Consultation outcome

Responses to Consultation Feedback

Updated 5 July 2023

1. Deck - Ship Stability: An Introduction

Role	Deck cadet Phase 3	Lecturer - Cadet Education	Captain	Cadet
Organisation	International Shipping Company	Nautical College	Motor Yacht	International Shipping Company
Module	Deck - Ship Stability: An Introduction	Deck - Ship Stability: An Introduction	Deck - Ship Stability: An Introduction	Deck - Ship Stability: An Introduction
Your Feedback - Outcome 1	1.9 Have never used this	“Suggestion 1 - Outcome 1 - Load Lines Please retain all current parts. One item missing is the reading of draughts. This is equally, if not more relevant to practical operations on board, but sadly is not part of the syllabus. Suggest please add this to the list of topics.”	#N/A	I feel that all of those outcomes go into more detail than what a deck officer needs to know in modern times. I don’t feel things like Archimedes principle etc are needed now, particularly as there are computer aids etc. Hydrometer use should be scrapped altogether as it is outdated.
SG 1.2 Response	Many thanks for your feedback, it has been noted.	“Many thanks for your feedback, it has been noted. This should be covered within outcome 1.7. However we can specifically require that this is covered.”	#N/A	“Many thanks for your feedback, it has been noted. While we certainly agree that electronic aids are useful tools for stability operations, the basic principles of stability and buoyancy still underly the operation of these tools and must be understood to effectively use them. With regards to hydrometers, these remain relevant, particularly for draft surveys which remain a common means of calculating cargo quantity on board cargo ships as well as dock water allowance. “
Your Feedback - Outcome 2	#N/A	“Suggestion 2 - The syllabi currently require cadets who have not even been out to sea, to learn all of these topics (which are actually the SQA OOW syllabus) within their first 5 months in phase 1. This then gets repeated in phases 3 and 5 with slight variations. This appears to be a strange and if I may say, unwise approach. It would be far better and more sensible to a) Require phase 1 and 3 cadets to just be taught simple aspects of Density, interpolation, Load lines, draughts, KBGM, TPC. b) and require phase 5 cadets to learn all these topics. Suggest divide these topics into simpler topics for phases 1 and 3, and equivalent to SQA OOW in its entirety for Phase 5, so that all colleges adopt the same uniform approach, and our cadets learn at a sensible pace.”	Adding context to GZ curves making them more relevant in practice would be beneficial	#N/A
SG 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. Phase one currently only covers the fundamentals of this topic with deeper knowledge of this topic being covered in phases three and five. “	“Many thanks for your feedback, it has been noted. We are in agreement with your suggestion and have added it to outcome 2. “	#N/A
Your Feedback - Outcome 3	#N/A	“Suggestion 3 - Please retain all topics, but please also add interpolation as a topic to be taught. Interpolation - which is what the cadets will actually use on board regularly, even as OOWs is sadly missing from the syllabi. Experience of teachers in all colleges suggests that most deck cadets find interpolation difficult, as they have not been taught this in school. Suggest add Interpolation as a separate topic”	#N/A	Take into account modern loadicators etc
SG 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. Please be advised that interpolation is already covered in the navigation mathematics module and in the foundation course. “	#N/A	“Many thanks for your feedback, it has been noted. Loading computers are already covered in this context in the cargo modules and covered to a higher level in the Management level stability module. “
Your Feedback - Outcome 4	#N/A	Please retain these topics - but please keep 4.2 for phase 5 (not phase 1 when a cadet is not even seen / been on a ship)	#N/A	Don’t go into so much detail, keep in mind loadicator programmes
SG 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. Phase one currently only covers the fundamentals of this topic with deeper knowledge of this topic being covered in phases three and five. “	#N/A	“Many thanks for your feedback, it has been noted. While we certainly agree that electronic aids are useful tools for stability operations, the basic principles of stability and buoyancy still underly the operation of these tools and must be understood to effectively use them. “
Your Feedback - Outcomes Above and Beyond	#N/A	“These are all good ideas. However, what they entail, and how this is to be delivered is not clear in these documents. Suggestion 4 - Human element factors - Suggest the UK MCA circulate a MIN notice containing examples of the same. For example, for angle of loll, the various MAIB fishing vessel investigations can be included. For GM and FSE, incidents such as the Cougar Ace can be included as part of the discussion. Suggestion 5 - Data science skills - The meaning of this term is not clear or uniformly understood by all teachers themselves. Each of us is interpreting this in our own way. Some of us feel this relates to Bloom’s taxonomy. Others are totally in the blank. Suggest that this be clarified in the next document (so that people can give feedback accordingly). Suggest that this also be explained in the final document, so that it gets applied uniformly by various maritime institutions. Suggestion 6 - Contextualised - Agree. Currently, about half our cadets train and subsequently work as OOWs on cruise ships and ro-ro ferries. There is little of the currently syllabus that they find relevant. The same is true for about 10% of our cadets who work on offshore vessels, and 10% who work on ro-ro / ferries. Barely 5-10% of the cadets end up working as cadets or OOWs on tankers, container ships, bulk and general cargo ships, which the stability and other topics seem to be focusing more towards. Hence it would be useful if the final document also explains, with some examples, how these topics can be contextualised for cruise ships, ferries and offshore vessels. This wil lhelp uniform application of this requirement across all cadet training maritime institutions across the UK. “	#N/A	I don’t feel a specific focus on Data Science skills is needed - as you’ve noted, they are already used/covered in other parts. There is danger of going in to unnecessary detail.
SG 1.2 Response	#N/A	“Many thanks for your feedback. The intention of these suggestions were to include all of these topics, where applicable to the syllabus. No areas had been identified where they were applicable within this module. However, your suggestion regarding Human Element factors is relevant and we have added the requirement to include case studies for HELM on outcomes 2.1, 2.2, 2.6 and 3.3. Please rest assured that data science will be further explained in the academic guidance documents produced as part of this process. With regards to contextualisation, we agree that different vessel types of vessels should be covered and currently they are. However, the basic principles must be covered as generally as possible at the operational level as we are training for an unlimited certificate of competency.”	#N/A	“Many thanks for your feedback, it has been noted. Please be advised that the ““Data Science Skills”” suggestion is generic across all templates but no specifics have been identified within this module. “
Your Proposed Outcome	I think applying real word examples could be better if they expanded on the contents. In example questions we are going the mass of one type of cargo. In reality we have 2, each with different mass and volume. I think teaching this will help students to understand real life cargo and stability	#N/A	#N/A	#N/A
Your Rationale for this outcome	#N/A	#N/A	#N/A	#N/A
Your Action for this outcome	#N/A	#N/A	#N/A	#N/A
SG 1.2 Response	“Many thanks for your feedback. Please may you provide clarification on this point by responding to ctand.enquiries@mcga.gov.uk as you have not provided a Rationale or Action.”	#N/A	#N/A	#N/A

