Empa's position on PEC's
Pilot Exemption Certificates (PECs) are used throughout many EMPA member countries. The criteria for obtaining these certificates are locally defined, based on local conditions and therefore differ between ports within individual countries.
Considering that a PEC permits the holder to navigate in pilotage waters without the assistance of a pilot, then that person should be able to prove to the issuing Competent Authority that he/she has the necessary experience and knowledge to safely conduct the navigation for the ship or ships stated on the certificate;
Acknowledging that not all member countries permit PECs;
Agreeing that no formal European Guidelines are in force for the provision of PECs,
EMPA recommends the following in an attempt to promote best practice:
- In an area of compulsory pilotage, the provision of a licensed Pilot is the default option. Where a Master and, in those circumstances considered appropriate by the Competent Authority, a qualified Officer of a ship have met the criteria laid down by that Competent Authority, and where the type of ship for which the exemption is to be granted under the Authority’s rules, a Pilot Exemption Certificate (PEC) may be issued permitting that person to navigate the specified ship through the compulsory area, or to and from a designated berth on a designated route, without the services of a Licensed Pilot.
- The use of PECs may be limited by rules set down by Competent Authorities. These rules will determine the parameters when an exemption certificate will be valid and they may often be port specific. Exceptional Hydro/Meteo conditions, hazardous cargo types, tug use and the conditions when a qualifying Officer’s exemption certificate can be used, are examples of these limiting parameters, the list is not exhaustive. An Authorities’ limiting rules should be described in full on the exemption certificate.
- PECs must only be granted to the bona fide Master, and where considered appropriate by an individual Competent Authority, certain suitably qualified Officers of ships that regularly use a particular port or port system.
- The qualifying standards for Exemption Certificates must not be more onerous than those required for a licensed Pilot; however they should comply with those elements applicable to the Pilots’ competence chart.
- The PEC should only be granted when candidates, have obtained the necessary local practical and theoretical knowledge, and have been thoroughly assessed by the Competent Authority that they do not require the assistance of a Pilot.
- PEC holders should be able to meet any special medical fitness standards required for licensed
Pilots set by the Competent Authority.
- The name of the ship or similar ships for which the PEC is applicable should be indicated on the certificate. A PEC should not be valid on other ships when the size, manoeuvring characteristics, or type of those other ships differ from that for which the PEC was originally granted.
- PEC’s should not be awarded when the trade patterns of the ship induce evident levels of fatigue in the Master and/or Bridge team. The services of a Pilot in these circumstances can benefit both the ship and the port by ensuring the ship is being navigated safely by someone who is both alert and highly experienced. The granting of a certificate to a candidate onboard a ship manned by only two certificated watch-keepers and engaged on the short sea voyage trade should be avoided, unless adequate rest periods can be guaranteed by that candidate.
- The presence of the conducting PEC holder on the bridge of the ship should be continuous throughout the passage in pilotage waters. Where this continuity cannot be guaranteed the assistance of a licensed pilot must be requested prior to the vessel entering the pilotage area.
- PEC holders must ensure that they are, at no time, alone on the Bridge of a ship when in pilotage waters. The competent Authority must be immediately advised should the PEC holder be incapable, for any reason, from carrying out the responsibilities granted by the PEC.
- Qualifying trips prior to practical assessments must be made accompanied by licensed Pilots and to be completed over a limited set period. The vessel type and the difficulty of the Pilotage area should determine the number of qualifying trips. The practical assessments should be restricted to the ability of the candidate to safely manoeuvre the vessel, to communicate properly & effectively at all times in the language adopted for pilotage in the local area, and to the adherence of port navigational procedures during the passage.
- In addition to the practical assessments there should be a theoretical written and oral examination conducted by the Competent Authority to ensure that the candidate has a comprehensive working knowledge of the navigational features of the pilotage area including buoyage, courses to steer, other navigational marks and dangers; port emergency plans and local laws. The Competent Authority should make available to the candidate, in advance, all information pertaining to the knowledge on which any examination is based, with guidelines on the level of knowledge to be expected. It is recommended that Pilots are included on the examination panel.
- Competent Authorities should monitor the use and validity of PEC’s. Where there has been an abuse of the criteria under which the PEC was originally granted, procedures should be in place for the suspension and if necessary the removal of the PEC.
- A PEC should be granted with the assumption that the manoeuvring equipment on the ship is in full working order. Where a defect exists the Competent Authority must be advised prior to that ship entering the pilotage area, and if considered appropriate by the Authority, a licensed Pilot supplied.
- PECs should not be valid on ships that carry certain classes of dangerous goods, nor should they be permitted to manoeuvre close to terminals where dangerous goods are being loaded discharged or stored.
- The PEC should remain valid for a finite period during which the holder should keep up to date the required local navigational knowledge. Where there has been a lapse in the use of the PEC and in any case following a set period the candidate should be reassessed.