Memorandum by NUMAST (P 17)
UK PORTS INQUIRY
NUMAST welcomes the Transport Sub-committee's
decision to conduct an inquiry into UK ports policy. For an island
nation, depending on ships and the sea for the carriage of more
than 95 per cent of its international trade, the importance of
having safe, effective, technologically advanced ports playing
an integral role in a truly integrated transport policy cannot
It is fair to say that ports and related policy
issues have suffered some considerable neglect in recent decades.
The publication in December 2000 of Modern Ports policy
paper is a welcome, but long overdue, attempt to define new objectives
and new standards.
NUMAST believes, therefore, that it is both
timely and appropriate that the Sub-committee has decided to inquire
into whether the policy proposals are adequate to overcome some
of the difficulties and problems that presently affect safety
and efficiency in UK ports.
1. What contribution such ports make to the
economy of the United Kingdom
Efficient and economic port movements are essential
to the rapid and effective movement of both freight and passengers
in and out of the UK. At a time when national, European and international
transport policies are having an increasingly marked influence
upon the UK's maritime infrastructure, NUMAST believes that the
role of shipping could be enhanced through improvements at ports
and in related infrastructure, therefore providing additional
economic and environmental benefits.
Whilst the Modern Ports policy document states
that "it is not government's job to run the ports industry",
there are crucial issues to be addressed on how ports can be operated
in the public (regional and national) interest, with strategic
and planned investment and development.
There can be no doubt that ports play an inherent
role in the economic and strategic well-being of the UK. Despite
the opening of the Channel Tunnel, more than 95 per cent (by weight)
of the UK's international trade is still carried by sea and some
22 per cent of goods moved within the UK in 1999 went by water
transport. In addition, there were almost 32 million international
sea passenger journeys through UK ports in 1999 and 38.5 million
passengers carried on domestic ferry journeys.
The crucial role of UK ports is certain to continue
well into the 21st century. World seaborne trade has increased
for the past 15 consecutive years, and looks set to remain on
an upwards trend for the foreseeable future. Ships remain unmatched
as a means of transporting large volumes of cargo, and passengers,
at relatively low cost and with relatively little damage to the
environment. In addition, new ships types and technology are raising
the prospects of maritime transport being able to take a greater
share of cargoes currently carried by airfreight or by road.
As the most recent UNCTAD review of maritime
transport points out, pressure is being exerted to reduce port
costs and to provide services for a new generation of "mega-vessels".
These factors are accelerating the development of transhipment
hubs and feeder portsall of which require substantial investment
in infrastructure and extremely efficient intermodal connections.
The need for attention to be paid to the performance
of UK ports and their position within an integrated transport
policy is all the more urgent given the way in which other European
countries are developing initiatives in this area. UK ports could
become relatively uncompetitive and "user-unfriendly"
if they fail to match the pace of change elsewhere in Europe,
particularly at a time of increased globalisation and consolidation
within maritime markets. As an island nation, our import and export
costs could rise significantly were the UK to become marginalized
as trends towards new shipping alliances and globalised freighting
strategies see the emergence of new port patterns. Reliance on
transhipment and feeder services would reduce economies of scale
and add to the volume of HGV traffic.
It is therefore essential that clear policies
and objectives are in place for ensuring that the UK remains a
key player in these broader regional and international developments.
The expansion of the existing Freight Facilities Grant Scheme
to provide more support to innovative projects to encourage more
freight to be carried by shipping should be a central platform
of such an approach. Clear national targets should be in place
to identify and develop the ports and associated infrastructure
that will be required to keep pace with changing trading patterns
and operating practices.