2. Deck - Ship Stability: Theory and Practical Application

Role	Deck Officer	Lecturer - Cadet Education	Cadet
Organisation	International Shipping Company	Nautical College	Student
Module	Deck - Ship Stability: Theory and Practical Application	Deck - Ship Stability: Theory and Practical Application	Deck - Ship Stability: Theory and Practical Application
Your Feedback - Outcome 1	#N/A	“Since OOWs do not use loadicators, and will never really use a loadicator on board till the time they become Chief Officers, there is really no need for them to learn this. it is sufficient for them to be generally aware of the existence of loadicators. Else we will have a generation of computer software loadicator third mates and second mates who don’t know how to take a draught (which is what they need to do prior to sailing), but know how to se loadicators (which will never really be part of their work on board as cadets, third or second officers).”	#N/A
SG 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. While Chief Mates will be the main users of loadicators, there is a need on many vessels for junior officers to use and understand loading computers. While the level of detail may not need to be as in depth at officer of the watch level, an understanding of their use and interpretation of the data they output, will allow them to understand why they are taking the drafts and provide the Chief Mate with someone to cross check the vessel’s stability with. Please also note that this is a management level module, so specifically designed to take seafarers to the underpinning knowledge required for a Chief Mate and Master’s CoC.”	#N/A
Your Feedback - Outcome 2	#N/A	“2.5 - It is excessive and irrelevant to teach a cadet, 3rd officer and 2nd officer level person how to calculate damage stability. It is sufficient for them to simply be aware that flooding causes a loss of buoyancy, and generation of FSE which can be detrimental to the vessel’s stability, perhaps with a few case studies to bring context. We must keep in mind that most of our cadets have just 1-2 years experience sailing at sea, and have very very minimal practical understanding, especially since half of them have only been on cruise ships. Suggest this element be reworded to reflect familiarity, rather than calculation.”	#N/A
SG 1.2 Response	#N/A	“Many thanks for your feedback. Please also note that this is a management level module, so specifically designed to take seafarers to the underpinning knowledge required for a Chief Mate and Master’s CoC.”	#N/A
Your Feedback - Outcome 3	#N/A	“Suggest modernise through the use of models and virtual reality glasses, as most cadets have never been into tank during their entire cadet ship of 1-2 years. This will help achieve the goals of the Government of the UK and MCA.”	#N/A
SG 1.2 Response	#N/A	“Many thanks for your suggestion, it has been noted. However, this would be more appropriate in the ““Naval Architecture: Ship Construction”” module, we have included it there.”	#N/A
Your Feedback - Outcomes Above and Beyond	#N/A	“What data skills inclusion actually means remains unclear. Suggest clarify this. Are we referring to Bloom’s taxonomy? Or something else? Agree regarding the idea to contextualize learning to relate to the ships that our cadets work on. Experience and discussions with cadets suggest that most of them work on cruise ships, ro-ro vessels and offshore vessels. Since most of them do not use the concepts that are being taught (TPC on cruise ships?) suggest circulate a MIN notice or guidelines for maritime colleges to explain how these can be done.”	#N/A
SG 1.2 Response	#N/A	“Please rest assured that data science will be further explained in the academic guidance documents produced as part of this process. With regards to contextualisation, we agree that different vessel types of vessels should be covered and currently they are. However, the basic principles must be covered as generally as possible as we are training for an unlimited certificate of competency.”	#N/A
Your Proposed Outcome	“Add learning objective related to cargo loading/unloading sequence. How to formulate a cargo loading plan and carry out cargo ops whilst maintaining correct stability condition throughout as per stability information booklet, particularly in regards to stress/bending moments. Additionally, introduce cadets to stability loading computers. This they see their Chief Officers using at sea so it helps contextualise the importance of this module. Also, the importance of draught surveys - again it helps them understand why we do them. Explain why sometimes the observed draughts and calculated draughts do not match - residual deadweight etc.”	#N/A	The use and understanding of ship stability software is needed
Your Rationale for this outcome	It helps cadets link the learning to what they see onboard. All stability nowadays is via a loading computer. Absolutely, they need to learn how to do the manual calculations but showing them how it is actually done at sea will help them see why this module is so important.	#N/A	Practical application
Your Action for this outcome	“Add learning objectives of: Stability computers, cargo loading/unloading sequences, draught surveys etc.”	#N/A	The use of stability software by the students
SG 1.2 Response	“Many thanks for your feedback, it has been noted. We are in agreement with your suggestion. However, we feel this has already been covered through outcome 1 and our suggestion to include the practical application of theoretical topics through the use of stability software.”	#N/A	“Many thanks for your feedback, it has been noted. We are in agreement with your suggestion. However, we feel this has already been covered through outcome 1 and our suggestion to include the practical application of theoretical topics through the use of stability software.”
Your Proposed Outcome	Maybe touch on shoreside assistance - most ships now sign up to classification societies stability response service. E.g. Lloyds Register ERS (Emergency Response Service). This could form part of the bilging/damage stability lectures.	#N/A	#N/A
Your Rationale for this outcome	It gives them an understanding of the expert shoreside assistance that is available to ships. Most ships nowadays send their pre-departure stability conditions ashore for these emergency responses services - cadets would then have background knowledge on this.	#N/A	#N/A
Your Action for this outcome	Incorporate shoreside stability assistance services into damage stability/bilging lessons.	#N/A	#N/A
SG 1.2 Response	“Many thanks for your feedback, it has been noted. We are in agreement with your suggestion and have included it within outcomes 2.5.”	#N/A	#N/A

