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APPENDIX E Central Features of a Complete Pilotage System The committee's examination of a wide range of pilotage systems in the United States, Canada, and Europe disclosed a number of features that are com- mon to most pilotage models, although their actual form varies significantly. The composite model discussed in this appendix includes features that are essential to building, maintaining, and administering a complete pilotage system. Although these features would constitute a complete pilotage system, all components would not necessarily have to be carried out by a single organization. Some compo- nents may be most appropriately handled by a licensing authority, others by a pilot association or a third party; for some components, joint administration may be appropriate. Some components are interrelated, but all are discussed separate- ly for purposes of clarity. The central features provide a conceptual framework that can be used by pilotage administrators and pilot associations as points for comparison in assess- ing the completeness and, subjectively, the adequacy of their pilotage programs. Although this discussion is directed toward pilot systems, the basic features could also be used by shipping companies for the same purpose. PROFESSIONAL DEVELOPMENT The primary feature of pilotage is professional competence. All other fea- tures provide support to ensure the efficacy of pilot services. Recruitment The objective of recruitment procedures is to provide the most suitable and, 397

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398 APPENDIX E if prior maritime experience is required by pilotage authorities or associations, the most qualified applicants for training. The goal is to ensure that the individu- als selected can develop the professional competence essential to effective pilot- ing and that they have personal and professional integrity to justify the high level of trust and responsibility that others place on them. Considerable care is essen- tial in choosing pilot applicants, because they will be expected to work indepen- dently, that is, without assistance from their colleagues while piloting, and be- cause of the considerable personal and organizational investment of time and resources required for qualification in the profession. An effective recruitment process needs to consider whether an individual has the physical condition, demonstrated mental abilities, interpersonal capabili- ties, visual-motor and practical skills (or potential), and maturity, as well as whether the individual is professionally suitable. These factors need to be as- sessed relative to the expertise that is or can be expected to be required. For example, the rapid move toward computer-based systems (such as integrated bridges with pilot expert systems) requires computer literacy with regard to the use and application of these systems, whether or not the pilot actually operates these systems or relies on the bridge team to operate them. Additionally, as more and more mariners enter the profession from nonmaritime countries or nontradi- tional sources, as vessel crew size is reduced, and as more-intense competition for cargoes is generated among world shipowners, more responsibility may be placed on marine pilots for the safety of vessel operation in port regions. Emerg- ing electronic navigation systems for real-time determination of positions, tidal stages, currents, wind velocity and direction, and visibility may only be available on board some vessels. To provide this capability on all vessels, the pilot may have to be equipped with and operate portable computer-based equipment. There- fore, computer literacy or the potential to acquire computer literacy of the form needed is a new, nontraditional job requirement, which needs to be balanced with other screening factors. Other factors in recruitment are the resources that will be committed to professional development. Will pilot skills be built from a basis of little or no maritime knowledge, or will development be subsidized by drawing on individu- als with prior maritime experience and licenses? If extensive vessel maneuvering is associated with a route, as opposed to long transits with few course changes, individuals with extensive ship or boathandling skills might be desirable. Simi- larly, if tugs with tows are the primary clients, individuals with towing industry experience may be preferred. Thus, the tasks the pilot is expected to accomplish, the relative importance assigned to each screening factor, and the resources avail- able for training determine the most appropriate recruitment sources. Experience Experience to become a competent pilot consists primarily of two elements.

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CENTRAL FEATURES OFA COMPLETE PILOTAGE SYSTEM 399 The first is basic maritime knowledge. (Some of the components are discussed in the next section under "knowledge.") The second element is practical experi ence. Basic maritime knowledge is gained either through: service aboard seagoing vessels or harbor craft such as tugboats or ser- vice craft (such as pilot boats); or attendance at one of the state maritime colleges or the federal maritime academy, followed by time at sea as a licensed deck officer, as an apprentice in a rigorous marine pilot development program, or both. Basic maritime knowledge can also be obtained at one of the sea service acade- mies, followed by service aboard Navy or Coast Guard vessels. Navy and Coast Guard sea service may provide, for some individuals, sufficient maritime knowl- edge to support a transition to commercial pilot service. Practical experience leading to development of professional competency is usually gained during a pilot training program, as there is little opportunity for seagoing officers to handle their own ships in a piloting situation. An exception is experience as a tugboat master in the piloting waters that will be home grounds for the pilot. Tugboat masters routinely maneuver barges, provide assistance to ships in docking evolutions, or both. Another exception is Navy and Coast Guard sea service. Piloting and shiphandling is usually performed by ship's officers, even in those cases where a pilot is taken. Thus, there may be opportunities for some individuals to acquire expert shiphandling skills that could be adapted to commercial service through a pilot apprenticeship program. In a complete pilot model, individuals selected for training as pilots would have attained at least a master's license (ship or tug, depending on pilotage needs), with several years experience as master. That experience could be aboard either large vessels in domestic or foreign trade or aboard towing vessels either engaged in harbor or offshore towing or in ship assist work. If an apprenticeship program is utilized for producing pilots, then, ideally, the individual should have at least some advanced nautical education, preferably at a maritime college or academy. Knowledge The knowledge required to become a competent pilot consists of both the basic maritime knowledge that an individual gains from seagoing or towboat experience and the additional specific knowledge and experience required to become a competent pilot. The latter includes local expert knowledge about the pilot area and shiphandling theory. If the individual selected to become a pilot does not have knowledge of ship bridge organization and procedures, then that knowledge must be gained through a training program that emphasizes that aspect. Individuals with experience on

