This paper examines the risks attached to reducing the seatime requirements for STCW Officer of the Watch (OOW) candidates. It is based on observations by experienced master mariners and maritime educators within the Maritime Professional Council of the UK and draws heavily on a submission to IMO by The Nautical Institute.(1)

Executive Summary

This paper assesses the safety implications of reducing the minimum seagoing service required before candidates may proceed towards certification as an Officer of the Watch under STCW Regulation II/1 (2). It argues that the decision taken at IMO sub-committee level to reduce the required period from 12 months to 9 months, with simulator training permitted to replace part of the sea service, has not been supported by an adequate evidence base and risks lowering safety margins within the shipping industry.

The central point is straightforward. The holder of an STCW II/1 certificate is not merely a trainee navigator who has passed a technical examination. That officer may be the only person on the bridge of a large commercial vessel, responsible for the safe navigation of ship, crew and cargo. Competence at that level depends not only on classroom learning and simulator exposure but on extended experience of shipboard life, real bridge watches, fatigue, workload, weather, hierarchy, communications, and the gradual acquisition of judgement.

The paper makes five main points. First, sea service remains a core part of professional formation and cannot safely be compressed without proof that equivalent competence will be maintained. Second, simulators are valuable adjuncts but not full substitutes for the texture, uncertainty and endurance demands of life at sea. Third, the argument for reduction appears to have been shaped at least in part by training berth constraints rather than by positive safety evidence. Fourth, comments from experienced mariners within the Maritime Professional Council strongly support the view that cadets still need prolonged exposure on board if they are to become safe watchkeepers and deck officers capable of undertaking the many other tasks required of them. Fifth, there has been insufficient visible participation in the debate by insurers, P&I Clubs and classification societies, despite the obvious relevance of their casualty and risk data.

The Maritime Professional Council believes that further cuts in seatime would reduce safety at sea. In the Council’s view, a safety regulation that has stood at 12 months since the implementation of STCW should not be diluted unless those proposing change can demonstrate, with robust evidence accepted by IMO, that there will be no reduction in competence and no increase in risk.

 

1. Background and regulatory context

The issue under discussion concerns certification under STCW Regulation II/1 for officers in charge of a navigational watch on ships of 500 gross tons or more. In practical terms, this is the Officer of the Watch qualification for unlimited service. It is not a minor or sheltered role. The certificate may permit a newly qualified officer to take sole charge of the bridge of a vessel of any size, in almost any waters outside the specific polar regime, and to do so while carrying direct responsibility for the safety of life, property and the marine environment.

The Nautical Institute submission, summarised in the uploaded paper, notes that several proposals in the current STCW review sought to reduce the seagoing service requirement, including a proposal to move from 12 months at sea to 9 months supplemented by up to 3 months of shore-based simulator training. Similar proposals appeared in multiple submissions considered by the Sub-Committee on Human Element, Training and Watchkeeping. Despite the advice of The Nautical Institute, the sub-committee decided to support the reduction. That decision now moves forward for approval at a higher level within the IMO system.

This is not merely an administrative adjustment. The sea service requirement exists because the STCW framework recognises that competence at operational level must be grounded in practical experience. The uploaded material recalls that IMO itself has noted that sea service is needed in order to gain adequate experience and acquire skills, and the STCW Code states that mandatory periods of seagoing service are of prime importance in learning the job of being a ship’s officer and in achieving the overall standard of competence required.

 

2. Why seatime matters

The case for maintaining seatime rests on the nature of the work itself. Real shipboard experience builds competence in ways that cannot be fully replicated ashore. It exposes cadets to the full cycle of routine and non-routine operations, to variations in weather, visibility, traffic density and watch conditions, and to the discipline of repeatedly standing live bridge watches over time. It also embeds habits of checking, reporting, prioritising and communicating under real operational pressure.

The uploaded paper stresses that the ordinary practice of seamen is experiential by definition. It is learned by seeing how real situations unfold, by absorbing what matters on board, by witnessing how experienced officers anticipate problems, and by discovering how apparently small departures from good practice can create risk. This is part of what mariners often describe as a seaman’s eye: the instinctive capacity to notice that something is not right before it becomes an incident.

