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

Memorandum by the United Kingdom Maritime Pilot's Association (P 05)



  Using figures quoted by the Department of Environment, Transport & the Regions (DETR), there are approximately 800 marine pilots in the United Kingdom of whom 10 per cent are part time.

  The United Kingdom Maritime Pilots' Association (UKMPA), formerly the United Kingdom Pilots' Association (Marine) (UKPA(M)) represents approximately 700 pilots in the UK, the majority being full time pilots. A number do fulfil a dual role, for example Harbour Master/Pilot. The UKMPA is a section of the Transport & General Workers' Union.

  The history of Pilotage has been long and complicated. Our organisation has been in existence under several titles since 1884.

  For over three centuries pilotage has been governed by numerous Pilotage Acts, culminating with the present Act, the Pilotage Act 1987. Opinions have been expressed that the 1987 Act is an inadequate ambiguous piece of legislation, in that it de-regulated Marine Pilotage in the UK, adversely we believe.

What is Pilotage?

  Article 742 of the Merchant Shipping Act 1894 defines a pilot as "any person not belonging to a ship who has the conduct thereof". A pilot brings on board a vessel local knowledge and information pertaining to the district in which he works. Our organisation considers that a pilot expedites the safe and efficient passage of a vessel to or from a port or harbour, or within a harbour during what is considered to be the most hazardous part of a vessel's voyage, often in restricted or dangerous water.

  A pilot performs an independent safety role for the protection of life, property and the environment. We consider a pilot's independent role serves the Master and his ship advantageously.

  With this background it can be seen that the role of the pilot is strongly linked to the port marine operation in the district where the pilot operates. We therefore welcome the document Modern Ports: A UK Policy, and the opportunity to comment on the paper. We echo the sentiment that our national economy needs a thriving ports industry as this in turn will mean a thriving pilotage service.

  We also consider that the importance of pilotage in the safety of our ports had been seriously neglected from the introduction of the Pilotage Act 1987 until the Review of the Pilotage Act was ordered by the present government after the grounding of the Sea Empress in 1996.

  It is stated (1.18) that it is not the government's job to run the ports' industry. We consider it is the government's job to oversee that the ports' industry is run safely and efficiently. De-regulation (1.1.10) can lead to unsafe practices).


  We agree with the content of this section and consider from a pilotage point of view that the:

    (a)  Port Marine Safety Code

    (b)  The Drafting of the Guide to Good Practice on Port Marine Operations

    (c)  Competence Standard for Port Marine Personnel, eg Pilots

  . . . do much to address the content of the Key Points.

  We are aware the proposed EU Directive on port services may have some bearing on certain aspects of points made in 1.2. but are adamant that the EU Directive would be detrimental to pilotage and consequently to safety in our ports and estuaries. There is ample competitiveness in the UK with the number and range of ports in existence.

Bigger Ships

  2.1.5  These bigger ships are often being handled by pilots in ports where the physical features have changed little over the years.


  2.3.1  We consider that it is unfair that certain European ports receive substantial state aid thus creating unfair competition with rival UK ports.

Ports and maritime infrastructure in Europe

  2.3.2  Aware that the EU published the Green Paper, Ports and Maritime Infrastructure, not much progress appears to have been achieved. The EU also authorised reports on Maritime Pilotage which was not acted upon and again on Technical Nautical Port Service on which inadequate consultation took place with European pilot services.


A new course for shipping

  2.6.8  We concur with the four aims of shipping policy as being of great importance. The UKMPA/T&G took part in shipping working group from 1997.

    From a pilotage aspect there is interaction between the four points.



  3.1.7  We welcome the decision that harbour authorities will be required to submit proper accounts. This conflicts with the proposal to abolish separate pilotage accounts. We do not believe that harbour authorities should make a profit on pilotage income, on a service which is essentially based on safety. Separate pilotage accounts must be maintained. Transparency on accounts is essential.

