A professional’s view of the Carriage Regulations

In the Spring 2018 paper edition of On Board magazine Michael Howorth used his Comment column to write about the expense and, as he sees it, the questionable value, of publications required onboard by the various national Carriage Regulations. When I raised concerns about the article, the editor kindly proposed that I write an article, on behalf of my trade association, to explain our point of view, for the web version of On Board. Here is the result.

First a bit about us. The Chart & Nautical Instrument Association (CNITA) was born, 100 years ago, in the gloomy spring of 1918. Initially, its main purpose was to help the government to manage the production of sufficient magnetic compasses for the replacement shipping being built to make good the sinkings of German unrestricted

U Boat warfare. Magnetic compasses remain part of our core identity, and we have been fighting for the retention of independent, power source free, navigation aids onboard ships since long before the current fashionable talk of need for resilience. Our members’ main centre of activity now is, however, the provision of charts and publications, both digital and paper, so that ships and vessels of all sizes can carry out their voyages or operations.

There are only 50 or 60 specialist Chart Agents in the world, and our membership at CNITA encompasses the majority (by volume of sales). Clearly we need to make a profit to survive, but our professional expertise is in identifying and providing what charts and publications mariners require. This also, for most of us, involves providing the follow up services of corrections and new editions. Contrary to what some in yachting believe, and Michael Howorth seems to imply, commercial shipping is a fiercely competitive business with paper thin margins, and shipping management companies that seriously outgun their suppliers in terms of commercial power.

Every centime that a merchant ship spends is scrutinised for necessity, and in any case where management companies sense an opportunity to reduce cost, they attack. Against this background the suggestion that there is a fat margin of profit sitting on top of every book price (and I’m using book generically for paper, e-book, software based data, whatever) doesn’t add up. For sure, many of these books are expensive. In an era when Amazon has forced down the cost of many books to ridiculous levels, it is easy to forget that many costs have gone up, and for books which need to be accurate, authoritative, and up to date, there is a huge burden of ongoing cost of maintenance.

The Bridge Procedures Guide is not expensive so that the members of the International Chamber of Shipping can retire from the business and take up a life of tropical luxury, but because of the very high cost of maintaining a world class document, quoted in court cases and government documents. Imray Guides are not the price they are so that the owning families can build further country houses in Rutland, but because of the need to fund authors (or their replacements) to check and update charts and publications. It is for that reason that, from time to time we see new very promising cruising guides appear on the scene, only to disappear at the time they should be producing new updated editions.

Michael takes a particular shot at publications produced by international organisations, including those of the International Maritime Organisation (IMO) and the International Telecommunications Union (ITU). Increasingly flag states like the Marshall Islands spell out in their Carriage Regulations which international publications, specifically IMO publications, they require carried, even though the IMO identifies them as technical documents. We distributors welcome this clarity, since, like the Marshall Islands Registry authorities, we believe that the key guideline is having onboard the minimum necessary for safe completion of a voyage or operation, rather than the absolute minimum that will survive inspection. It is worth remembering that.

In criticising the ITU and its publications, Michael forgets the recent history of radio at sea. It was only in 1999 that GMDSS became fully mandatory at sea. Up until that time, almost all ship shore communications was exclusively in the hands of specialist Radio Officers. While the main driver of GMDSS was to improve, rationalise, ans integrate worldwide safety communications, an important by-product, as far as ship owners were concerned, was the parallel end to the requirement for ROs. Of course the ITU has been conservative in its requirements, but insisting that all vessels carry a copy of Maritime Radio Regulations, and up to date lists of Ship & Shore Stations and their callsigns does not seem to me unreasonable. I doubt that any captain would wish to turn the clock back, and explain to his owner that he had to make room for a radio room, and accommodation for two or more ROs onboard!

One final thought. Carriage Regulations are published by Flag States, indeed by those same organisations that help form, then vote into being the various international regulations. They do not do this work on the basis of whim. Most maritime agencies have three main objectives, namely the safety of mariners, the safety of the marine environment, and the safety of vessels at sea. In their work these agencies are obviously directed by their political masters, but they are also subject to influence and pressure from the shipping world. Plenty of environmental charities argue that these agencies are subject to too much influence from the shipping industry. If the yachting industry really has a case to opt out of some or all of these safety regulations then its own trade bodies like the PYA should make that case. In the meantime, please ensure that you have your required, up to date, mandatory charts and publications onboard. We will be happy to source, supply, and help you maintain them.

Simon Jackson
Riviera-Charts eurl
Chart Committee, CNITA