Seafarers and Administrative Burdens

Lately, due to a DMA report, there has been a lot of talk regarding administrative tasks in the maritime sector. In this article the findings of this report are being highlighted. The DMA report contains data from three studies on administrative burdens in the maritime sector. The first two studies on Danish seafarers and Danish shipping companies found that Danish seafarers use up to 20% of their working time on tasks they consider as administrative burdens and for employees in shipowners’ offices ashore the figure was 9 %. The study that has been conducted on international seafarers (with data from 59 nationalities) showed that 30 % of international seafarers feel that they spend too much time on tasks that they consider to be administrative burdens.

2013.10.31 - DMA Study on Administrative Burdens in the Maritime Sector Figure 1

It is true that the maritime system has come a long way to improve safety and efficiency at sea. The efforts are mainly focused on the creation of formal standardized procedures and requirements to create safety and efficiency, which as a result required a good deal of administrative “procedures”. This approach on the one had a positive effect on safety but on the other hand the documentation and control requirements have gradually grown larger, more complex and more time consuming. Not to mention the fact that new regulations are being issued/scheduled as part of the industry’s “evolution” (whether it is for safety, environment, security etc).

DMA’s survey on Danish seafarers showed that they use no less than one-fifth of their working day on dealing with what they consider to be administrative burdens, filling out forms and maintaining documentation on board the ship and of course take part in inspections.

In the Danish shipowners’ offices, the administrative personnel use almost 10 % of their working time on administrative burdens.

In the DMA’s survey on international seafarers, 30 % of the seafarers feel that they spend too much time on tasks that can be considered administrative burdens and paperwork. These burdens primarily stem from unnecessary repetition of tasks and demands for too much paperwork and handling of documentation. Such paperwork is considered by many as “boring” and that its repetitive nature can dull or even damage mental strength.

While repeated experience offers opportunity for learning, it also introduces the possibility of affecting motivation and causing boredom (Cynthia D. Fisher (1993), Boredom at work: A neglected concept). When a task is repetitive, familiar, or dull, an individual is more likely to experience only low levels of cognitive arousal and, as a result, might disengage from the task (Warr, P. (2007). Work, Happiness, and Unhappiness).

The DMA report documented on the following observations, what is widely believed by seafarers regarding administrative burdens.

Observation 1. Seafarers of all nationalities perceive administrative burdens in the maritime sector as frustrating and burdensome. Despite very similar assessments internationally among seafarers, there is a cultural tendency towards Western European seafarers being more vocal in voicing the many inappropriate consequences of issues, rules and procedures existing today. It would be interesting to further study the reasons behind this observation. Why Western European seafarers are less reluctant to express their beliefs on administrative burdens? Is it related to the fact that culturally they are more close to the English language used internationally? Are they “treated” on such matters differently from their colleagues from other nationalities?

Observation 2. Seafarers are concerned about ship safety and take great professional pride in their jobs. Many requirements and procedures are thus understood and accepted as a natural part of working routines. Many seafarers say that they consider drills to be meaningful because both their own safety and that of the ship is at stake. The filling-out of journals in the engine room and on the bridge is something which seafarers have grown accustomed to and see as a good way of documenting and sharing information. It is not perceived to be a significant burden. Most seafarers also express their understanding of the need to conduct inspections to make sure that the ship’s standard and performance is satisfactory.

Observation 3. Seafarers and shipowners experience that there are significant potentials for standardisation and optimisation concerning port and pre-arrival documents and processes. The surveys that have been conducted in Denmark and internationally show that the procedures concerning port and pre-arrival documents are considered a burden. The seafarers often find it difficult to see the rationale in manual handling of information which is already available in digital form or could easily be handled in a digital format. At the same time, the seafarers point to the differences in formats and forms used in different countries and ports when, essentially, it is the same data which is being handled.

It is not uncommon to provide the exact same information in ports of different countries but in totally different forms. Not to mention that the forms aren’t always self explanatory and what may seem simple to report, depending on the way it is written on paper, can have room for more than one answers leaving the seafarer in a confusion on what is the correct entry in a form. For example there are different formats for listing the names of the crew. Some ports require that you write the name as on an airline ticket, but since the comma is not in the passport, some ports require another format: while others require the names in reverse order with the given name first, not to mention that some require each name in a separate column.

Observation 4. The seafarers find ISPS rules to be somewhat burdensome and do not always acknowledge that they lead to a reduction of the risk of terror actions in ports. Half of the Danish seafarers who are particularly sceptical consider it very annoying because the implementation of the rules, in their view, does not lead to fulfillment of the purpose for which the rules were created. 27 % of international seafarers do not find that ISPS requirements lead to increased ship safety.