3. Deck - Naval Architecture: Ship Construction

Role	Lecturer	Deck officer cadet	Captain	Lecturer - Cadet Education	Naval Architect
Organisation	Nautical College	International Shipping Company	Motor Yacht	Nautical College	FPSO and Marine Structural Integrity Company
Module	Deck - Naval Architecture: Ship Construction	Deck - Naval Architecture: Ship Construction	Deck - Naval Architecture: Ship Construction	Deck - Naval Architecture: Ship Construction	Deck - Naval Architecture: Ship Construction
Your Feedback - Outcome 1	#N/A	Familiarity with archetaecture can only be universally applied across all ship types for damage assessment and deck weight bearing inegrity. All ship types are so different and so dissimilar from each otger that plumbing and piping systems will have to be learnt on each individual ship, if, it applies to the responsibilities of a deck officer. Often it does not.	#N/A	“1) More practical exercises should be included (example: ““View this video of a tank entry and identify the longitudinals, transverse frames, lightening holes and web frames in it””) - this is currently not mandatory - it should be made so, else the topic ends up being too theoretical without the real world connect required. 2) The use of models should be made mandatory, so that all maritime schools use models of framing. This will help enable cadets to visualise what they are being taught - especially those cadets who have not been on a ship / not been inside a tank 3) Updated books are required in the UK for these topics. The current stream of books tend to have many older concepts that are redundant, and leave out more relevant concepts that mirror current day ship construction practice. It would be useful for the government and MNTB / Maritime UK to fund the compilation and publication of these books, ideally by getting lecturers in different maritime schools to contribute one chapter each. “	Suggest you make sure structural arrangements subjected to fatigue failure are covered. Experience has shown that cracks resulting from fatigue in way of cargo hold envelope and ships hull shell has cause loss off containment of cargo holds and ballast tanks.
Sub-Group 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. While we appreciate your feedback, the overwhelming indication from the industry consultation was that this remains relevant.”	#N/A	“Many thanks for your feedback, it has been noted. We are in agreement with your suggestions 1 and 2 and believe that visual aids would improve the teaching of this module. We shall add these as suggested teaching methods on our academic guidance documents. Should you wish to pursue the creation of the resources suggested in point 3, please contact the MNTB directly.”	“Many thanks for your feedback, it has been noted. However, please be advised that the content of your suggestion is already covered in the Marine Vessels - Structures and Maintenance module”
Your Feedback - Outcome 2	#N/A	All must be modernised and issues effecting older ships made its own subject.	Included in passenger ships it would be beneficial to include basic details about motor and perhaps even sailing yachts as some are operated as class 1 passenger ships, some operate under passenger yacht (36 persons max) certification and others are still of size that require unlimited tickets. A very large portion of the global yachting fleet falling under the red ensign group and further still including countries like Panama refer to the Red Ensign Group yacht code (ref: Panama Merchant Marine Circular MMC-370) for certification of yachts under their flag.	For 2.4 - For uniformity of application, suggest that the MNTB / MCA clarify and list which ship types should be added, and provide material on these, ideally on a cadet education website maintained by the MNTB / Maritime UK.	Offshore floating platforms to be covered in specialist vessels outcome 2.5? E.g. F(P)SO typically have marine cree onboard.
Sub-Group 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. While we agree that each outcome should cover modern ship types, with reference made to older ship types as appropriate, we believe that the outcomes in their current format provide the flexibility for colleges to deliver the relevant topics as they should update their teaching content as part of their own continuous professional development, as stated in the college’s quality management system. “	“Many thanks for your feedback, it has been noted. If a yacht is operating as a class 1 passenger vessel, it would have to comply with passengers ship construction requirements and, as such, would not need additional content from what is already covered.”	“Many thanks for your feedback, it has been noted. However, this would not be relevant to this syllabus review. Should you wish to pursue the creation of these resources, please contact the MNTB directly. In addition, all kinds of merchant vessels should be covered within this outcome.”	“Many thanks for your feedback, it has been noted. However, this topic would not need cover F(P)SOs as their construction is covered in outcome 2.1. “
Your Feedback - Outcome 3	#N/A	Modernise all	#N/A	“For outcome 3 - Rather than the current practice of discussing these subjects even before a cadet has set foot on a ship, suggest that these are taught in Phases 3 and 5 only. The stability and stress software exposure should be in phase 5, as cadets will have the 12-18 months seatime to begin to understand and appreciate its relevance.”	#N/A
Sub-Group 1.2 Response	#N/A	Many thanks for your feedback, it has been noted.	#N/A	“Many thanks for your feedback, it has been noted. While there is a basic introduction to the terminology surrounding ship construction in phase 1 of the cadetship, this module would already be taught in phase 3. We believe that covering stability software within phase 3 would be the appropriate time. “	#N/A
Your Feedback - Outcomes Above and Beyond	#N/A	Agree with all. Human element is too ambigious. Put more effort in to antidiscrimination and reduction of rantionalised judgment of other nations working standards.	#N/A	“1) It is overkill to expect cadets who have barely spent 12-18 months to understand or appreciate these. As it is, our seatime requirements have got highly diluted, with cadets working barely 12 to 18 months at sea and then becoming third officers. Hence the second and third items - human element and data science - are best kept for cadets to learn after they have spent 3-4 years at sea. 2) Discussions with cadets who have become officers, especially those in the non-cruise sector tell us that they feel they should have had longer experience at sea before getting their second mates license. Most of them feel 24 months seatime would be better than the current 12-18 months seatime. 3) Many cadets and officers also feel that it would be better if cadets also give the SQA exams, as it helps them learn far more (due to the motivational factor of SQA exams) and become higher quality officers with knowledge levels equivalent of officers from other nationalities.”	#N/A
Sub-Group 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. To clarify, we have noted throughout the syllabus where and how Human Element Factors may be included. However, there were no relevant outcomes within this module. In addition, antidiscrimination and awareness of other nations working standards are covered in the management modules. “	#N/A	“Many thanks for your feedback, it has been noted. The Cadet programme has been designed to educate seafarers to the management level and, as such, we would need to cover these topics at the Cadetship level. In addition, we believe that Cadets need to learn these skills at an operational level so that they can implement it in their work and appreciate the work of those at a management level. While we appreciate your comments 2 and 3, they are not relevant to this syllabus review. However, written examination requirements will be reviewed later in the process.”	#N/A
Your Proposed Outcome	including more green shipping topics	Modernisation is highly necessary. Context of why nav arc is required. Knowledge of globalisation ship constructing and ship construction workers standards should be considered.	#N/A	“1) Suggest remove human error and data science discussions from the cadet syllabus - instead, include them in chief officers syllabus. 2) Suggest keep the sea time requirement at at-least 24 months. We are currently experiencing a distressing situation of officers who have barely sailed for 12-18 months, and hence are poor in their knowledge and experience, as compared to their colleagues from other countries who tend to complete 24 months at sea before they get their second mates license. 3) Please do not replace actual seatime with simulators - the latter are a poor replacement of seatime. They are good to augment existing seatime 4) Suggest help compile and publish a text book - with inputs from lecturers from all maritiem schools - to address the comments that were written on earlier pages 5) Please do not add human element and data science at this nascent stage where the cadet is just about managing to understand what is currently listed 6) Suggest add the requirement for ship visits during training (especially for phase 1 cadets) - arranged through the ship operators who are part of Maritime UK / UK Chamber of Shipping - as half the cadets do not get to step on a dry or wet cargo ship durign cadetship due to the ownership pattern of their sponsors. “	#N/A
Your Rationale for this outcome	to meet net zero 2030 and netzero 2050	“The industry is movibg so fast and although it trends based on constants the influence of comouterisation should be included in a more indepth way in the subject. National pride leads to borderline racism in buikding and working standards on this topic.”	#N/A	As listed above and in previous pages.	#N/A
Your Action for this outcome	include topics and discussion about new technologies about zero carbon shipping	Nav arc can be used to broaden the perspective of cadets on how globalised shipping is and how difderent new tech is from old tech	#N/A	“As listed above and in previous pages. Thank you for your good work.”	#N/A
Sub-Group 1.2 Response	“Many thanks for your feedback, it has been noted. We have attempted to include green shipping topics throughout the syllabus, as appropriate. However, there were no outcomes within this module that were deemed relevant for it to be suggested. If you would like to provide a suggested area within this module where green shipping could be added, please contact ctandm.enquiries@mcga.gov.uk”	“Many thanks for your feedback, it has been noted. While we agree that modernisation is necessary in this module, and we have attempted to cover this within the module, we do not believe that we should go too in depth into ship building and shipyard workers standards as this is not relevant to the work of a Deck Officer.”	#N/A	Many thanks for your feedback, please see our responses to your previous comments.	#N/A

4. Deck - Marine Vessels - Structures and Maintenance

No feedback requiring a response was received for the module Deck - Marine Vessels - Structures and Maintenance.

