The lights suddenly went out for some colour deficient seafarers. On 24 April, the UK MCA sent out revisions to the guidance for their Approved Doctors who are responsible for applying the guidelines for seafarer fitness certification (ENG1 certificates) and it looks likely to impact the yachting industry deck applicants in particular.
This is because the current restrictions have been causing problems in the yachting industry for MCA Surveyors and the MCA Training and Certification Team. The new restrictions have been agreed with Capt Roger Towner, the MCA Chief Examiner and Registrar General.
In the past it has been possible to issue a restricted ENG1 to an experienced, but colour deficient, deck applicant indicating “no solo lookout duties” and this restriction has been accommodated on yachts with multi-tasking crew. Historically, this restriction was introduced to accommodate colour deficient seafarers who had not previously been restricted for some reason and represented a compromise to avoid sabotaging an established career. This restriction can still be applied under the new revisions but colour deficiency would block a UK MCA STCW Certificate of Competency, although a RYA commercial endorsement is a possibility. Therefore this restriction is to be discontinued because it is not deemed suitable for anyone working in the large yacht industry (over 24 metres) or for any Merchant Navy seafarers. The only time an exception can be made is in the case of those who are already working with the “no solo lookout duties” restriction and this exception is intended to minimise disruption during the time of transition over the coming years. The wording of the revised restriction is “No solo lookout duties, employer/ship owner to conduct risk assessment”. The ENG1 should indicate that they are NOT fit for lookout duties but the understanding is that they ARE fit if complying with the restriction. The subtlety of this logic is likely to be challenging if someone is issued an ENG1 which is now ticked not fit for lookout duties and I think could be the most disruptive aspect of these revisions for experienced seafarers.
Given the impossibility of a future CoC, experienced but colour deficient seafarers are to be counselled by the assessing doctor on the potential limitations on their career opportunities and alternative career paths, such as engineering or yachts under 24 metres, are to be suggested. Otherwise the revised restriction is to be seen as a pragmatic solution for established Deck category seafarers to continue to function but with the understanding that they will not ever be able to qualify for a UK CoC.
The position for new deck applicants with colour deficiency is, in every way, very black and white. They cannot be issued an ENG1 certificate as fit in the Deck category and must be made permanently unfit (ENG3 certificate) unless they choose to make a career move into, for example, engineering and then receive a suitably completed ENG1 (see below). In the past, first time deck applicants could receive an ENG1 indicating “No lookout duties” and ticked not fit for lookout duties which seems to have been sufficient for some to find work but clearly there is a glass ceiling on their career prospects as deck officers. Given that yachting is only a short-term adventure for some, this restriction sits fairly lightly with them especially if they are normally doing lookout in a supportive capacity and have no aspirations for further qualifications and professional tickets. However, the revisions will focus the thinking of more dedicated deck officer candidates who envisage a career at sea.
The one fixed point in these revisions is the continued availability of the Lantern Test conducted by the MCA in the UK. This test mimics navigation lights at various distances and in varying levels of visibility and a successful Lantern Test over-rules the standard Ishihara Test (numbers based on coloured dots) and is valid for life!
The engineering option may appeal to some and has the advantage that fitness for lookout duties is not normally required (although in a multi-tasking crew that may not be the case). There are supplementary tests for engineers and these are based on colour matching skills. A successful supplementary test will qualify an engineering candidate for an unrestricted ENG1, as an engineer, but will be ticked not fit for lookout duties. A fail in the supplementary test requires a restriction “Not fit for work with colour coded cables etc”
The overall aim of these revisions is to ensure that those who are not fit for navigatio
nal lookout, whether due to colour deficiency or other eye conditions, are aware that they will not be able to gain a CoC because they are not safe to do so – but it is also intended to minimise distress to those already working in the industry – early days……..