Furthermore, it should be noted that the ISPS code remains exactly the same since its initial publication with no amendments at all, event though the operational requirements surrounding maritime piracy have changed.

Observation 5. The seafarers and shipowners consider possibilities for the exchange and sharing of inspection data among those responsible to be underutilised. There are substantial burdens associated with inspections and vetting. Two-thirds of international seafarers feel that tasks in this relation are being performed too often and almost 75 % feel that there is too much paperwork involved. Seafarers especially from tanker ships consider vetting inspections to be highly time-consuming and very annoying. According to shipowners, inspections and especially vetting inspections are a huge frustration point mainly for the seafarers, but also to some extent for the shipowners, because many of them have personnel employed to support crews in preparing for vetting. Not to mention the follow up that might be required depending on what the inspections has identified and the fact that sometimes in order to present a further preventive action regarding a deficiency there might be unnecessary revisions of documentation only to “show” that the matters has been addressed sufficiently.

Observation 6. The seafarers experience that various incentive schemes in place for those performing inspections lead to increased burdens for well-performing ships and have a detrimental effect on the ability of the inspections to actually serve their purpose. During the studies, many seafarers have mentioned issues associated with inappropriate incentives. For example, at port state control inspections, many seafarers have the impression that some countries measure their performance in relation to PSC by the number of ships inspected. This in some places leads to a practice of selecting well-performing ships for inspection. This leads some seafarers to feel that they are ‘punished’ for good behavior with the unreasonable burden of additional inspections and, at the same time, that PSC inspections are not catching sub-standard vessels as they are intended to.

One other issue related to PSC inspections is that occasionally the PSCO is either not clear on describing the deficiency or, although this rarely happens, the PSC inspection report handwriting is almost illegible making it difficult for the personnel ashore to understand what exactly the identified defficiency of the PSC’s report is.

Observation 7. Despite a general acceptance of the need for inspections, seafarers and shipowners perceive the inspection regime to have grown to a disproportionate level where inspections focus on unnecessary detail. Inspections take place when the ship is in port and has many other tasks. This makes inspections a very stressful procedure that sometimes takes so much attention that safety in e.g. cargo operations can be jeopardized. In such situations it is also possible to give the wrong impression to a PSCO, due to the fact that the Master or the Chief Officer might be occupied with many tasks at the same time and thus mistakes or omissions might occur that wouldn’t take place under normal conditions.

Vetting inspections is, by seafarers and shipowners dealing with tanker vessels, considered to be a special nuisance. Vetting is extremely important to shipowners. Doing badly in a vetting can ruin a business. On the other hand, the private vetting companies have to justify new inspections, so they tend to dig deeper to justify the inspection. The result, according to seafarers, is that small problems are often blown out of proportion. Seafarers find it particularly frustrating that inspections focus too much on correct paperwork and procedures and too little on actual ship standards. Inspection thereby becomes the ‘control of control ‘ with a tendency to evaluate the quality of the control system rather than the quality of the ship and crew. This trend is also described in other studies of audits and inspections. Some seafarers describe the development over the last 10 years as a vicious circle in which increasing demands from inspections and vetting leads to an increased level of detail and documentation in the internal QMS systems and additional work for those ashore who might not have always the time to evaluate if an addition is really needed or to review the QMS so as to removed procedures/instructions etc no longer needed. This again leads to focus on more detail in the inspections.

2013.10.31 - DMA Study on Administrative Burdens in the Maritime Sector Figure 2

Observation 8. The seafarers acknowledge that QMS is installed for a reason but there is a perception among seafarers that QMS procedures are becoming more and more burdensome. On the other hand, shipowners find it frustrating to implement new rules with various national interpretation or implementation forcing them to produce large QMS to encompass all the national differences.

One such example of multiple national interpretations is the implementation of the MLC where Flag Administrations issued in their national legislation their interpretation of the MLC, saying on some occasions, exactly the same thing, about various aspects of the code, but using different words. Those involved in the process of the DMLC Part II review may have received feedback from the RO doing the review requesting the exact wording of the Flag’s legislation to be incorporated in the DMLC Part II, as if this would make any difference in the implementation of the MLC.

The seafarers understand the reasons behind most of the procedures, but at the same time complain about the amount of paperwork. They find that it is sometimes more important to document correct behavior on paper than to actually follow through on efficient environment-friendly or safe-ship operations. Some seafarers go as far as to point out that increased burdens have reached a level where it actually might reduce safety and security because filling-out papers tend to remove focus from the primary concerns of safety, environment and security in a stressful and busy working environment.