5. Deck - Marine Law and Management: An Introduction

Role	Lecturer	Lecturer	Lecturer
Organisation	Nautical College	Nautical College	Nautical College
Module	Deck - Marine Law and Management: An Introduction	Deck - Marine Law and Management: An Introduction	Deck - Marine Law and Management: An Introduction
Your Feedback - Outcome 1	“Outcome 1.6 - would be better placed in Outcome 2. Describe the source and content of international legislation relating to human rights of seafarers “	#N/A	“Outcome 1 - Avoid using ““Explain””. Why do candidates need to know this content and how will they use it in real life? What do they actually need to be able to do? If look at Outcome 2, I have commented on order of delivery. The content of Outcomes 1 and 2 I believe requires significant re work and in doing this, coming up with new headers for outcomes. Outcome 1 may become ““Interpret and apply international regulations to a range of shipboard scenarios”” while Outcome 2 may become “” Analyse the roles and responsibilities of, and relationships between, international and national legislative bodies, Flag and Port State authorities and Industry bodies in ensuring vessels remain compliant with the law””. Outcomes 1.1 and 1.2 - It is crucial the focus is on STCW requirements and the future role of a 3rd or 2nd Deck Officer. Things like an in depth knowledge of the UK legal system (criminal and common law and the court system) are not required/nor particularly useful for the majority who will sail on non-UK flagged vessels nor for those who do sail on Uk flag vessels as 3rd/2nd Officer. A general understanding of the UK legal system is of benefit when explaining the penalty section related to MS Regulations and to ensure an understanding of the consequences in one Flag State of not complying with legislation (in terms of fines and imprisonment). Below I have marked what is relevant to candidate understanding of international and national legislation in order for them to be able to apply knowledge and understanding at Operational level. - Fundamental doctrines — Rule of Law, Separation of powers - not needed - The main bodies of the English legal system and their function - not needed - Primary and secondary legislation including statutory interpretation - yes keep and can advise that teaching UK system though other Flag State systems will vary and this is one example - Explain the basis of common law including the doctrine of precedent - basic understanding of common law useful though doctrines not necessary - Hierarchy of the courts - basic knowledge of criminal courts helps understand penalty section of MS Regs - Statutory and common law offences/actions - Basic understanding can help support delivery of MS penalty section - Criminal law definition including levels of crime and punishments - Basic understanding can help support delivery of MS Regs - Civil law actions: Contract and Tort The old Outcome 1.3 has been completely removed though is crucial. It requires the following to be covered: - International treaty/convention making bodies - Implementation of a convention from consultation paper - Amendment procedures - National implementation Suggest (through successful implementation at Glasgow the last 5 years) that the first 3 points become Outcome 1.1 and the 4th point is moved into a new Outcome 2. Outcome 1.5 would fit naturally in to the new 1.1 or follow as 1.2. It is covered anyway during delivery of conventions so not sure why it needs a separate outcome but perhaps this has been open to interpretation so not everyone teaches it. 1.4 fits naturally with National implementation so should go wherever that goes. Again it’s a minor point that can be covered but not sure needs it’s own outcome. The new outcome 1.3 is the old Outcome 1.4 which requires the following to be covered. Suggestions (based on current successful delivery approach at Glasgow) ♦ Primary and secondary legislation - move to after National Implementation (see Outcome 2 for order of entire Outcome 1 and 2) ♦ Convention provisions — regulations and codes - should be delivered after introduction to IMO/ILO and understanding of conventions and as intro to IMO/ILO conventions and codes ♦ Flag state recommended practices and guides - deliver In Outcome 2 after National legislation ♦ Industry recommendations - deliver in Outcome 2 after Flag State role Outcome 1.6 really important though would sit with delivery of MLC which is not currently included in this unit. Suggest it goes with delivery of the other conventions. Also can bring in with delivery of LO3 SASH and authority and assertiveness.”
Sub-Group 1.2 Response	“Many thanks for your feedback. Our rationale for putting it in outcome 1 is to ensure that the differing international requirements are considered while reviewing the onboard practice. “	#N/A	“Many thanks for your feedback. We appreciate your ideas to amend this outcome and wider module. We will be in touch separately to discuss your amendments further. An updated module will be published on the consultation page following this discussion. “
Your Feedback - Outcome 2	“Outcome 2.3 BoL comes under the Business element of Shipmasters Law and Business Outcome 2.6 Not required - this is a vast and intricate amount of information. Outcome 3, covering management principles and techniques, should be able to allow candidates to have an understanding of senior management decision making and enlighten them about their own.”	