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400 APPENDIX E small vessels such as tugboats are usually somewhat deficient in this aspect of pilot knowledge when they enter the profession. On the other hand, individuals from the towing industry typically enter the pilot profession with greater-than- average practical experience in handling vessels in harbors. Expert local knowledge of the pilot routes served is fundamental (IMO, 1981~. Essential elements of information include: . area geography; port and waterway configuration; hydrography (channel depths and widths, bottom configurations); hydrology and hydraulics; tides; currents; winds and weather; aids to navigation (including not only the aids themselves but also how to interact with them and the information they convey effectively); bottom composition (such as rock, mud, sand, or combination); marine facilities used by marine traffic; other traffic and operations (such as commercial fishing vessels, recre- ational boating, dredging, marine regattas); air draft (for bridges and overhead wires); communications; marine traffic regulation (such as vessel traffic services); local and seasonal traffic patterns and densities; ship maneuvering behavior for all vessels to be piloted, including hydro- dynamic interactions with respect to other vessels, facilities, and channel bathym- etry; advantages and limitations of various types of main propulsion and auxil ary maneuvering macnlnery; shiphandling (for piloting, anchoring, docking, and undocking, maneu- vering with and without the aid of tugs, and emergency situations); tug control (for maneuvering assistance); use of ground tackle to aid maneuvering; navigation systems (traditional and electronic); radar systems (and where of utility, automatic radar plotting aids WARPATH; marine and environmental-safety requirements; and other information of local significance. Additionally, the pilot must have knowledge of both federal and state laws and regulations pertaining to the profession. These consist not only of those directly related to the profession but also those that can affect the pilot's actions, such as water, air, and noise pollution laws; quarantine regulations; federal regulations relating to vessels tests, manning, and outfitting; ship bridge visibility regula

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM 401 lions; and operational regulations or special orders (such as regulated navigation areas, Coast Guard Captain of the Port Orders, and state-imposed tug escort requirements for tankers). Skills The practical skills needed to become a competent pilot are those primarily related to shiphandling in general, shiphandling in narrow channels and shallow waters, and use of bridge resources (bridge team members J and navigation equip- ment in support of piloting tasks. Such skills must be attained through a profes- sional development program. Both theoretical knowledge and practical knowl- edge must be acquired for a full range of ship types in order to apply practical skills effectively. Thus, the development program or training curriculum must integrate the two so that one reinforces the other. Theoretical knowledge and practical knowledge about how to apply theory can be developed in several ways. Virtually every marine pilot association de- velops practical skills through a rigorous program of on-thejob training. Pilot candidates accompany experienced pilots as they perform their duties to learn the route, bridge procedures, vessel behavior, decision making under various operating conditions, and other insights that are applied in developing and apply- ing practical skills. When considered ready by senior pilots, the apprentice han- dles vessels under the tutelage of suitable experienced pilots. Some time is re- quired to develop the required skill level up to 3 to 4 years if the pilotage grounds are lengthy and complex. The time required also depends to some de- gree on the apprentice's prior maritime experience. Additionally, skills must be developed in maneuvering and using ship-assist tugboats for docking and un- docking evolutions, even if this is not a service normally provided by the pilot. A pilot may be called upon to use tug assistance during an emergency and must be prepared to do so. Generally, ship masters and other senior licensed deck department officers have limited opportunity to control ship-assist tugs or to develop, from a tug operators perspective, insight on the dangers involved in working alongside oceangoing ships. Therefore, an ideal pilot model would have apprentices spend time aboard various tugboats while they are assisting ships, observe these ma- neuvers from the ship, and become familiar with and practice tugboat control under the tutelage of an experienced pilot. Similarly, tug operators have little to no opportunity to develop insight on the bridge organization of an oceangoing vessel and on how to interact with bridge team members and the functions they perform. Thus, the pilot model needs to accommodate this gap in knowledge when tug operators enter the marine pilot profession. Practical skills also include the techniques required to board and disembark from vessels using pilot ladders in various weather, sea, and visibility condi- tions. While pilotage grounds or areas vary greatly, one common thread is that