NUMAST is concerned that the recent sale of
the south coast port of Newhaven to French interests is an indication
of the greater emphasis placed by other governments on the importance
of ports and waterborne transport. As we write this evidence,
there are reports that Boulogne's Chamber of Commerce is considering
a similar bid for the port of Folkestone. The regional authorities
in France appear to have a strong desire to re-launch or preserve
closed or threatened ferry services, and recognise the employment
and economic benefits that can flow from such interventions. Similarly,
the work now underway in the port of Amsterdam for a new "indented
berth" containership terminal, capable of handling up to
300 container moves an hour, is just one example of the scale
of the competitive pressures facing the UK.
Similarly, issues such as light dues and port
chargeswhich could act as an inhibitor upon the development
of coastal shipping and related environmental benefits, for instancecannot
be excluded from a consideration of broader national policy issues.
There are strong arguments to support the case
that such charges should be fully inclusive (to cover the costs
of handling and disposing of ships' waste, for example, to discourage
the dumping of waste at sea) or possibly restructured in a way
in which all "users" pay for the benefits they receive.
The possibility of the UK being classified as a "single port"
in respect of light dues could bring benefits to "multi-users"
(such as coastal shipping). In any event, these charges must be
seen in the context of other European ports benefiting from state
funding or alternative arrangements that may put UK ports at a
2. What problems and opportunities currently
face such ports, particularly with respect to co-operation with
each other, safety, the environment, and regulation?
The Modern Ports document notes the deregulation
that has affected the UK ports industry over the past two decades.
NUMAST is concerned at the impact this has had, most notably in
terms of safety. We are particularly disturbed that these trends
have come at a time when increasing ship size and sophistication,
as well as a growing volume of hazardous and potentially environmentally
devastating cargoes, have emphasised the need for an ingrained
safety culture and defined safety management systems and procedures,
supported by state of the art technology. Advances in shipboard
systems and electronics, for example, are now creating unprecedented
opportunities to develop vessel traffic servicesyet significant
investment is required in shoreside infrastructure and training,
and in a highly cost-competitive environment such expenditure
may be questioned.
The statistics show that docks and harbour areas
are extremely dangerous, with an injuries rate four times higher
than the all-industry average and even higher than deep coal mining.
The need for ships and seafarers to have reliable and efficient
safety support systems is emphasised by the fact that navigation
in port and harbour areas is inherently dangerous, with busy traffic,
shallow waters and restricted manoeuvring space all creating potential
problems. This is underlined by an international study and suggested
that 90 per cent of shipping accidents occur in restricted or
pilotage waters. The cutbacks in crewing levels and the overall
reduction in the standards of foreign shipping using UK waters
add to the need for high standard shoreside vessel traffic support
and pilotage systems.
With no evidence that accident rates are falling,
urgent action is needed. NUMAST believes that many port and harbour
authorities are failing to ensure an adequate level of safetynot
only for dock workers, but also for crew members transiting between
the ship and the dock entrance. We believe that excessive competitive
pressures, combined with a lack of adequate resources and the
unwillingness of senior managers to adopt a "safety culture"
lie behind these statistics.
While new technologies and containerisation
have led to significant automation of cargo handling, there are
considerable grounds for concern over the safety of such operations.
As an illustration of the hazards that can be generated, it should
be noted that in 1998 the International Maritime Organisation
issued a circular to member states on the subject of the safety
of container securing operations after a number of fatal accidents
to crew and dock workers during securing and unsecuring work.
In addition, the European Commission consultations on sea ports
and maritime infrastructure have underlined the need for a harmonised
approach to prevent unfair competition from a lack of uniform
application of safety and environmental rules. In this connection,
NUMAST would urge the Committee to examine the International Transport
Workers' Federation proposal for the production of health and
safety manuals for national port industries, containing guidelines
on the implementation of IMO and ILO Conventions through national
legislation and regulation.