For cadets, that learning is cumulative. They do not simply accumulate days. They absorb context. They learn how their ship sounds and feels, how watches vary at different times of day, how bridge resource management changes when fatigue builds, how cargo operations affect the rest of the ship, how mooring and unmooring create hazards, how weather degrades performance, and how responsibility feels when the margins narrow. That is the basis on which formal competence is built.

 

3. The Officer of the Watch is responsible for more than navigation

The Nautical Institute submission is that it rejects an overly narrow view of the OOW role. The certificate holder is not just a technician of collision avoidance. The workplace of an OOW is the whole ship. On a large vessel that may mean a complex industrial environment with fuels, lubricants, mooring equipment, lifting gear, cargo hazards, enclosed spaces, watertight doors, stability considerations, and people working across multiple departments.

The submission underlines that the holder of the certificate must be able to discharge legal and professional duties extending well beyond the bridge console. The officer must supervise, communicate, lead, and sometimes intervene urgently when something is awry. That requires confidence grounded in experience. It may also require a young officer to direct ratings or other seafarers who have spent much longer at sea. Such authority is much harder to exercise safely if the officer has had less time to understand shipboard routines and less opportunity to observe how sound judgement is exercised in practice.

The STCW Code itself, as quoted in the submission, makes clear that the scope of knowledge implicit in competence extends beyond immediate technical tasks. It includes what to do, how and when to do it, and why it should be done. That wider understanding is exactly what prolonged experiential learning helps to develop.

 

4. The strengths of simulation and the limits of simulation

The uploaded paper does not dismiss simulation. On the contrary, it records several important advantages. Simulation offers risk-free learning. Mistakes do not cause casualties, pollution or damage. Complex situations can be repeated until the trainee responds correctly. Performance can be recorded, reviewed and debriefed. High-intensity exposure can be delivered in a structured and standardised way. These are real strengths and modern training should make use of them.

But the same material also sets out the limitations in detail. Simulators do not fully reproduce the physical reality of shipboard life. They are usually climate-controlled. They do not impose the cumulative biological effects of fatigue over long voyages and repeated watches. Many do not replicate motion realistically. Many part-task systems lack the sensory and lookout fidelity of a real bridge. They do not recreate the social dynamics, sustained responsibility and practical distractions of a live vessel.

MPC members also make another vital point: poorly designed or poorly delivered simulator courses are a risk in themselves. One MPC contributor with around twenty-five years’ experience teaching mainly senior deck and engineering officers on full mission deck and engine room simulators argued that the tools can be very effective, but that the quality of the teach-ware and the competence of instructors are essential and are often found wanting in many centres around the world. Even good simulator training, he noted, still requires follow-up mentoring and coaching on board before learning becomes embedded in operational culture.

The broad conclusion from the material is not that simulation has no place. It plainly does. The conclusion is that simulation is an adjunct to experiential learning, not a wholesale replacement for it. Most experts and regulatory bodies do not regard simulator training as a one-to-one substitute for sea service. At best it may safely trim a limited period at the margins. It cannot credibly replace months of exposure to the realities of service at sea.

 

5. Human factors, fatigue and the realities of life on board

The arguments against reducing seatime are not confined to technical competence. The contributors to this paper stress the importance of human factors. An officer who lives on board for months has to perform in spite of fatigue, seasickness, isolation, interpersonal friction, disturbed sleep, irregular routines, heat, cold, and the discomforts of a working ship. The cadet who learns to function safely in that environment is learning something essential about the profession.

This is one of the weakest areas in any case for substituting sea service with time ashore. Simulators can present scenarios, but they cannot replicate the cumulative physiological toll of real watchkeeping at sea, or the need to sustain performance day after day in a closed working and living environment. Nor can they recreate the small but relentless frictions that shape judgement and resilience on board.

These factors matter because STCW officers are expected to perform safely not in ideal conditions but in the real world. A newly qualified OOW who is technically capable in a simulator but less seasoned in the lived demands of shipboard work may be more vulnerable to error when tired, pressured or uncertain. Reducing seatime therefore risks weakening precisely the kind of practical resilience that the industry should want to strengthen.