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402 APPENDIX E the pilot always must be able to skillfully board a vessel and to debark the vessel on completion of piloting duties. This skill is attained by accompanying experi- enced pilots on the job and then by maneuvering vessels under tutelage to create a favorable lee for debarking. While this particular skill may seem minor, to the pilot it is probably the most dangerous part of piloting, as it relates to individual safety and health and to the safety of the pilot vessel that comes alongside. Sometimes the environmental conditions are so bad that disembarking an out- bound vessel would be life-threatening to the pilot and pilot-boat operators. In these cases, pilots must stay aboard to the ship's next port of call. Skill must also be developed in using various navigation equipment on the bridge. These equipment includes radar, ARPA, automatic steering systems, thruster controls, bridge-control devices for propulsion, radios, internal commu- nications systems, depth-finding equipment, Doppler speed readouts, and emerg- ing electronic equipment such as electronic charting systems. The pilot must also be able to operate basic equipment such as radar. It is impractical for the pilot to be familiar with all equipment configurations and features, however. For exam- ple, there are just too many variations in ARPA systems for the pilot to become proficient in the operation of each. Instead, the pilot must understand the capa- bilities of the equipment and whether it is being correctly used by the bridge team to support the pilot as he or she provides expert direction and control of the ship's movements. Another way to develop practical knowledge and skills is through use of computer-based or manned-model marine simulations. Because these simulation programs usually last only about a week, there is little time to develop practical skills as might be acquired through more frequent use of this training medium, as in aviation (see Guest, 1992a). Preliminary research literature that suggests but does not fully prove the value of simulation for building skills that transfer effectively to actual operations (Haapio, 1992; Hammell et al., 1985; Kayten et al., 1982; Miller et al., 1985; Mutter et al., 1983; O'Hara and Saxe, 1985; Schill- ing et al., 1985; Webster and Young, 1993~. That pilots can benefit from simula- tion was demonstrated by Hammell et al. (19859. There is a growing belief in the maritime community that simulations can at least provide familiarity and basic and refresher training with the tools of the trade that can then be turned into practical skills through on-thejob experience. For the most part, simulation is not used as an entry-level training medium for marine pilots, although several U.S. marine pilot groups have begun to use sim- ulations as part of their apprentice programs. Such uses have included prepara- tion of pilot apprentices for emergency shiphandling decision making. But, ma- rine pilot associations using simulations have done so primarily for continuing professional development. Ten possible pilot-training modules for computer- based simulations were identified through research conducted by the U.S. Mari- time Administration (Box E-13. While substantial progress has been made in computer-based simulations, not all pilots are convinced of its value in develop

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM 403 ing practical skills for their work. They question the accuracy of its replication of actual conditions, either representative vessel types, sizes, and maneuvering be- havior or operating conditions in narrow channels, shallow water, and river envi ronments. Crisis management experiences have shown that learning how to respond to a crisis during the crisis is not only less than ideal, it also greatly increases the probability that decision making will be flawed. A licensed marine pilot is ex- pected to have, for example, all the shiphandling skills needed to respond to a breakdown by another vessel that blocks a channel. However, a pilot's normal experience would not necessarily provide the mental preparation necessary for time-critical decision making under stress (see Gates, 1989; Huffner, 1976; NTSB, 1989a, 1991a; Plummer, 1966~. Similarly, taking a ship with uncertain handling characteristics in shallow water into a confined channel, or meeting another vessel there for the first time, would severely challenge even the most seasoned mariner (Plummer, 1966~. Marine simulation is one means to practice emergency procedures so that they become instinctive and to provide a sense of the time frame in which decisions need to be made in order to be effective. Marine simulation could also be used to determine whether certain interactions should be attempted such as meeting another ship in a narrow channel (NRC, 1992a), and also to improve the skills necessary for successful maneuvering. Each use could reduce the potential for marine casualties. Continuing Professional Development Although marine pilots in the United States generally form close-knit pro- fessional associations (which are, in effect, state-regulated or locally regulated, limited-access businesses), their profession is nevertheless characterized by in- dependent service. Rotational assignments are used to ensure fairness in assign