The detailed QMS can also lead to a feeling among the seafarers of being left with very little room for manoeuvre and autonomy. This is also experienced as a disregard of the professional competences of the seafarers and their ability to judge what is best in a given situation. Another observation is that the QMS and key performance indicators may have incentive structures which can actually lead to honest behavior being punished – and thus cheating about reporting of e.g. near-misses or rest hour compliance may be rewarded. It would seem beneficial to develop a learning culture instead of a culture focusing on finding errors.

Observation 9. Seafarers find that there is a lack of responsiveness to look into the consequences of new procedures and paperwork introduced to the vessels. Seafarers often feel as the last link of the chain with limited feedback opportunities. An example of this disturbing finding is the fact that 33 % of international sea-farers have not during the last three years been approached by a ship manager, a senior officer, a shipowner or a DPA (designated person ashore) to give feedback. Also, many captains/masters have experienced the annual master’s review as a mechanism that does not function well enough.

Master’s SMS review is incorporated in the SMS of every Shipping Company that has to implement with the ISM, but how much attention is given to the feedback received from the Master? Not to mention that the suggestions of a Master may be seen as “extra work” for those working ashore and since the Master might be replaced after a few months there is no need to pay any attention. Especially when the Master’s SMS review comments can be lost in all the paperwork that is going back and forth…

Observation 10. The Danish shipowners mention a range of special Danish requirements and conditions that produce unnecessary administrative burdens for the shipowners’ offices. The shipowners also find that they have to spend many hours on gathering data to report to Statistics Denmark and other public authorities, but they do not feel that they benefit from this exercise. In addition, the same data needs to be reported to different authorities. For this reason, the shipowners wish that the reporting of data could be done less frequently and that the authorities could share the data.

Observation 11. It is the sum of burdens that matters. Many seafarers and shipowners indicate that it is not a specific burden which causes frustration. Instead, it is the sheer sum of burdens which has accumulated over the years. Seafarers and shipowners indicate that rules and procedures have accumulated over the last 5-10 years to an extent where it is now becoming counter-productive. Shipowners are frustrated by the difficulties and complexity of maintaining an overview of changes in international and national rules. The shipowners feel that it is burdensome to:

  1. Find information in international and national databases.
  2. Stay on top of changed regulations.

Many international seafarers point out that keeping up with the administrative du-ties while retaining the required focus on the operational tasks often implies viola-tion of rest hour regulations and that this is a safety concern in itself.

Further details on data collection, data analysis and study findings are given in the individual reports:

  1. Administrative burdens among international seafarers.
  2. Administrative burdens in shipowners offices.
  3. From craft to control, Danish seafarer’s perspective of administrative burdens in the mari-time sector.

The DMA report underlines that the seafarers and shipowners’ understand the rationale underlying most procedures and requirements even though these may lead to administrative burdens. They acknowledge that such procedures are not implemented with the aim of being ‘a burden’, but that they in principle serve higher-end objectives like personal safety and environmental protection. However, many are worried that the marginal utility of more procedures and requirements could now be negative: That procedures and requirements introduced with the intention of protecting people and the environment can in fact obstruct that aim.

A cautious conclusion could be that the substantial level of administrative burdens, which seafarers and shipowners experience, reflects a significant potential to reallocate time to more fruitful tasks within the sector. This could possibly lead to increased efficiency and quality.

Finally, the International Maritime Organization has started a process that aims for the identification and possible elimination of unnecessary, disproportionate or obsolete requirements in mandatory IMO instruments. To assist in the identification of such requirements the IMO has launched a public consultation, for more information please click on the following link:

Reduction of Administrative Burdens

During last April’s session of the IMO FAL Committee, Denmark hosted a presentation where the Danish Captain Christian Rørbeck shed light on the administrative burdens faced by ships on a daily basis around the world. Information on the presentation by Captain Christian Rørbeck can be found by clicking on the following link:

The Administrative Burdens of a Modern Shipmaster

Source: DMA

Comments

  1. A substantial part of today’s shipboard paperwork is fulfillment of formal obligations. The latter have taken the part that used to be handled by personal competence and accountability of officers. Crew sizes have been cut with no room left for practical maintenance (as opposed to planned quayside maintenance), training and drills, and more and more paperwork is added by IMO and national institutions (with an agenda of their own) to check on practices that are the result of insufficient crews (both in size and actual, not paper, competence). My two cents.

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