Small Commercial Vessel Association
Ontario
Region
National
CMAC presentation on Personnel
April
24 , 2012
Honorable
“CMAC “ members :
We
are a newly formed group of Small Commercial Vessel Operators who would like to
take this opportunity to express a number of concerns on Federal regulations
affecting our industry. Our group is mostly comprised of Marine Contractors,
Marina & Taxi Boat operators, Tour operators, Property Managers, Real
Estate Brokers, Camp operators & Construction Support service providers.
Our group is working in concert with another small commercial vessel working
group in the pacific region who made a presentation at the Vancouver CMAC in
early March . It is our intension to bring this information to all vessel operators
across the country to encourage long overdue changes in regulations affecting
our industry .From our preliminary surveys we are estimating that there could
be as many as 10,000+ vessels in this category in Ontario
alone and over 50,000 nation wide.
Many
of us have been working on Georgian Bay , the Great Lakes / inland lakes across northern Ontario , the
Muskoka Lakes and Parry Sound District for decades, and in some cases for two
and three generations and possess considerable nautical skill & experience. Construction is a challenging and
dangerous profession that requires significant training and experience to
safely execute work on Road Accessible projects.
When
Construction and the provision of related services occurs in water access
locations using small work boats , landing and deck barges etc. , it adds
exponentially to the complexity of performing
work safely . In a recent Transport Canada power point presentation in Port
Severn, we learned that over 80 % of commercial vessels are considered “small
commercial vessels” under 15 GT, yet very little support seems to be available
to this industry.
“Principal operator certification and
training “
We
have observed that most of the TC regulations and personnel training programs
appear to be focused larger ocean going and great lakes cargo and charter
vessels. In particular,the “Principal operator certification and training “is
for the most part not relevant to smaller vessels in our industry.
Almost
without exception, the graduates of these courses have commented that the
course syllabus was helpful relating to general marine safety, lifesaving, firefighting
and navigation and helicopter evacuation from large ships, but fell extremely
short in providing meaningful education
around the proper loading & lashing of loads and safe operation of work
boats landing and deck barges.
It
would be our hope that TC would consider the possibility that in the best
interest of protecting the public and small commercial vessel operators, that new
courses could be developed in collaboration with our industry. These
courses could be an amendment to the existing Med-A-3 & SVOP courses and
include many of the protocols and safety measures already used by responsible
small craft operators.
More
conventional and situation appropriate life saving protocols could be taught
that fit challenges facing smaller craft.
In
our opinion, all TC certified courses should teach and test actual operator
proficiency. Every graduate should be required to demonstrate their competence
to an examiner by taking the vessel for which they are trained, through its
paces before licenses are granted. On a further note , currently a commercial
vessel under 8 meters may be operated in sheltered waters by someone with a
PCOC .
PCOC
This subtitle is in
reference to the vast differences from one license category to the next and how
it affects our members not only during our commercial usage but also as we
encounter our pleasure boating counter parts. There is
an immense double standard in compliance required between pleasure craft and
small commercial vessel regulations.
PCOC – Problems
with Pleasure Craft Operator Cards
-
vast number of ways of obtaining a card
-
many sanctioned issuers offer
“guaranteed” success rates
-
common place for cardholder to have
another individual complete exam on their behalf
-
zero practical experience required to
obtain card
-
exam instructors seem to have little to
no boating experience (summer students)
-
PCOC holders can operate vessels which
can have extreme gross tonnage in the case of pleasure yachts (once again, no
experience required)
-
PCOC holders can operate vessels at speeds which are twice vehicular Highway speeds with
little or no experience
We are certainly not the first group to criticise the
PCOC program , which arbitrarily certifies
operators of any class and size of vessel with a 30 minute quiz on
navigation . Many operators were certified online with no accountability for
how they achieved a passing grade. Recently there was a story on the radio
wherein a pet owner was able to get a PCOC for his dog.
We
do not believe that Pleasure Craft Operator Card level of certification should
be a valid license to operate any commercial vessel regardless of its size or
intended use. PCOC’s can be obtained on the internet by someone who is
completely incapable of handling a vessel in actual conditions, and there is no
proficiency testing involved whatsoever.
Wheeled
Vehicles, driven on public highways with centerlines, stop signs, lights and
visual aids require vigilant competency testing their intended vehicle before
licenses are granted.
Waterborne
vessels are operated on all classes of waterway, in fog , high winds and high
seas at times ,with only an occasional spar buoy to guide the way. Pleasure
craft operators are often completely incompetent operating vessels safely and
it is our belief that this inadequate and dangerous method of vessel
certification should be completely abolished.
If
I am the owner of a pick-up truck and I use the truck recreationally, I must
still pass a written examination , a practical in vehicle exam and an eye exam.
Whether I use my truck for work or pleasure I must follow the same protocols .
Over
the last few years , the public have seen hundreds of thousands of dollars
spent promoting the flawed PCOC program through various means . Why did
Transport Canada not dedicate similar resources to promoting the new small
commercial vessel regulations and licensing requirements that came into law in
2007? Until most recently the information
was mostly spread by rumour.
“ Whether 5
GT or 15 GT , One size should fit all “
The
responsible small vessel operators in the region of Ontario have for the most
part have embraced the requirements put in place by Transport Canada for small commercial
vessels, however due to lack of awareness and enforcement, many operators are
staying “under the radar “ . Over the last few weeks our members have tried to
understand the requirements that are going to be put in place regarding Med –A-3,
SVOP and Masters Limited 60GT.
Although
there have been conflicting reports, 5 GT
seems to be the limit for SVOP certification.