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404 APPENDIX E ing piloting jobs and to provide adequate periods of rest. Rotations generally expose pilots to changes in marine transportation, including new propulsion and steering systems, navigational aids, electronic navigation systems, and so forth. However, rotational assignments and shipping trends in any particular pilot ser- vice area do not by themselves provide complete certainty that pilots will keep pace with all changes in operating practices, technology, rules, regulations, and official policies. A complete pilot model would therefore include means to en- sure that a marine pilot's knowledge and skills remain current with develop- ments in the shipping and towing industries so that their service accommodates marine transportation needs. Options for continuing professional development include organized meet- ings to provide updates on changes in transportation and marine safety regula- tions and debriefings on lessons learned from marine casualties; other informa- tion transfer opportunities; skills enhancement and development opportunities; refresher training; and instruction in emergency procedures. Some options are suited to the classroom; others may be better suited to field work or marine simulation. No one approach provides the full range of professional develop- ment. Simulation facilities provide some capability to refine or refresh some shiphandling skills; when simulation is coupled with classroom training, theoret- ical knowledge can be increased or refreshed as well. Manned-model simulations can be used in real environmental conditions to refresh shiphandling skills for particular types and loading of vessels in generic situations. The knowledge and skills are transferable to practical situations by interpolation. This form of simulation can also be used to introduce pilots to types and sizes of vessels not normally piloted, again, under real environmental conditions. Effects of scaling factors on transfer of training, and value added to piloting skills, are not certain. However, many pilots who have participated in manned-model simulations report that the experience provided insight or re- freshed awareness of shiphandling theory and practice. It also introduced them to techniques that were unfamiliar or with which they had limited experience. Computer-based full-mission simulations can be used in continuing profes- sional development programs for the training areas indicated in Box E-1. How- ever, the limitations discussed earlier apply. There is also the question of the relative value of manned-model simulations versus that of computer-based simu- lations for development of shiphandling skills. Manned-model training is limited to the physical hull forms that are available, the physical limitations of the lake or basin used for the training, and the environmental conditions at the time (the facilities are outside). Manned-models do, however, provide a reasonably realis- tic anchoring capability and also allows the operator to sense and experience the forces at work on the hull and how the vessel reacts to them. Computer-based simulations are limited by such factors as the mathematical ship models and the vessel hydrodynamic, port, and environmental data available to drive the simula- tion. However, as these are software and data availability rather than hardware

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM 405 factors, there is somewhat more flexibility in developing port- and vessel-specif- ic simulations when using computers. Additionally, it is possible to simulate tug- assist operations at some simulator facilities. But, resources to develop new port- specific simulations are a limiting factor. The cost of the training also can be a limiting factor. Computer-based simulations are also limited in their capability to provide realistic anchoring scenarios. Development and refinement of shiphandling skills for licensed pilots is already accomplished to some degree using manned-model simulations, and, depending upon the fidelity required, computer-based simulations. Other poten- tial uses for part- or full-mission computer-based simulations include route fa- miliarization, development of pilot candidate and ship's officer shiphandling skills, bridge team training, and advance preparation for handling vessels or unfamiliar classes of vessels. Personal computer (PC)-based simulations for marine training are an inno- vation increasingly considered by the Coast Guard for possible use in marine licensing (ECO, 1987; USCG, 1993f). However, the value of PC-based training for selected piloting tasks, route familiarization, and for practice or mental re- hearsal has not been established either through field applications or experimental research. The state of practice of PC-based simulations is rapidly evolving as manufacturers search for training and real-life applications. Simulations have been incorporated into PC-based interactive multimedia instructional presenta- tions under instructor guidance, principally by the U.S. Navy, and into rules-of- the-road applied training (McCarthy, 1993; USN, 1992~. PC-based training sys- tems for navigation, radar plotting, and communications tasks are available and in use by some training facilities. PC-based maneuvering simulations have also been developed and have been advertised as decision support aids for real-life operations. Although the computational power of current generation microcom- puters permits the use of sophisticated mathematical models for ship behavior and high definition graphics, their ability to produce accurate vessel trajectories and induce real-to-life human responses is constrained by the limitations that also affect full-mission ship-bridge simulations. Additionally, PC-based simula- tions lack bridge instrumentation and do not reproduce the bridge operating en- vironment, including interactions among bridge personnel. PC-based training systems potentially might be useful in continuing training and evaluation as the application of this technology to marine training and licensing matures. A complete pilot model would include pilot participation in a program of continuing professional development combining the various needs and approach- es just discussed. Such programs could either be required by licensing authori- ties or implemented voluntarily by pilot organizations as a professional service to their members (a formal requirement may be necessary in some cases to motivate and ensure organizational, industry, and financial support). Regardless of how it is implemented, the program should be routinely scheduled at a fre- quency sufficient to ensure that all pilots are kept abreast of technical, operation

