Fear, Anger, and NI DP CPD

Introduction:?A few people asked me for my opinion on the Nautical Institute’s (NI) new dynamic positioning operator (DPO) continuous professional development (CPD) requirements.?DPOs are concerned that they have to pay someone new for the privilege of jumping through another, poorly defined hoop, and are worried about increased cost and risk without benefit.?Let’s take a look.??

First Look:?Someone linked me to Keelson’s post on the subject.?I had a look at what was required and was glad that that I didn’t have to pay two sets of people with possibly different opinions to do my job (who am I kidding, I pay three).?I like what I have seen of Keelson and like how they are filling the knowledge gaps left after classroom training (learn long enough to pass test and then forget), but online training is still online and I love practical vessel specific training.?Keelson’s data shows what experience shows, many operators, engineers, and managers don’t understand the DP basics and that is the gap Keelson works to fill.?Their finding isn’t really a surprise, as I spend most of my time covering the basics - look at my articles.?There is a lot of misinformation and misunderstanding floating around.?Someone who gets CPD from Keelson, or a similar source, gets the gaps filled and should be much more likely to pass the NI annual revalidation test.?Keelson tries to work with operators, so they avoid being a financial burden on DPOs, and that is respectable.

Anger:?“I paid my money to qualify and work hard to be good at what I do.?Now, I have to pay more money to do an annual course and test??More money, more distraction, no safety benefit.?It’s just a cash grab.”?That summarizes one message I received.?Put like that, the new CPD requirement looks like a net negative for workers, and will probably reduce the number of good people.?If it is just pay to play, then why should people be loyal to the industry??Especially in a downturn, when getting 150 days is hard.?Why jump through meaningless, expensive hoops to have them taken away, when another industry will treat them fairly?

History:?We all know that knowledge fades over time, unless people keep each other or themselves sharp, and we have all met individuals who were not aware of the basics or had brain malfunctions (I once forgot my name and had to look it up in my passport).?Once upon a time, the local professional culture provided the training to overcome this, crew members would keep each other sharp, surveyors would harvest and share experience, and operators would provide experience and training.?Experienced-based professionalism is very powerful, and used to be the real foundation of safe operation.?Courses got you through the door, but all the real learning happened on the vessels.?This was excellent on vessels with good cultures, but a problem where such cultures were discouraged.?With the increased commoditization of crew and the cult of top-down management becoming dominant, the old foundation was eroded.?People responded to how they were treated and the results were poor.

IMCAM117:?IMCA saw the problem, and in 2016, they updated their DP personnel training guidelines (Rv2).?The 2006 version had a section on maintenance of personal skills with general, but non-restrictive advice.?The 2016 version defined CPD programs and considered them an integral part of owner/operator safety management.?They defined expected components:

• DP Operations – The traditional tracking of hours or days.
• Regular Training – Formal courses, work-based learning, distance learning (online), conferences, and review of DP guidelines, incidents and journals.?Refresher training was considered fundamental.
• Practice of Skills – A weak area where classroom and simulator training don’t help much.?The importance of DP trials was emphasized (my original subject for this week).?I’d add in that people need time to play with systems, so they can develop and maintain expertise to solve problems.
• Mentoring – Teaching others teaches you and them.?This was a fundamental part of the old professional system.?It’s the best way to develop vessel specific understanding.?More formally, this could include writing papers and contributing to guidelines and industry bodies.
• Test – While keeping each other sharp was a constant thing in the informal professional system, a more formal system requires regular assessment with defined objectives.
• Introduce Improvements – Improved practices and procedures, and new technology.?This is something that the old system was good at, and the current top down system is poorer at.?I’m concerned that crew need to own these things.?Something can’t do it for them.?DP conferences, journals, and guidelines help with this.

Nothing said that this needed to be done by an external body for money.

NI:?Six years later, the Nautical Institute updated their certification and accreditation standard to require formal CPD (Jan 2023).?It requires online CPD be provided by a body that they approved, or a week long, in person, refresher course be taken every year.?Either way, an annual NI test must be passed, but it can be performed remotely.?The CPD is the cheaper option, but requires paying for CPD and possibly for the test (unclear).?Why didn’t they create a system that supports the traditional crew mentoring or operator CPD??This was probably done to provide top-down quality assurance.?The crew and operator CPD no longer seemed to be reliable and are harder to monitor, so another approach was taken.?This doesn’t mean that existing CPD systems can be approved, but they need to be formal, structured, approved, and provide consistent passes in the revalidation test.?NI saw the same skill-fade problem that IMCA saw, and they weren’t the only ones, so this is how they plan to close the gap.?They needed something that they could measure the success of.

Concerns:?NI’s new requirements generally reflect IMCAM117, which it quotes.?Obviously, there are differences as CPD is now a NI function, which can only be delegated to an audited and approved provider, so crew-based and most operator based CPD schemes are out.?I worry about the neglect of practical vessel specific training and further removal of crew control that might result from this rebalancing.?Practical operating skills and knowledge are not always remotely testable, and CPD schemes need to emphasize their importance, even if NI can’t measure them.?Similarly, crew ownership and buy-in is vital to operation and success.?These faults need to be carefully considered and compensated for by good CPD providers.?I could quibble about some of the content (Imagine only looking at IMO645 every 5 years! Am I the only one who keeps needing to ground himself in the source?), but that is probably not worthwhile covering, and adaptive systems can find and resolve those gaps.

Benefits:?The main benefit of the new scheme is its ability to help keep knowledge fresher.?Once a year isn’t really good enough for this, but assuming the CPD schemes are used weekly and interactive to find gaps and maintain skills and knowledge, then the process should cover basic classroom knowledge and skills.?The appropriateness of each CPD scheme can then be further evaluated in the annual test results.?Multiple providers means the best provider can be selected and competition means the fees should stay reasonable.?Companies that were struggling to provide internal CPD may find this eases their burden, and those that performed none must now consider it.?It can be a company paid benefit for DPOs that work for good companies. CPD done right is good and not an atypical professional approach. I have been under one scheme for over twenty years and another for almost 30.

Drawbacks:?Normal CPD is something that people do themselves out of interest and a desire to be good at the job.?NI CPD is something that is done to them.?This looks bad and needs fixed by good CPD providers.?A useful tool that also gets through the NI hoop is welcome.?There is room for intelligent application and competition in this factor.?Remote tests and videos are no better than classroom training.?Practical skills need added, and crew initiative, ownership of the process, and interaction need encouraged.?

Business: Multiple providers means the worst approved providers can be selected.?We have seen how this works with document providers, approvals, and auditors, so we know it is a problem.?A provider might dazzle NI with paperwork and only prepare the participants to pass the annual test.?This provider could then undercut good providers with lower prices and less demand on customers.?Broadening the training market, from those who want to proactively improve safe operation through training to everyone looking for a CPD certificate, puts downward pressure on all providers.?NI needs to be very careful to avoid these paperwork games.?Finally, bad operators can demand their DPOs pay for the CPD.?Worst of all, they might select a provider based on a kickback.

Conclusion:?Maintaining skills and knowledge is vital to safe DP operation.?Given the trends, this change in CPD was probably inevitable. The NI CPD scheme is only aimed at the classwork portion of those goals, but could be enriched to include practical operation.?If properly implemented, the scheme has the potential to improve things for all market participants.?Because we have people rather than angels, the scheme will cause some harm, and DPOs, operators, CPD providers, and NI need to be aware of and guard against the potential drawbacks.?DP knowledge generally wasn’t good, and the NI CPD benefits can outweigh the drawbacks.?It’s already required, so let’s attack the problems, and make it work or improve it.