#N/A	“Outcome 2 - recommend that the majority of the content of this unit is delivered first (before current Outcome 1 content) starting with where International legislation comes from (IMO/ILO) and principal conventions and codes. Once candidates have an understanding of this, the natural progression is to show how it’s given the force of law in Flag States using the UK system as an example with primary and secondary legislation. Candidates can be shown examples of how international legislation they have learned about is transposed into UK law, e.g. LSA Code to MS (LSA Code) Regulations. This could be the point where we introduce the UK criminal/court system using examples of fines/sentences within the Penalty section of regulations to illustrate the potential consequences of non-compliance and help candidates understand their responsibility as 3rd/2nd Officers in terms of ensuring compliance with the law. From this point we can naturally move on to the role of the Flag State including their responsibility to keep those under their Flag up to date with changes to legislation through M-Notices and support understanding and application of legislation through Flag State Codes. From there can move on to Industry publications supporting vessels in compliance with law. Outcome 2. The term ““Describe”” used in this outcome results in shallow learning. Candidates should be able to ““Demonstrate knowledge and understanding by applying the regulations and guidance””, e.g. when assessing, rather than ““Describe MARPOL Annex I content”” or such like, ““You are the 3rd Officer on the Bridge of when you receive a call from the ECR to discharge oily residues. They inform you that the oily water separator is in use with alarm and auto-stop, and the oil content without dilution is < 15ppm. You look at the chart and ascertain that you are inside an Annex I Special Area. Your current speed is 15kts””. State whether you are ok to discharge or not. Justify your decision by stating the regulations and showing which ones are met/not met””. This question prompts deeper understanding and is aligned to real life application. Recommend scenario based questions for all aspects of this assessment. 2.1 Safety and environmental should be split into separate outcomes (as it was before) as it’s huge area to cover and essential candidates are tested on both SOLAS and related codes including ISM, ISPS, LSA and FSS as well as application of BWM and MARPOL conventions. 2.1 Perhaps it would be advantageous to be specific about which conventions and codes the unit covers. I imagine it’s been worded this way to make it easier for colleges to up date dependant on changes in legislation, however, the reality is it’s open to interpretation and one lecturer or one college might cover SOLAS and MARPOL while another covers a huge range of conventions. Suggest a decision is made using the OOW Orals syllabus to ensure we are not covering too little or too much. 2.4 This needs to tie in with Flag State recommended practices and guides currently in new Outcome 1.3 2.6 Does this need an entire outcome and assessed question? Can this be incorporated into an outcome? Think it’s important we are always aiming to cover what is required for OOW level in sufficient detail which I believe is more focus and time spent on understanding who all the different bodies are involved in legislation in industry, what they develop/implement/enforce, a good understanding of the relevant conventions/codes/legislation and how to apply in role, understanding of consequences of not complying (fines/imprisonment/detained/reputational damage/accidents…), and record-keeping. This outcome could fit within as one point rather than an outcome.”
SG 1.2 Response	“Many thanks for your feedback, it has been noted. Our recommendation in outcome 2.3 was not to include the details of a Bill of Lading but instead to highlight the digitalisation of records, with an electronic BoL as an example. The indication from the working group and industry feedback is that outcome 2.6 should be covered. While the communication of this decision making would be covered in outcome 3, it is important for officers to understand the impact of legal responsibilities and commercial pressures on a Master’s decision making. Covering this topic at this stage will help Officer and Master understand the decision making process without having to explicitly discuss it on every occasion a decision is to be made. “	#N/A	“Many thanks for your feedback. We appreciate your ideas to amend this outcome and wider module. We will be in touch separately to discuss your amendments further. An updated module will be published on the consultation page following this discussion. “
Your Feedback - Outcome 3	#N/A	#N/A	“3.1 It might be worth bring in this outcome earlier in the unit - candidates need to understand who people are on board and ashore (and ship/shore interface) before covering STCW levels of responsibility, DPA, Company Security Officer, Ship Security Officer, Safety Officer, all of which are covered through delivery of ISM Code, ISPS Code and COSWP. Candidates who complete this unit in Phase 3 start it with the shipboard structure knowledge and usually minimal shore knowledge while those who complete it in Phase 1 are usually unfamiliar with the terms ETO, Able Seafarer Deck, Chief Mate and so on. 3.2 and 3.3 Important candidates understand difference between management and leadership and are familiar with leadership styles - authoritarian, democratic, laissez-faire, consultative - and that these can all be used by the same person and suit different situations. Some people use them in the wrong situation, e.g., authoritarian in a safety committee meeting. Links can be made here to the new content in 3.3 - impact of style on getting job done, motivating people etc. Exercises can draw on previous experience as well as scenario-based questions where can analyse whether style used is appropriate or not and justify. Promoting shared mental models as a leader would be good to add within these outcomes (through toolbox talk and understanding of objectives of job and each other’s roles) as would authority and assertiveness using industry accident reports to elicit who had authority and who needed to be assertive to speak up about safety concerns. 3.4 Suggest re-wording this outcome with a focus on teaching the various human factor safety elements through risk assessment. One way of contextualising the content for this outcome - effective communications, managing fatigue, stress, conflict, lack of experience, complacency etc etc - is through risk assessment hazard identification, preventative/control measures and analysis of risk. In class, candidates can analyse situations like pilot boarding at sea or crew joining a vessel at anchor (videos for 1st phase cadets with no sea experience) and consider the human factor hazards associated with it which can be considered hazards, then consider preventative measures. The process not only brings in COSWP risk assessment guidance, it also gets them thinking ahead and thinking safely and shows real life application. Assessment of this outcome can be through analysis of risk. Wording of outcome could be ““Analyse risk to improve safety onboard in respect of human factors””. 3.5 and 3.6 Excellent to see these included. Important that we avoid ““Awareness”” in the outcome descriptions as most people are aware, they need to learn methods to address these issues. Assessing awareness will likely lead to surface learning. Suggest look at covering identifying or recognising poor behaviour on board (in terms of SASH and bullying and harassment), signs to look out for that someone is being bullied, harassed or worse on board, responsibility to speak up, language for speaking up, allyship, who to speak to, potential impact on victims when no-one speaks up.”