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406 APPENDIX E al, procedural, and legal developments, and that practical piloting skills remain at or above acceptable levels. Proficiency Validation Means are needed to determine or validate the professional competence or proficiency of: . pilot apprentices seeking licensure; candidates for pilot route extensions; . pilot preparation for routes infrequently traveled; pilot upgrading to vessels of different types or sizes; eels; pilot preparation for new categories of vessels or newly constructed chan pilot resumption of service after a an extended period out of service; and determination of pilot fitness to continue service. This list demonstrates that the need for proficiency validation extends beyond pilot apprentices or junior pilots moving up to senior pilot status (that is, full branch pilot or equivalent). There is a need to ensure the skills of senior pilots as well. The methods available for proficiency validation include: subjective written examinations; tutelage (including observation and evaluation'; check rides (under observation by a pilot assessor or examiner qualified and approved or certified for this service); in-service evaluations (by a qualified pilot examiner); and marine simulation. Not all individuals may be able to convey their practical skills well using written responses. Some indication of proficiency is possible through "expert account- ing," that is, oral responses to various scenarios by the individual being assessed. The technique has limitations. Additionally, deficiencies in practical skills are difficult to detect unless actually observed. The scope of validation substantially exceeds common practice, except for apprentice programs and those pilot systems that embrace the concept of pro- gressive advancement. In the latter case, progression typically involves advance- ment to ever-larger vessels (length and tonnage) after route experience and pilot- ing and shiphandling skills are reinforced through experience on small vessels. Few pilotage systems have check-ride programs, although this is common prac- tice for Panama Canal pilots during their first two years of service. Verification of proficiency in handling vessels of each size is not common practice. However, proficiency can only be determined by evaluating the actual piloting and han- dling of each size or category of vessel, or perhaps through observation of pilot

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM 407 performance during a marine simulation. Neither approach is common practice in U.S. pilotage systems, although a few U.S. and foreign associations are ad- vancing in this area. A complete pilotage model would provide means to ensure the professional competence of pilots at the highest level served and to maintain the level of competence that is necessary. Recency Recency of service on pilotage routes is imperative to ensure that the pilot keeps abreast of changes that have occurred along the route; and skills have not become rusty through either long periods between active service or limited opportunity to practice skills on certain types, sizes of ships, or routes. How frequently a pilot should provide service to particular vessels and routes varies according to a wide range of operating factors associated with each port (see Chapter 4~. Pilots need to experience the full range of operating conditions, including seasonal variations, for the vessels to be piloted, either as an observer or as a pilot. In the committee's opinion, this experience is needed on an annual basis. More frequent piloting experience may be necessary in some operating environments, because changes may occur more frequently than annually. For example, visual cues can change quickly in areas undergoing intense develop- ment. In the absence of fundamental research to guide such determinations, local expertise would be required to establish reasonable recency requirements. ACCOUNTABILITY Marine pilots have responsibilities to the piloting profession (to maintain its integrity and credibility), the ship (including the master, crew, owners, and cargo owners), colleagues (both as practitioners and as members of a pilot association), port authorities (who depend on the efficacy of the pilot's service), governing authorities, and the general public (for public and environmental safety). Given the weight and importance of these responsibilities, pilots are held accountable for the services they provide in order to maintain the credibility of the pilotage system itself. Certification/Recertification Certification is a voluntary act by an individual and a certifying entity that, in some organized fashion, measures an individual's qualifications to perform a specialized function. No authority or privilege is conveyed, although custom or market forces may require or necessitate that an individual obtain certification. Accreditation is similar to certification, except the term is applied to institutions

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408 APPENDIX E and programs and not individuals (Anderson, 19921. Certification could be ap- plied within pilotage systems as a means to demonstrate continuing development short of actual licensing requirements. For example, a pilot could seek certifica- tion for different types of navigation equipment. Although certification programs are traditionally voluntary, certification criteria that establish professional stan- dards are sometimes institutionalized into regulations or licensing programs to make the application of such standards universal (see Chapter 3~. Certification requires individuals or organizations qualified to conduct the certification. Many marine pilot associations certify their own pilot apprentices using internal professional development programs. Some state pilot association apprentice programs are officially sanctioned by their governing authorities, but few are formally accredited. Ten pilot-apprentice development programs are, however, approved by the Coast Guard as equivalent to actual sea service in building the service and route experience required to obtain original Federal First Class Pilot's Licenses or Endorsements. These approvals are subjective and based on recommendations of the pilot associations. Because certification is not widely used in developing professional competence for other aspects of naviga- tion and piloting, implementing certification within pilotage systems would also require the establishment of qualified certification authorities. Licensing Licensing is an authorization in the form of a license granted by a govern- ment or an entity to perform or provide a function or service. Licensing is rooted in a government's police powers and is traditionally applied for the purpose of protecting public health, safety, and welfare. Licensing conveys a legal authority to engage in a function or service (Anderson, 1992~. In pilotage, licensing is also applied to protect property and the environment. Inherent in marine licensing is the concept that an individual is professionally competent to perform under the license granted and is accountable to the licensing (that is, governing) authority for competent performance. A complete licensing program would include prerequisites in terms of ser- vice and training as well as theoretical and practical examinations and chart sketches to demonstrate route knowledge. At present, only theoretical examina- tions are conducted in the federal and some state pilotage systems. No formal practical examinations are given to determine proficiency in piloting and ship- handling. However, in many state pilotage systems, an individual may not sit for a written examination until pilots within the association are satisfied that the apprentice has the necessary practical skills. This approach is an alternative to a formal test of proficiency to the degree that proficiency validation by pilot asso- ciations (or third parties) is credible and acceptable to licensing authorities.

