Managing Director of Hong Kong Shipowners Association

From: nacsn [mailto:
Sent: Thursday, February 07, 2013 10:47 AM
To: 'Arthur Bowring'
Cc: undisclosed recipients
Subject: RE: 24 May 2011 MSC Circular 1163/Rev.7 and 7 June 2012 MSC Circular 1164 /Rev. 10

Chairman of ICS manning and training committee

Dear Arthur,

On behalf of Taiwanese seafarers, thank you so much for your assistance.

Happy Lunar New Year of Snake

Best wishes

Bob Hsu

Secretary General

NACS

National Association of Chinese Shipowners

Tel: 886-2-23111230 886-2-23110239

Fax: 886-2-23116924

E-mail address:

Website:

From: Arthur Bowring [mailto:
Sent: Wednesday, February 06, 2013 5:24 PM
To: nacsn
Subject: Re: 24 May 2011 MSC Circular 1163/Rev.7 and 7 June 2012 MSC Circular 1164 /Rev. 10

I will get back to you shortly, Bob. We have the ICS manning and training committee meeting tomorrow, and I will bring this up then. I presume reports are late because there is very little practical sanction that the IMO can impose.

All the best

Arthur

On 4 Feb, 2013, at 4:52 AM, nacsn wrote:

Dear Arthur,

Please,

I need your help and comments of the following issues on STCW Convention and

MSC.1/Circ.1163/Rev.7 /24 May 2011 (STCW Reg. I/7 Communication Reports of Information) and

MSC.1/Circ.1164/Rev.10 / 7 June 2012 (STCW Reg. I/8 Quality standards Reports of Independent Evaluation)：

1.According to the MSC.1/Circ.1164/Rev.10 / 7 June 2012, regarding to the information related to reports of independent evaluation submitted by Parties,

Hong Kong due date of the Second Cycle Report to be communicate to the IMO Secretary General

is on the 29/07/2009. According to the STCW Section A-I/8 Item 3

“Each Partyshall ensurethat an independent evaluation of the knowledge, understanding, skills and competence acquisition and assessment activities, and the administration of the certification system,

is conducted at interval ofno more than five yearsin order to verify that：.1、.2、.3、.4“

Will Hong Kong prepare the Third Cycle Report and submit to the IMO Secretary General before the

Third Cycle due date of 29/07/2014 which is the Second Cycle due date of 29/07/2009 plus 5 years,

this kind of concept and logic are correct or not?Especially each Parties are put every efforts at this

transitional period on the so called of STCW 1995 convert to STCW 2010 to be enter into force 01/01/2017.

The Second Cycle Report of The Independent Evaluation of Taiwan was completed and ready for

whom it may concerned to check in 14/04/2009,

whether Taiwan must prepare theThird Cycle Reportof The Independent Evaluation and ready for

checking before 14/04/2014 or otherwise?

2.Regarding to the MSC.1/Circ.1164/Rev.10 dated 7 June 2012, between the“Due date”of reports to be

communicated to the Secretary General and the”Actual Date”report communicated to the Secretary General.

i)Why IMO MSC allow such biginconsistence gap existing between Parties ?

Is it might due to ensure to conduct the Independent Evaluation reportis a shall，

but at intervals ofno more than five years is not a Mandatory ?

ii)There are so many Parties never submitting Independent Evaluation report, or submitting

Independent Evaluation report over the “due date “, but according to the Reg. I/7 Item 3.2

MSC “review the list of Parties which communicated information that demonstrated that

they give full and complete effect to the relevant provisions of the Convention,

to retain in this listonly the Parties so concerned；and .3 “

Why those Parties still in the so called “white list “, and never delete in MSC.1/Circ.1163/Rev.7

dated 24 May 2011 according to the Reg. I/7 Item 3.2 ?

See you

in17 March 2013 at Taipei for the forthcoming ASF SRC 16thInterim Meeting.

Thanks and best wishes