SG 1.2 Response	#N/A	#N/A	“Many thanks for your feedback. We appreciate your ideas to amend this outcome and wider module. We will be in touch separately to discuss your amendments further. An updated module will be published on the consultation page following this discussion. “
Your Feedback - Outcomes Above and Beyond	#N/A	#N/A	“Number 1 - it is crucial we keep this unit focus on Marine Law and Management. It is already a challenge to deliver the content well within the allotted timeframe. More hours are already needed to do justice to all the legislation and with the addition of the really important topics of SASH, it will be a struggle to do it all justice. I would suggest the broadening of understanding of the maritime industry is best suited elsewhere and is already covered in Maritime Industries unit. Number 2 - wholeheartedly agree. I have included suggestions throughout and have many more. Glasgow has been delivering this unit in a contextualised manner for the last 5 years. Number 3 - I don’t believe creating risk assessments is covered in the OOW Deck Syllabus and it fits naturally into delivery of the safety culture part of LO3 for delivery. It’s a great way of teaching human element and ensuring candidates do not only focus on the technical aspects of a job. Again, it could do with more hours. Perhaps this needs to be a 2 credit unit? Number 4 - not quite sure I understand what this means so what I say might not be relevant. If this means candidates should be analysing scenarios, assessing risk and applying regulations as opposed to regurgitating materials then absolutely. In the past, I have attempted to ensure this is part of their learning and assessment though I have found the barrier is actually the language used in the unit descriptor. Terms like ““Describe”” and ““Explain”” tend to result in surface knowledge and assessment which requires memorising with no application. When the unit descriptor is revised it is crucial that each outcome and also evidence criteria requires the candidate to provide evidence of their ability to apply/use their knowledge and understanding in real-life scenarios and tasks. Glasgow has many examples of how this can be done if needed. I ask that whoever writes the descriptor takes great care to ensure we are assessing candidates on what they actually need to be able to do in the real world.”
SG 1.2 Response	#N/A	#N/A	“Many thanks for your feedback. We appreciate your ideas to amend this outcome and wider module. We will be in touch separately to discuss your amendments further. An updated module will be published on the consultation page following this discussion. “
Your Proposed Outcome	#N/A	Ensure that the subject is taught with relevance to OOW. Include for non UK flagged ships	“Glasgow has been delivering LO1 and LO2 in a holistic manner for the last 5 years and has incorporated an activity based approach to learning using real-life scenarios and application of regulations/knowledge and understanding. Candidates are assessed through scenario-based questioning. I have delivered pre this change and post, and student and lecturer feedback on the unit has been very positive, plus the base of knowledge and understanding cadets have when they reach their MCA Oral prep has significantly improved. As well as contextualising content, the order of delivery of content within LO1 and 2 has been significantly changed - not just the order of the outcomes - to follow what we considered to be a logical order. While lecturers always have the flexibility to re-order content, it may help other colleges to let them know what is working in Glasgow and to reflect this order in the unit descriptor (teaching from the international where everything comes from, then to the national then Flag State then industry). It crucial Blooms taxonomy is considered in the language used in the unit descriptor and that if we want candidates to be able to apply knowledge and understanding to their future roles in industry then we need to teach and assess them in this way and use apply, analyse, justify rather than describe and explain. The unit descriptor needs to be clear on the legislation to be covered. The equivalent engine unit ““Marine Legislation and Leadership”” specifies which conventions and codes to cover. It doesn’t currently cover enough in terms of what the Engineers require for EOOW exams, however, there can be no debate over what legislation to deliver and asses. Finally, in determining what should be included in this unit, it is crucial the focus is on STCW requirements and the future role of a 3rd or 2nd Deck Officer. Things like an in depth knowledge of the UK legal system (criminal and common law and the court system) are not required/nor particularly useful for the majority who will sail on non-UK flagged vessels. A general understanding of the UK legal system is of benefit when explaining the penalty section related to MS Regulations and to ensure an understanding of the consequences in one Flag State of not complying with legislation (in terms of fines and imprisonment).”
Your Rationale for this outcome	#N/A	Majority of Cadets will sail on NON UK Flagged Ships therefore subject needs to incorporate this	Have explained this within previous section.
Your Action for this outcome	#N/A	Update Syllabus	Have explained in previous section.
SG 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. We believe we have already covered this through the addition of Outcome 1.4 ““1.4: Awareness of legal and practical implications of working on a foreign flagged vessel.”””	“Many thanks for your feedback. We appreciate your ideas to amend this outcome and wider module. We will be in touch separately to discuss your amendments further. An updated module will be published on the consultation page following this discussion. “