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM Exemptions 409 Traditionally and in theory, masters are considered the most experienced shiphandlers for their vessels because of extensive familiarity with them under a wide variety of operating conditions. Assuming that the master (or senior mate) could acquire sufficient expert knowledge of a pilotage route, the master or mate could effectively pilot his or her vessel on it. Exemption programs such as those found in the Netherlands and the United Kingdom recognize this, often as an economic service to port-state shipping companies, by authorizing the master or mate, after suitable local qualification, to serve as the vessel's pilot. In such cases, a certificate, license, or license endorsement is issued to formalize this permission. However, modern manning and operating practices and port-state operating requirements may or may not result in the master (or a senior mate) acquiring a high level of shiphandling skills or pilotage route knowledge. In Europe, where exemptions are generally an option for masters and senior mates of member states of the European Community, these exemptions are limit- ed to a specific vessel (or sister vessel' and a specific route. Qualification re- quirements usually include a minimum number of trips, very recent experience on the route, a written examination, and a field test. Because port states or feder- ations of mostly port states (such as the European Community) do not control the qualification of masters and bridge teams of foreign-flag ships, they do not au- thorize the masters or mates of such ships to pilot their vessels where pilotage is required. Professional Oversight Because pilots provide their service independent of other pilots, their perfor- mance is not observed except by personnel aboard the ship piloted, and, to a substantially lesser degree, by other pilots aboard other vessels encountered dur- ing pilotage jobs. To ensure that pilot performance meets at least minimum standards and to provide a means to detect problems for which corrective action can be taken, professional oversight is needed within the pilotage model. One option is maintenance and analysis of complaint or accident records to identify individuals whose names appear more frequently than is acceptable or who have one or several reports that merit specific attention. Another option is field checks by appropriately qualified pilot examiners. Because of the need to maintain in- tegrity and credibility of oversight, and to preclude difficulties in professional relationships between individual pilots, formal oversight may be best accom- plished by governing authorities or suitable third parties. However, pilot associa- tions and their members have a moral and perhaps a legal responsibility to ensure that the safety performance of members meets acceptable standards. Pro- fessional peer pressure to perform pilotage services at the optimum level of safety is a traditional and integral part of established associations. Pilots also

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410 APPENDIX E could provide, for example, some form of professional screening, perhaps as a component of their continuing professional development program, to assist their colleagues whose performance may have deteriorated (a condition that could go undetected without occasional performance assessment) but could be restored to acceptable levels. Incident/Accident Investigation Credibility of pilotage depends in part on investigating incidents and acci- dents to determine their cause, so there is a factual basis for corrective action. Such action may involve either pilot performance or other components of the marine navigation and piloting system that may have been causal factors. A complete pilotage model would, therefore, specify means for collection of inci- dent and accident data, including testimony. It would also specify provisions for analysis and corrective action based on the results. There is a distinction between incidents and accidents, although both should be reported and investigated to determine what corrective action might be appro- priate. Incidents include numerous events, often minor in scope, that result in no adverse consequences, either to the vessel or port infrastructure in terms of phys- ical damage or to personnel in terms of injuries and non-life-threatening events. Incidents, as used here, also include events with damage or which cause effects that are below thresholds recorded as marine accidents (referred to as marine casualties under Coast Guard reporting requirements). Incidents include a line parting during docking or undocking without injury, loss of propulsion or steer- ing without a grounding or collision, radical maneuvers to avoid recreational craft, and wake damage. Some incidents are so minor as not to merit further attention. Other events (such as loss of propulsion), individually or in the aggre- gate, may provide valuable insight on the performance of pilots, vessels, and the marine traffic safety system (Ives et al., 1992; Young, 19921. A complete model would provide means for reporting and analyzing incidents, so that incident- specific needs for improvements or corrective action can be identified. Accidents are easier to define than incidents. They involve certain types of events, such as collisions and groundings. Certain events such as groundings may need to be reported regardless of whether damage occurs, because they can provide strong indications of piloting or vessel system problems. Other types of accidents may be governed by reporting thresholds, depending upon the safety objectives being served. Effective investigation of marine accidents requires an in-depth understanding of vessel systems, human systems, waterways manage- ment, and marine pilotage, so that both proximate and underlying causal factors can be determined. Proximate causes of accidents can generally be determined through analysis of the facts by knowledgeable individuals, and through expert forensic analysis (Gates, 19891. However, underlying causal factors are more difficult to ascertain, because (1) accident data typically emphasize vessel rather