 

6. Evidence, or the lack of it

One of the most troubling aspects of the push to cut seatime was the lack of evidence supporting reduction. The Nautical Institute submission states plainly that proposals to cut the sea service requirement do not include evidence to show that the change can be made safely. Indeed, under the field asking for available evidence, data or research to support one proposed amendment, the response was simply ‘None’.

That matters because this is a safety regulation. The burden should not rest on those defending the status quo to prove that the existing standard must remain. The burden should fall on those proposing a lower requirement to demonstrate that it will not reduce competence or increase risk. In safety-critical industries, lack of evidence is not a neutral condition. It is a reason for caution.
The submission also recalls that the IMO has previously recognised the importance of gathering information and understanding developments before making future regulatory decisions on the basis of evidence. That principle should apply here. A reduction in experiential training should be evidence-led, not convenience-led. At present, on the basis of the material available, that threshold has not been met.

 

7. The absence of insurers, P&I Clubs and classification societies

The Maritime Professional Council considers it especially important to underline the apparent absence, or at least lack of visible weight, of insurers, P&I Clubs and classification societies in the debate. This matters for practical as well as symbolic reasons. These sectors sit close to the consequences of maritime failure. They analyse collisions, groundings, pollution incidents, machinery damage, personal injury, claims trends and near-miss patterns. They have a direct interest in whether newly certified officers are adequately prepared for independent duty.

It is therefore striking that a proposal to reduce practical training time appears to have advanced without a clearly visible body of risk-based input from those communities. Their data and experience could help answer questions that are central to the issue: do casualty patterns show elevated risk among less experienced officers; what forms of failure most commonly emerge in the first months of independent watchkeeping; and what indicators should regulators examine before deciding that a lower threshold is safe?

The same point applies to classification societies, which are deeply involved in safety culture, standards, technical assurance and operational learning across the fleet. Their absence leaves a gap. If the industry is going to alter a long-standing competence benchmark, it should do so with input from the full safety ecosystem, not primarily from training administration alone.

One MPC contributor explicitly stated that input from the insurance industry and P&I Clubs is important and that a survey of shipmasters would also be enlightening, since masters take ultimate responsibility for their officers’ failures. That is an important practical recommendation. Before the reduction proceeds further, shipowners, insurers, P&I Clubs, classification societies and masters should have a clear opportunity to test the case against operational reality.

 

8. Comments from experienced mariners within the Maritime Professional Council

Comments from experienced mariners that reinforce the formal submission. These observations are especially important because they come from practitioners and educators who have seen how cadets and junior officers develop in real settings.

One contributor, after many years of teaching on modern full mission deck and engine room simulators, stated that cadets do not yet know what they do not know. In his view, simulators can help them learn safely, but at that fledgling stage of their careers such training can only be an adjunct to overall experiential learning, and sea time is irreplaceable if cadets are to learn slowly on board what they do not yet know. That is a significant professional judgement, precisely because it comes from someone who understands both the value of simulation and its limitations.

He added an important caveat: even sea time itself has to be structured properly. Officers on board must have the time, competence and inclination to mentor cadets. He suggested that many of the conditions that once supported this have been eroded by crew sizes being cut to the bone, fast port turnarounds and excess paperwork. That observation is highly relevant. If the real problem is that the quality of onboard training is under pressure, then the answer should be to improve training conditions, not to reduce the amount of exposure required.

Another MPC contributor agreed strongly with the Nautical Institute position and argued that if berth availability and fatigue are among the underlying issues, those are the matters on which the industry should focus right now, rather than resorting to sticking-plaster solutions involving more simulator substitution. This is a sober warning from experienced practitioners, not a rejection of modern methods.

 

9. Structural pressures are not a sound basis for lowering standards

The MPC believes one of the key drivers behind the proposed change is shortage of training berths. That may be a real and serious problem. But if so, it should be addressed as such, not treated as proof that a lower standard is equally safe. Safety requirements should not be adjusted downwards simply because the system is struggling to meet them.