6. Deck - Shipmaster’s Law and Business

Role	Lecturer	Lecturer	Marine Assurance Management O&M
Organisation	Nautical College	Nautical College	Renewables Company
Module	Deck - Shipmaster’s Law and Business	Deck - Shipmaster’s Law and Business	Deck - Shipmaster’s Law and Business
Your Feedback - Outcome 1	Outcome 1.3 - should be contained with Outcome 1.4	#N/A	#N/A
SG 1.2 Response	“Many thanks for your feedback, it has been noted. While the role of Flag State and Port State legislation and Classification Societies are interlinked, and we have suggested that this link should be covered in Outcome 1.3 in our suggested action, the remit of Classification Societies is wider than their interaction with Flag and Port State legislation. As such, they are required to be covered in their own sub-outcome.”	#N/A	#N/A
Your Feedback - Outcome 2	#N/A	#N/A	#N/A
SG 1.2 Response	#N/A	#N/A	#N/A
Your Feedback - Outcome 3	#N/A	#N/A	#N/A
SG 1.2 Response	#N/A	#N/A	#N/A
Your Feedback - Outcome 4	Outcome 4.6 - I disagree with adding an outcome in response to a geo-political situation which is a contested topic between the UK and neighbouring States. I would suggest that this is added as a topic to Outcome 1 where UNCLOS is the governing legislation for search and rescue/migrants.	#N/A	#N/A
SG 1.2 Response	“Many thanks for your feedback, it has been noted. The rationale to add this sub-outcome is not based purely on the UK’s geo-political situation, this is a situation that is becoming more prominent on a global scale. In addition, we believe that this outcome is appropriately placed in the module as it is sufficiently relevant to standalone as an outcome and training centres have the flexibility to link it to outcome 1 as appropriate.”	#N/A	#N/A
Your Feedback - Outcomes Above and Beyond	#N/A	#N/A	#N/A
SG 1.2 Response	#N/A	#N/A	#N/A
Your Proposed Outcome	#N/A	“Include NON UK Flagged Ships Make subject more relevant for Cadets with limited Sea Time “	For 1.3, including the roles of industry bodies such as IMCA, OCIMF and G+.
Your Rationale for this outcome	#N/A	Majority of Cadets have only 6 months sea time and find it difficult to relate subject to ship board life. Very few cadets sail on UK Flagged ships	As Flag/Port State and RO regulations aim for the minimum safety requirements, industry bodies enhance these rules and add additional, industry specific requirements.
Your Action for this outcome	#N/A	Modernise Course Resources	Add to the sylabus
SG 1.2 Response	#N/A	“Many thanks for your feedback, it has been noted. While much of this module covers international regulations, the UK as a signatory will implement these into UK legislation. We believe that this is the appropriate level of information. It would be unrealistic to cover multiple countries specific legislation. However, UK legislative interaction with Non-UK Flagged vessels would be covered in the normal context of this module. The UK uses an integrated model of education and training and, as such, requires Cadets to mix their academic learning and shipboard experience to fully contextualise their learning.”	“Many thanks for your feedback, it has been noted We have added these suggestions as examples of ““sources of further guidance””. Though we have replaced G+ with CDI to represent the unlimited sector.”