Operators
are often using vessels < 5 GT simply because of regulation, expense and lack
of access to an operator having Masters Limited 60 GT license, even though a
larger vessel may be safer and more appropriate for the application.
We
would submit that an experienced operator of a 5GT vessel who has demonstrated
their competency, are easily capable of operating a vessel of 10 or 15 gross tons
safely and efficiently.
If
SVOP operators were permitted to operate a vessel up to 15 GT, they could perform their duties more safely in much shorter time where materials
are being delivered to job sites.
Fewer trips = fewer departures and landings = Lower
chance of incident.
A
vessel up to 15 GT is much more stable when encountering rough seas due to wind
or other vessels throwing large wakes, as is often the case on the Great Lakes,
Georgian Bay or the Trent Severn waterway.
Non commercial pleasure craft vessels over 5 GT and even over 15 GT are often operated
, by irresponsible & unskilled
operators having no more than a Pleasure Craft Operators Card that was procured
by their 12 year old on the internet .
We
believe that the size limit for operating vessels with an SVOP license should
be increased from 5 GT to 15 GT.
Sheltered
Waters Voyage – a
voyage in Canada on a lake or a river above tidal waters, where a vessel can
never be further than 1 nautical mile from shore, or that is on the waters
listed in Schedules 1 and 2 of the Vessel Certificates Regulations.
(Section 1)
SHELTERED WATERS VOYAGES — WATERS
PART 1
ONTARIO
|
Column 1
|
Column 2
|
|
|
Item
|
Waters
|
Period
|
|
2.
|
The waters of Parry Sound (sound) and
the waters off Thirty Thousand Islands east of a line drawn from the
southwest end of Franklin Island to the northeast end of Sandy Island and
from the southwest end of Sandy Island to the east side of Fryingpan Island
|
Beginning on May 15 and ending on
October 15
|
|
4.
|
The waters of Georgian Bay east of a
line drawn in a northerly direction from the mainland at 44°51.5′N, 80°0.5′W
to the southern tip of Giants Tomb Island
|
Beginning on May 15 and ending on
October 15
|
|
and south of a line drawn from the
northern tip of Giants Tomb Island to the mainland at Cognashene Point,
including the waters of Severn Sound and Penetanguishene and Midland
Harbours
|
We would like to propose an amendment
to extend “Sheltered Water” classification from a line drawn from the
south west end of Sandy Island, Georgian Bay in a southerly direction to the
Northern most tip of Giant’s Tomb Island , Georgian Bay, and include all waters
lying east of this line.
This amendment would continue to include
Frying Pan Island, on Georgian Bay along with the area drawn from the Northern
tip of Giant’s Tomb Island to the mainland at Cognashene Point .
These waters meet the current definition of
Sheltered Waters Voyage cited above whereby the route of travel is no more than
1 nautical mile offshore.
These waters are clearly marked by a buoy
and navigation system maintained by Canadian Coastguard.
The inclusion of these waters as described
above would be a natural extension of what most mariners consider “sheltered
waters” and are often more sheltered than other areas already designated as
“sheltered” such as Waters off the North Channel
This proposal would offer a unified
approach to the classification system rather than dividing various sections
that are geographically similar and would have a similar “risk Rating “.
Our proposal would enable commercial vessel
operators to operate within the same guidelines as their counterparts south of
the items listed in item 2 (southwest end of Sandy
Island to the east side of Frying pan Island) and north
of item 4 (south of a line drawn from the northern
tip of Giants Tomb Island to the mainland at Cognashene Point ).
Secondly , we would submit that the Annual Dates
for these voyages in all cases should be extended to between May 1rst and
November 15th of each year as these are common times for operation
of small commercial vessels and barges.
In general , we believe that a vessel
travelling within 1 nautical mile of shore should be considered as travelling
in “Sheltered Waters “.
Economic
Impact
1) TIME –
this information has come at the WORST possible time. The Northern Ontario
construction industry is, at best, a seasonal business. It is almost ‘normal’
and ‘socially acceptable’ for people to be laid off and collect EI for the
winter and be rehired in the spring. The Construction Industry as a whole is
just starting to emerge from one of the biggest recessions the world has ever
seen. We also have just had one of the mildest winters on record coupled with
the earliest ice-out in history.
Due to the total lack of consultation with the industry, most SCV
operators only discovered recently about the June 30 , 2012 deadline for
commercial vessel licensing , and associated self inspection of vessels .
-The 60 Ton Masters (limited) licence
to drive the bigger barges to large jobs such as new cottages and septic beds.
$1350.00
per student tuition PLUS 3 weeks wages @
$1,500 / wk PLUS food and lodging in
Owen Sound @ $100 /day. Estimated course cost of $7,350
per operator.
In addition , the
lost opportunity cost of the operator would calculate to approx. 150
HRS @ $15 / HR =an
additional $2,250 for approx. $9,600 per operator
Many
of the larger contractors have 5 or more operators on staff for a total
investment of $48,000 or more
In
summary , the economic impacts of this initiative are extremely onerous for any sized business. In some cases ,
business operators are simply not prepared for a sudden financial burden of
this impact.
We
would additionally submit that even if a business owner has the resources to
provide the aforementioned training and updated equipment ... the operators are
still not properly trained for the type of work being undertaken in our
industry.
We
respectfully request , that a grace
period be offered on the June 30 ,2012 deadline util Transport Canada and
Industry have an opportunity to work out better programs and solutions for the
aforementioned concerns .
The Small Commercial Vessel Association ,Ontario
Region .
This document was prepared in collaboration
of all members under the supervision of the President and 10 member Board of
Directors .
Sincerely ,
Armin Grigaitis.
President
Small Commercial vessel Association .
Ontario Region .
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