Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence

Memorandum by The Corporation of Trinity House (FUS 14)



  The Corporation of Trinity House believes that, despite the ever increasing internationalisation of shipping, a strong UK merchant fleet, both in terms of ships and shipping operations based in this country, is essential to the UK as an island nation. The associated skills, resources, businesses and service industry links provide an important contribution to the economy and help towards protecting the marine and coastal environment.

  For this reason, the time is right for UK Shipping and the associated maritime industries to be given a real incentive, by maintaining a place at the forefront of the Government's agenda, to develop and remain competitive against an international backdrop of increasing regulation, inconsistent compliance with the rules and emerging markets.

  The professionalism synonymous with UK Shipping requires high standards of training and the ongoing development of quality seafarers. The present shortage of skilled personnel is of great concern to Trinity House and has led the Corporation to take positive action, through its Merchant Navy Cadet Training Scheme, to contribute to the training and future employment of UK seafarers.

  Efforts are being made both nationally, regionally-through the EU-and internationally to promote greater all round compliance with the International Maritime Organisation's (IMO) regulations. Codes of practice are also being developed and enhanced by the Chamber of Shipping and other leading representative bodies. These bodies also regularly seek intervention on the wider issues of flagging-out, tax incentives and shipbuilding subsidies. However, the responsibility for promoting British Shipping is a collective duty, one that involves all political and commercial interests working together within a framework of common aims. The global nature of shipping means that the solution to the problems faced by UK Shipping relies on using all relevant channels to exert the maximum power of influence in the international arena.

  The standards set for shipping need to be sufficient to safeguard life at sea and protect the environment and at the same time be similarly attainable by not only the established maritime nations but also the emerging ones. If the standards adopted in the UK or the European Union are too high, commercial pressures may drive shipowners towards a less rigid regime. The solution seems to lie in what is achievable by the vast majority of nations based on the highest possible common standard. A balance approach should be taken by the Government:

    —  to increase efforts to fortify and enforce IMO rules to ensure their consistent application worldwide;

    —  to review the existing UK shipping regulatory framework in comparison with those adopted by our continental neighbours and elsewhere;

    —  to ensure ongoing co-operation among the UK maritime industries and in particular the Insurance Industry and the Classification Societies which have a key role in ensuring compatibility with the wider regulatory framework for shipping when certifying vessels.


  The role of the Corporation of Trinity House is to Serve the Mariner by providing a reliable and economic aids to navigation to all classes of user for the safe and expeditious navigation of vessels. The Corporation, with the General Lighthouse Authorities for Scotland and Ireland, jointly published their Marine Navigation Plan in 1997 for the provision of aids to navigation well into the 21st Century, following a thorough consultation process worldwide on future requirements. Implementation of the Plan is well underway with the provision of a differential Global Positioning System satellite navigation service, the proposed discontinuance of the present radiobeacon service in 1999 and the Decca Navigator System in 2000, and the review of traditional aids. A copy is enclosed for information purposes.

  However, a reliable system of aids to navigation cannot compensate for ships that are not well managed, adequately equipped or properly crewed, regardless of flag. The Corporation therefore has a special interest in co-operating with other maritime interests to ensure that all the essential elements that contribute to safety at sea are being given the highest priority. Services to UK Shipping depend on mutual co-operation to be truly effective and successful.

  The irony is that safety is only achieved at a financial cost. It seems that safety measures therefore need to be carefully considered and monitored in terms of the benefits and the costs, with an eye to the policies adopted by other nations. It may be important therefore to ensure that the commendable efforts to find causes and provide answers in the wake of a major shipping diaster—such as the Braer and Sea Empress, do not result in measures which may inadvertently penalise sectors of UK shipping and their competitive position in the global market. For this reason, the multi-lateral approach to improved safety at sea through the IMO is to be the preferred option in all cases, unless time is of the essence.


  Most of the shipping that enters UK waters is foreign-based and the record of ship detention's under port state control measures provides ample evidence that IMO rules are not necessarily universally or consistently applied.

  The European Commission (DGVII—Transport) has repeatedly stated its intention and has already been responsible for introducing a series of Directives to ensure compliance with the IMO regulatory framework by ships entering the ports of EU nations. As the EU eventually expands to include Poland, Turkey, Malta and the Baltic States the gap in standards among EU nations may, in fact, widen which could leave the UK in a position of some weakness in the market.

  The Corporation believes that it is essential therefore to ensure that the European Union keeps on track with its policy for measures aiming:

    —  to establish a convergent implementation of existing international rules and the tighter enforcement of these rules; and

    —  to promote a coherent and harmonised development of aids to navigation and traffic surveillance infrastructure, bringing maritime safety into the electronic age with particular attention to environmentally sensitive areas.

  The right balance is likely to be a mixture of formal regulation, where necessary, and internal policies and procedures contained in recognised codes of practice—with input from all the various interests—which are formally adopted by the UK Shipping Industry where appropriate.


  The UK needs mariners not only to serve in its merchant ships but also to be pilots, harbourmasters or to fill the many other mariner based posts within the around the periphery of the marine industry, afloat and ashore. The Corporation's efforts to serve the mariner have so far encouraged 60 suitable young people to embark on a sea going career and to further encourage them to go on to achieve their ultimate goal in the marine industry, wherever their skills are in demand.

  The Corporation can apply its charitable income in one of two ways involving cadets and seaman in all matters pertaining to navigation and seamanship:

    (a)  by giving educational grants or bursaries to officers Cadets and seaman; or

    (b)  by assisting schools and other institutions providing such education or training or assisting in the establishment of such training.

  New entrants to seafaring need adequate sea time as well as more formal training and the depletion of the UK fleet which has traditionally provided the best training ground is making it more difficult to find places and continue to motivate talented and enthusiastic cadets. Every shipowner involved in cadet training recognises a responsibility to the industry at large. In the mid-1970s there were 90,000 British seafarers associated with 1,7000 vessels. By 1995, that number had declined to something below 20,000 while the number of vessels had roughly halved. History has shown that training can be given a lower priority in the face of recession without an eye to the long-term consequences of training neglect. If the majority of vessels controlled by UK interests are manned by personnel from Pacific rim countries, industry ship operating experience is likely to transfer from the UK to the Far East and with it the qualified candidates for the infrastructure jobs.

  The significant improvement in recent years in the recruitment of Cadets has been due, in no small part, to Government assistance to the industry in the form of the DOCS scheme, which is designed to encourage and assist British shipowners in the employment of qualified British junior officers. It is essential for such Government initiatives to be maintained and extended in the form of an intervention fund which will ensure that British nationals are employed in all officer ranks to underpin the British shipping establishment.


  Although not strictly a commercial ship operator in the true sense, the Corporation is aware, as a shipowner, that there are significant economic benefits to be gained from building and registering ships outside the UK. It is unlikely therefore that the competitive position of UK Shipping can be improved without reviewing the whole matter of shipbuilding subsidies, tax incentives and other financing packages. Trinity House believes that the Government should consider a range of options to provide incentives to encourage ownership of British ships and their economic manning by British or British trained mariners. The UK leads the world in terms of shipping safety standards at sea and the quality of their officers and crew. The Corporation is concerned that unless appropriate steps are taken the costs associated with safety and maintaining those standards will continue to drive commercial operators towards less expensive and poorer quality flags.

  The Corporation believes that the Inquiry into the future of UK Shipping is a timely and important intervention by the Transport Sub-Committee and looks forward to a constructive outcome in parallel with consultation on the Deputy Prime Minister's proposed paper on Shipping flowing from the broader integrated Transport White Paper issued in July.

P B Rowe

Deputy Master

4 December 1998

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