Board composition

  3.1.9  There should be a more logical approach to appointments to boards, for example from business and maritime backgrounds. Too often vested interests sit on a board.



  3.2.4  We believe enforcement of regulations directions and bylaws to be very important. Too often no action is taken on dangerous navigation and breaches of regulation relating to navigation.

Light dues

  3.1.14  There is an opinion that light dues are an additional burden on Shipping trading to UK ports. Alternatives should be considered.

Satellite systems

  3.2.16  We do not believe that satellite systems should be used for port navigation. Satellite systems are open to failure and error.


4.1  Safe Port Workplaces

Fewer jobs—difference work

  4.1.2  We are aware that docks are recognised as hazardous places. The UKMPA have been invited to assist the HSC in their Review of Regulations and Approved Code of Practice.

  However, we as pilots are also linked to the Maritime Coastguard Agency from the seaward side. Many accidents also occur in the operation of pilot boats and in the towage industry.

Employment Relations Act

  4.1.22  Consideration should be given to the introduction of the Working Time Directive to marine personnel in our ports, estuaries and waterways. It does not apply at present. Trade union recognition has also been difficult to obtain in some instances. Trade unions are responsible organisations and should be recognised.

Employment Agencies

  4.1.23  It is imperative that employment agencies provide properly trained personnel. Untrained personnel may become an increasing problem if the EU Directive on port services is introduced. The passport scheme would appear to be a positive step forward.

Working time directives

  4.1.28  It is noted that a separate WT Directive for seafarers will be introduced by June 2002. It must include all port marine operatives including marine pilots.

Safety on ships

  4.1.29  The content of this clause is noted on the relationship between MAIB, MCA and H&SE.


Port Marine Safety Code

  4.2.3  The UKMPA is one of the participating bodies involved in the Port Marine Safety Code. When the Review of the Pilotage Act 1987 was introduced the position of the UKMPA was that a very poor piece of legislation should be amended. In the event that this was not possible we worked in a positive way to produce a code which will go some way to nullify the deficiencies of the Act and the De-regulation which occurred with the introduction of the 1987 Act.

  We still consider that strict oversight, perhaps along the lines of a regulator, is necessary to ensure compliance with the Code.

  We also believe that at this point of time harbour authorities are not complying with their obligations on consultation (4.2.5.).

Reserve power

  4.2.8  The introduction of reserve powers for use by the Secretary of State in the event of a harbour authority failing in its duties is imperative. We do expect that those reserve powers will be forthcoming in the near future.

Good practice

  4.2.9  We await the completion of this document as a party to its production. It would be unfair to comment on the Guide prior to completion but the UKMPA expect the Guide to act as the "bible" for port marine operations.


  We are satisfied with the National Occupational Standards for Marine Pilotage produced under the guidance of BPIT.

  It is important that a creditable qualification is now established for port marine professionals such as pilots in the event that suitable applicants can no longer be obtained from Sea Service. We do believe there is some evidence (4.3.5.) of a recruitment shortage. We also consider that some sea experience is essential for port marine operatives (4.3.7.)

  It would be useful for the SmarT scheme to be extended to include port marine careers (4.3.9.)

  Little mention is made of pilotage exemption certificates (4.3.6.) and none on compulsory/non-compulsory pilotage.

  Both these aspects are very important considerations in the Safety of our ports, rivers and estuaries, and require an analytical approach. Problems are created by the inadequacy of some PEC holders, such as their command of the English language and by ships not subject to compulsory pilotage by local Directions.


  It should be noted the marine pilot carries out a Public Service role under EU Directive in reporting defective and deficient ships to the appropriate authority.

  In conclusion, the Port Marine Safety Code states that under consultation "harbour authorities must involve all those who work in and use the port and those who represent them". With this in mind the UKMPA offers its services for further consultation and assistance to the Transport Sub-Committee if so required.

N C E McKinney

Chairman of UKMPA

January 2001

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