7. Deck - Shipboard Management

Role	Lecturer - Deck	Lecturer	Captain
Organisation	Nautical College	Nautical College	Motor Yacht
Module	Deck - Shipboard Management	Deck - Shipboard Management	Deck - Shipboard Management
Your Feedback - Outcome 1	I agree with all recommendations. It is currently only a 1 credit ( 40 nominal hours ) for the HND awarded by the SQA. The addition of the extra vital material means the credit value should be looked at and increased to 1.5 credits. To ensure that it is taught properly alongside existing content and there is enough time to deliver it.	#N/A	#N/A
SG 1.2 Response	“Many thanks for your feedback, it has been noted. Please be advised that all changes made will be communicated to and assessed by the SQA to ensure they are still credited appropriately.”	#N/A	#N/A
Your Feedback - Outcome 2	#N/A	#N/A	my cadetship was from 2004-2007. In all honesty i do not remember this unit so maybe it is new and therefore my comment is not relevant however it has existed for that time it must surely need updating to be relevant. As a small company that i work for there is very little support in procurement and having more knowledge in budgeting and finance would be immensely beneficial, albeit at the mates level and above rather than cadet level.
SG 1.2 Response	#N/A	#N/A	“Many thanks for your feedback, it has been noted. Please note that we have suggested to add ““covers cost codes, forecasting, basic book balancing, how to use excel as a budgeting and cost tracking tool and, awareness of other budgeting tools.”” into this outcome. In addition, this is a management level topic and, as such is teaching to a Chief Mate/ Master level. Some Cadetships cover all education up to Chief Mate/ Master level, such as Foundation Degrees. “
Your Feedback - Outcome 3	See comments from outcome 2. The extra suggestions are very valid, but to be done justice will require an overhaul of the credit value and delivery time from the SQA for this subject.	Outcome 3.1 - rationale is to remove due to already being covered in Shipmasters Law. Same rationale has not been applied to Outcome 1.4 and 1.5 which has been proposed to be added to Shipmasters Law and Shipboard Management.	#N/A
SG 1.2 Response	Many thanks for your feedback, please refer to our response to your comment on outcome 1 regarding SQA credits.	“Many thanks for your feedback. While we have suggested to include SASH and Psychological Safety within both this module and the Marine Law and Management module, they have been recommended to be taught to different levels. Marine Law and Management would cover an awareness of these topics (operational level), whereas this module would cover the methods to comply with the requirements and ensure psychological safety (management level). However, seafarer employment legislation is being taught to a management level in both modules and is, therefore, only required in one. “	#N/A
Your Feedback - Outcomes Above and Beyond	“For the last statement. That is a generic skill and not just relevant to shipboard management. The skills of data collation, analysis and presentation are important. But they should be looked at in a separate subject. I would suggest a revision of the ITAS ( Information Technology and Applications ) subject. I feel it would make shipboard management to unwieldy a subject to deliver otherwise. Regarding suicide awareness and mental health and ED&I, absolutely it needs to be taught to cadets and to chief mate candidates as potential managers . But I believe this should be in a separate or existing 2 tiered STCW short course ( similar to the structure of, or even included in in HELM (O) and HELM (M) ) because all seafarers need an awareness of it and managers need further awareness of how to deal with it ( signposting to help etc) . There is already a section on counselling / support in learning outcome one. However echoing previous comments, this subject with all the proposals, I think will be too unwieldy to deliver properly and in the allocated single credit hours. I am a very firm advocate for its inclusion within the overall training though.”	#N/A	#N/A
SG 1.2 Response	“Many thanks for your feedback, it has been noted. Please note that the ““Data Science Skills”” suggestion is generic throughout the syllabus as we have made suggestions to include this topic in many modules. While we agree it would not be relevant for many of the outcomes within this module, it certainly would be relevant to highlight the use of these skills in outcome 2 when looking at budgetary control. Our suggestion regarding Seafarer Wellbeing, Suicide Awareness, Equality, Diversity and Inclusion would introduce a new outcome to this module, which would then be reviewed by the SQA to credit the module appropriately. In addition, we feel that it does not fit into a short course as appropriately as it is a topic that will require further research and evaluation from the Cadet and would, as such, be more appropriate within the Cadetship ““long course””. “	#N/A	#N/A