The use of contract labour has exacerbated the
situation, even through there is a clear need to ensure that dock
workers are properly trained. In addition, the British Port Industry
Training Board is dominated by the employers. Ideally, its structure
should be balanced and tripartite, with a fair composition of
employer and employee representatives and educationalists and
NUMAST believes the ports industry has not devoted
sufficient investment in training and that it will suffer profoundly
over the next few decades unless urgent action is taken to address
the problems posed by the growing shortage of skilled and experienced
UK seafarers. Maritime experience and knowledge is essential for
a wide range of safety critical positions, including vessel traffic
services, pilotage, harbour masters and ship surveying and inspection.
At present, UK officer cadet training is barely one-third the
level agreed necessary to meet future seagoing and shore-based
demand and the international shortage of officers is forecast
to grow to at least 46,000 by 2010. There is therefore a defined
need for shore-based employers to "invest" in the seagoing
skills they require to discharge their responsibilities for safe
and efficient port operationsparticularly at a time when
there is a growing emphasis on the development of shore-based
support services for shipping operations. Ports need to make a
contribution to the national maritime skills pooleither
through involvement in the sponsorship of cadets through the SMarT
training scheme, or through the Maritime Training Trust.
NUMAST has welcomed and provided practical support
to the development of the UK's new Port Marine Safety Code and
we hope this will result in significant improvements. The Sea
Empress disaster in 1996 highlighted profound and fundamental
problems in safety in port areasmany of which could be
linked to the deregulatory pressures of the 1980s and the fragmented
and decentralised nature of UK port operations.
The Code sets positive targets for the development
of greater accountability and transparency within port and harbour
safety systems, not least through the introduction of requirements
for the publication and review of risk management policies.
The introduction of new national occupational
standardsmost notably in the area of pilotageshould
help to address some of the shortcomings identified by the Sea
Empress disaster. NUMAST has long been concerned that large users
may exert economic pressures on ports and the issue of Pilotage
Exemption Certificates was one example of the potential for such
problems to developparticularly when there was some evidence
to suggest that such certificates had been issued to people with
insufficient experience and/or inadequate English language skills.
Whilst the Code is therefore very welcome, NUMAST
is keen to stress to the Transport Committee its concern about
the need to ensure adequate resources are in place to deliver
its laudable objectives. Without clear and effective enforcement
and policing procedures, backed up by the necessary staffing and
resources, NUMAST is concerned that the aims may not be met. Valid
questions may already be raised over the enforcement and implementation
of oil spill contingency plans, and the Port Marine Safety Code
represents an additionally high workload responsibility for the
The mechanisms of Port State Control are an
example of the need to provide proper back-up to the Port Marine
Safety Code. With overwhelming evidence of serious safety problems
on a significant proportion of the foreign shipping using UK waters
(around 70 per cent of ships found to have defects and around
7 per cent being found to be unseaworthy), effective measures
for enforcing international standards are essential. Such ships
are a threat not only to themselves, but also to their crew and
to the safety of other ships and to port facilities and infrastructure.
NUMAST is concerned at the pressures that have affected the UK
port state control inspectorate, with a long period in which overall
staffing and resources for this vital work being cut back.
Similarly, NUMAST is also concerned at the need
to reinforce the role of the port health inspectorate. Conditions
on board many of the ships visiting UK ports are intolerable,
with cases of rodent and cockroach infestation, unsanitary or
unhygienic facilities and inadequate food and water provisions.
There is also an increasing problem posed by ships that have been
abandoned by their owners, often leaving the crew with no pay,
provisions or other resources. NUMAST believes it is essential
that such problems are addressed by having a fully staffed and
resourced inspectorate with responsibilities for ensuring the
enforcement of international standards for shipboard conditions.
It is also important for ports to consider the nature of the facilities
provided for visiting seafarers. With port turnaround times cut
dramatically in recent decades (from an average of more than 138
hours in 1970 to just under 16 hours in 1998), it is imperative
that seafarers are given easy access to welfare services, communications
and recreational facilities whilst in port. This is of particular
importance in that many ports are now in areas well removed from
centres of population and lack public transport connections. Addressing
the welfare of seafarers can have a significant impact upon their
morale and well-being, and therefore upon motivation and safety.