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM 411 than human systems, (2) the data are often incomplete or subjective, and (3) investigators are typically not prepared to conduct expert in-depth analysis. A complete pilotage model would provide for multidisciplinary assessment when the nature of an accident indicates the need for in-depth analysis. Such an assess- ment could be conducted by a specially constituted board of experts, a third party such as a marine surveyor, appropriately trained investigators from pilot associations or governing authorities, or some combination of these. Safety Performance Monitoring Related to professional oversight and incident/accident investigation is the monitoring of safety performance of pilots, vessels, and the marine traffic safety system in the pilotage area. Performance problems may be too subtle; intermit- tent; or, in the case of individuals, masked, and thus not always detectable through investigations of specific events or through periodic personal observa- tion or evaluation, either in the field or through simulation. For such cases, a dedicated program of long-term performance monitoring is necessary. Such pro- grams could be accomplished through collection and analysis of performance data, with incident and accident reports forming a principal resource. Compila- tion of complaints received about individual or vessel performance can also provide indicators of problems needing further assessment. To assist in this pro- cess, key data fields could be entered into an automated data base, which could then be consulted for frequencies and trends (see Young, 1992~. Discipline Discipline takes two basic forms professional discipline and official disci- pline after an incident or accident. Professional discipline is developed through the professioMal development features of the pilotage model, professional peer pressure, and professional oversight. A complete pilotage model, by establishing effective means to validate and oversee pilot performance as described earlier, provides the means for early detection of many performance problems before they become critical and contribute to a marine accident. Considering that pilot expertise takes years to develop, the pilot model would, as an objective, seek to correct deficiencies, rather than remove the individual, in order to preserve and enhance the pilot as a valuable asset in the local marine traffic safety system. For example, remedial or refresher training, or additional experience on smaller ves- sels, could be used to correct weaknesses in professional skills. The pilot model would establish a similar approach using similar techniques for rehabilitation of pilots involved in marine accidents, insofar as this is appropriate to the circum- stances. A pilot who has been involved in an accident (to the degree that lessons are learned and performance deficiencies are constructively corrected) may be- come more valuable as a special asset to the local system.

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412 APPENDIX E A complete model would also provide for punitive action as a measure of last resort if rehabilitation were not feasible or if incompetence, willful negli- gence, or substance abuse were involved. In these cases and in addition to possi- ble corrective actions, the pilotage model would provide options for fines, sus- pensions, and license revocations. Given that discipline can be a career-ending event, the pilotage model would also provide for hearings, review, and appeals processes where disciplinary proceedings could result in corrective or punitive action. In conjunction with discipline, a complete pilotage model would address liability. Because of the nature of their work, marine pilots are continuously exposed to considerable operational and economic risk. Liability insurance for most pilots is either not available or not affordable. To the extent that the integri- ty of pilotage might be jeopardized by pilot liability for marine accidents, the pilotage model would need to consider limits on liability at a level agreeable to the marine pilots, shipping interests, and governing authorities in the public interest. Local Involvement Pilotage is area-specific. As such, pilotage requires not only that the pilot be an area expert but also that refinement of the pilotage model to accommodate area-specific operational and environmental factors be developed and adminis- tered by individuals knowledgeable of them. For practical purposes, this task requires the participation of individuals from the area served. Local participation is also desirable in order to build pilotage system credibility with the local public. Audits Pilotage is in most cases a government-sanctioned, limited-entry business designed to maintain marine pilots in numbers that are in balance with time- consuming professional-development requirements and at compensation levels appropriate to the service provided. Because of its relatively closed nature, pilot- age draws considerable controversy over the efficacy of pilot recruitment, per- formance, administration, and rates. To establish the efficacy and credibility of the pilotage system, a complete pilotage model would provide for independent audits of system features to ensure that integrity, effectiveness, and efficiency are maintained. STANDARDS Administrative Standards The administrative support of pilotage systems needs to be as credible as pilot services themselves to maintain the integrity and credibility of the entire