There are several structural pressures in modern shipping that may be bearing on this issue: reduced crew numbers, short port stays, administrative overload, commercial pressure for efficiency, and less time for mentoring on board. None of those pressures is imaginary. But they are all reasons to protect competence, not dilute it. If cadets have fewer opportunities to learn properly during each month at sea, that strengthens rather than weakens the case for caution before reducing the total period available.

There is a risk here of policy inversion: taking symptoms of a pressured training system and answering them by lowering the benchmark that the system is meant to achieve. The Maritime Professional Council believes that the safer course is the opposite one. The industry should protect the benchmark and address the pressures directly.

 

10. Historical context

For context, prior to the introduction of the STCW the UK required candidates for the then equivalent to OOW, the Second Mate’s Certificate of Competency, to have completed four years’ sea service. That time was reduced to three years if the candidate had completed 12 months at a recognised training college (in the 1970’s, typically 3 years at sea, 18 months at college). We are a long way from that now.

This historical comparison does not prove that today’s arrangements should mirror the past. Ships, systems and training methods have changed. But it does serve as a reminder that professional competence at sea was once understood to require a much longer period of experience at sea before independent responsibility was entrusted. The overall trend has been towards reduction, not expansion. That fact should induce caution before the benchmark is lowered yet again.

 

11. IMO’s mandate and the safety case

The issue also has a constitutional and moral dimension. The purpose of IMO, as set out in the Convention on the International Maritime Organization, is to provide machinery for cooperation among governments in the field of regulation affecting shipping and to encourage and facilitate the general adoption of the highest practicable standards in matters concerning maritime safety and efficiency of navigation. (3) The STCW Convention itself is rooted in the desire to promote safety of life and property at sea and the protection of the marine environment.

In the Maritime Professional Council’s view, that mandate should shape the approach taken to any proposal that reduces practical experience before competency certification. If a change can be shown by robust evidence to preserve or improve safety, it may be considered on its merits. But where evidence is absent, as is currently the case, caution is not obstructionism. It is being true to the Organization’s raison d’etre.

The Council therefore believes that cutting seatime further would reduce safety at sea. That conclusion is not based on nostalgia or hostility to technology. It is based on the nature of the OOW role, the clear limitations of simulator substitution, the repeated emphasis in STCW on the importance of sea service, the professional judgement of experienced mariners and educators, and the evident lack of a convincing safety case for reduction.

 

12. Conclusions and recommendations

The Maritime Professional Council concludes that the reduction in required sea service for STCW OOW candidates from 12 months to 9 months should not proceed to final approval without a much stronger and broader evidence base. On the material currently available, the proposal risks diluting a safety-focused standard that has been in place since implementation of STCW.

Sea service remains the period during which cadets learn not only navigation but responsibility, judgement, endurance, leadership, communication and hazard awareness across the whole ship. Simulation has clear benefits, but it does not reproduce the physical, social and operational realities of prolonged life and work at sea. Used properly, it should complement sea service. It should not be used as a justification for materially reducing it.

The Maritime Professional Council also considers it a serious weakness that insurers, P&I Clubs and classification societies have not had a more prominent role in testing the safety implications of this change. Their participation should be actively sought before any final decision is taken. Input should also be obtained from serving masters, who carry ultimate command responsibility and who are best placed to judge whether newly qualified officers are sufficiently seasoned for independent duty.

The Council therefore recommends that the shipping industry, national administrations and relevant professional bodies urge IMO to pause and reconsider the reduction. Any final decision should be grounded in demonstrable safety evidence. If the real pressures lie in berth shortages, weak mentoring, reduced crew numbers or excessive workload, those problems should be confronted directly. Lowering the sea service requirement is not, in the Council’s view, a safe answer to them.

In summary, maritime safety depends upon competence earned in the real operating environment. Reducing experiential training at the point of entry into operational responsibility is likely to reduce, not enhance, safety at sea.

References
[1] The Nautical Institute submission to IMO HTW 12 regarding reduction in seagoing service requirements for STCW II/1 certification.
[2] STCW Convention and Code, including the preamble and Section B-II/1.
[3] Convention on the International Maritime Organization, Article 1.