NUMAST is also concerned that where port safety
committees do exist, seafarersperhaps one of the most important
"users" of portsare rarely, if ever, represented.
Effective port security is also of growing importance
to NUMAST and its members, at a time of increasing numbers of
stowaways and illegal immigration, as well as armed robberies
on merchant shipping and seafarers. Such incidents need to be
taken seriously by port authorities and effective measures such
as fencing, lighting, and screening of containers and cargoes
must be implemented. In addition, attention should be paid to
the complex arrangements presently governing port security, which
is presently the responsibility of agencies including the DETR,
HM Customs & Excise, Immigration, the Special Branch, the
MCA, police and private security guards. This can create ineffective
security and inconsistencies in liaison and operational practices
around the country.
3. Whether the proposals contained in the
government's document Modern Ports: A UK Policy are adequate to
address the difficulties and opportunities faced by such ports;
4. Whether other policies should be pursued
to benefit such ports.
The Modern Ports document clearly indicates
the scale of the task facing the government in reversing many
years of neglect and in defining policies that will create safe,
efficient and economic port operations at the heart of a broader
integrated transport policy.
The situation facing UK ports at the start of
the 21st century is one shaped by complex international political,
strategic and commercial factors. Given the far-reaching trends
affecting port development, it is essential that any UK policy
assessment identifies how the nation will respond to the development
of "mega ports" and hubs as global shipping alliances
and new shipping technology create new international trading patterns.
It is clear that significant work must be undertaken
to ensure that UK ports are part of a truly integrated transport
infrastructure. Intermodal links need to be dramatically overhauled
and road and rail connections to leading ports should be fundamentally
reassessed. The report's repeated emphasis on the devolved nature
of ports and port operations should not be used as an excuse for
failing to develop and maintain a broader strategic plan for the
development of UK ports and their facilities in a national and
international context. There needs to be a recognition of the
inter-connection between various policies and initiativesfor
example, the potential impact on UK maritime skills and employment
of using foreign shipping for new services, such as the proposed
link between Scotland and Europe.
There is no doubt that shipping can deliver
substantial environmental benefits, but there is a need for further
supportnotably through the Freight Facilities Grant and
greater involvement by UK ports in the Trans-European Network
Port related charges and funding needs to be
examined thoroughly, as these are factors that can have significant
impact upon competition and investment.
Training and skill requirements need to be defined
and developed, with ports being encouraged to participate in the
SMarT scheme to ensure the flow of seagoing expertise to port-related
positions. Without a contribution from the ports to developing
the pool of maritime experience, there is a very real danger that
skill shortages will adversely affect their ability to provide
essential safety services.
Whilst the development and introduction of the
Port Marine Safety Code is welcomed by NUMAST, we believe serious
consideration should be given to ensuring that there are sufficient
resources and staffing to enforce its provisions and to continue
to develop and enhance the port state control regime within UK
Other issues that need to be addressed in greater
depth include port security, the composition of the port industry
training board and of port safety committees, the deployment of
resources and staffing to port health inspections.
Efficient port operations are essential to the
economic and strategic well-being of the nation.
The role of ports will remain undiminished in
its importance, as national and international seaborne trade continues
The UK needs to have defined policies for the
development of its ports and associated infrastructure to ensure
they remain internationally and regionally competitive and keep
pace with changing technological and trading patters.
Funding issues affecting port safety and environmental
services need to be considered further.
There is considerable scope for improving the
safety record of UK ports.
Training issues need to be addressed urgently
to ensure the continued supply of skilled and experienced personnel
for port operations.
Adequate resources must be provided to ensure
the effective implementation and enforcement of safety initiatives
in UK ports.
Further support should be given by the government
to ensure maximum environmental benefits are realised through
the full integration of UK ports and shipping services within
the national transport infrastructure.