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM 413 system. To sustain its credibility, the pilotage model would include provisions for standard procedures, administration, billing, logistic support, disciplinary pro- ceedings, financial accountability, record keeping of safety data, and other infor- mation. Professional Standards The true meaning of professional standards in piloting is difficult to quanti- fy; most standards are very subjective and highly variable among pilot areas and systems. Where standards involve numbers, they usually refer to round trips, years of service, and so forth. Generic and port-specific standards that could be used to gauge professional performance are not available. A complete pilotage model would include standards to guide professional development and perfor- mance. In the absence of fundamental research to guide development of stan- dards, such standards would need to be developed by subject-matter experts. However, to aid in the acceptance of standards by all interested parties, the standards could be developed by a multidisciplinary team representing the view- points and expertise of the interested and affected parties. Physical Condition Standards Piloting demands excellent physical conditioning, to assure that the pilot not only is physically able to provide service but also can board and debark the vessel to which assigned. Physical standards need to be established by pilotage authorities. Each pilot should have a periodic physical examination to determine suitability for continuing work. In determining physical standards, pilotage au- thorities could consider the physical-examination guide developed in 1985 by the Seafarers Health Improvement Program Committee for merchant seamen. While there are no national physical standards for marine pilots, this program is available for use by pilotage authorities. Physical suitability should be deter- mined prior to granting an initial license, at the time of license renewal, or more frequently if licenses are renewed at intervals of more than two years. Also needed are provisions for physical examinations following a serious injury or illness, along with provisions for examinations if evidence shows that the physi- cal condition of a pilot has deteriorated. ORGANIZATION Organizational Structure Pilotage associations and boards (or commissions) need to be organized for sound decision making and administration. Various organizational structures have been used for pilot organizations some are organized as professional as

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414 APPENDIX E sociations for administration; some are corporations; some are companies with pilots as stockholders or employees; and in a few cases, some are divisions of government organizations. All forms are in existence and functioning, nationally and internationally. Each form at one time or another has also experienced fail- ure in maintaining the efficiency of pilotage services. No one form stands out as a perfect model. Whatever form is chosen needs to be responsive to both safety and economic need within the overall system. Pilot boards generally consist of appointed or elected members who serve for a set term. Membership composition varies greatly, from all pilots to no pilots. Sometimes shipping interests and the public are represented and some- times not. Because multiple interests need to be served, each viewpoint must be represented in decision making and administration. This balance can be facilitat- ed by including marine pilots and shipping, port authority, public safety, and public interests in board membership. Whatever composition is chosen must be responsive to the broad range of marine safety interests for the waters served, including operational, economic, and environmental protection factors. The economic factor of pilotage rates has indirect implications for safety. How rates should be administered and by whom, and what rates are reasonable, are very controversial issues to which the pilotage model needs to be sensitive. Rates established by law are inflexible to changing conditions, require legisla- tures to act, and immediately inject rate negotiations into the political process. On the other hand, legislative oversight of rates and rate-setting procedures pro- vides protection from various anti-trust laws that might otherwise be imposed for closed-access businesses. Regulatory rate-setting provides somewhat more flex- ibility in addressing changes in economic conditions, but it may require consid- erable processing time if public hearings are involved. Hearing processes can take on the aura of litigation, and hearings may or may not be heard by an officer or judge competent in marine affairs. Rates set by pilotage boards place these boards in the position of having to make tradeoffs between economics and safety, and between the interests of ship- ping companies and the pilots under their jurisdiction. Negotiated rates may or may not provide for adequate pilot compensation, depending on the economic power of the shipping companies relative to the ports to which they can call. Whatever rate-setting structure is chosen needs to ensure adequate compensation for the expert service that is provided sufficient resources to maintain an ade- quate pilot pool, and infrastructure requirements for effective and efficient ser- vice. Rate setting as a function separate from pilotage administration merits consideration in pilotage systems. Infrastructure Pilotage services need to be available on a 24-hour basis in most pilot ser- vice areas and under virtually all environmental conditions. To provide universal

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CENTRAL FEATURES OF A COMPLETE PILOTAGE SYSTEM 415 service, pilot vessels, dispatch services, administrative offices, and other support are needed. Infrastructure needs vary greatly by operating environment. In some cases such as open-sea approaches to pilot grounds subject to heavy weather, all- weather station boats are essential. In other cases, where headlands or other features may offer protection, pilot launches may suffice. In inner harbors, small- er launches or transport via tugboat may be sufficient. Dispatch services may or may not need to include a pilot tower at harbor entrances or in the harbor itself. Tower equipment may range from radios and telephones to radar and vessel traffic service equipment. One or more dispatch offices or stations may be need- ed. All these elements need to be accommodated in the pilotage system.