck at all times Do monthly drills including abandon ship, flooding, fire, and man overboard Heed weather forecasts and avoid fishing in severe sea conditions Maintain watertight integrity by inspecting and monitoring the hull of the vessel, ensuring that watertight doors and hatches are sealed, and inspecting and testing high water alarms regularly Utilize a man overboard alarm system Test immersion suits for leaks if operating in cold water NIOSH recommends that all vessel owners/operators should: Create a PFD policy for the crew while working on deck Conduct monthly drills including abandon ship, flooding, fire, and man overboard Install a man overboard alarm system, and man overboard retrieval devices Page 11 of 13

12 Install emergency stop (e-stop) devices on hydraulic deck machinery to prevent entanglement injuries Ensure all crew members have completed marine safety training in the past 5 years Other extracts from web sites around the world: A three-year federal investigation has concluded that deaths in Canada's fishing industry have remained depressingly high, and stable, with an average of one mariner a month being killed at sea. The Transportation Safety Board launched the investigation in 2009 to explore why there have consistently been about 13 fishing industry deaths a year, every year, a number that has not dropped despite different initiatives and safety programs. Life-jackets are not being worn by many fishermen, despite numerous safety campaigns, a TSB report has found. CBC The report cites plenty of problems a lagging "safety culture" among them, including inadequate training and oversight and found there is no simple solution for solving safety problems in an industry the TSB admits is complex and full of variables. Instead, it highlighted 10 separate areas of concern, ranging from fatigue to a poor understanding of vessel stability, and a lack of understanding of safety issues among those who set fisheries policy, which may inadvertently put fishermen's lives at risk. Solving the problems one at a time simply won't work, said the report, which was released Thursday. The report says even though 25 per cent of all fishing-related deaths involve mariners falling overboard, many fishermen refuse to wear life-jackets or other personal flotation devices (PFD). "Fishermen also may not wear a PFD because many have accepted the risk, it interferes with their movement while working on deck, and there is a fear of entanglement. "Nationally, despite [significant design] improvements, efforts to inform fishermen of their benefits through product information and safety training have not resulted in universal acceptance of wearing PFDs," the report states. References HSE. Economic Anyalysis Unit Appriasal Values. HSE, Intenational Labour Organisation. Report on Safety and Health in the Fishing Industry Marine Accident Investigation Board. Annual Report Page 12 of 13

13 Marine Management Organisation, NIOSH. Commercial Fishing Safety. National Institute for Occupational Safety and Health (USA), UK National Statitics. Seafarer Statistics Page 13 of 13

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