NFFO: ‘This is a really valuable opportunity to give the MCA feedback’
The Maritime and Coastguard Agency (MCA) has launched an online survey asking for views from fishermen on its proposals for the implementation of ILO 188 – the international regulations that deal with issues around fishermen’s work agreements, medical requirements, and living and working conditions.
This isn’t a voluntary initiative by the MCA. It is obliged under the ILO regulations to conduct a ‘post implementation review’ to assess the overall performance of the regulations, including assessing whether they are still required, if they have met their objectives, and whether any improvements or amendments are needed.
This requirement is outlined in Statutory Instrument 2018/1106 Regulation 32, and stipulates that the secretary of state for transport must carry out a review of the regulatory provisions, and also publish a report setting out the conclusions of the review.
FN has looked at the survey, and whilst it utilises multiple-choice questions – often a way of channelling answers towards certain outcomes, and restricting the possibility for genuine input or alternative views – the exercise does appear to be a genuine opportunity for respondents to have input and make their opinions crystal clear on the issues raised.
The survey comprises 27 multiple choice questions, but in each case, space is given to provide additional detail. There are also options in each question that allow participants to make clear any concerns or opposition to aspects of the proposals under ILO 188 – although the questions themselves provide little in the way of detail.
Charles Blyth, the former MCA surveyor who now works for the NFFO as risk, safety and training lead, told FN: “This is a really valuable opportunity for working fishermen to give the MCA both negative and positive feedback about their proposals around ILO 188 and the new medical requirements.
“This doesn’t seem to be a box-ticking exercise on the part of the MCA, and it is vital that the industry makes its voice heard. If we don’t engage, how will the regulator have any supporting evidence to change proposals that they are making, many of which we all agree will create burdens on the industry without making it safer?”
Shadow fisheries minister Daniel Zeichner made similar points, saying: “It is great to see that finally government is now consulting on what has been happening during the roll-out of various ILO 188 workstreams.
“But on visits around the coast, the stress and mental health implications of these roll-outs and new workstreams has been palpable, particularly among the small-scale fleet who do not have companies or shore support to help them.
“I hope in the future, when considering physical health, the government will also consider the mental impacts of what they are doing.
“It is of course disappointing that across government consideration was not given to the multiple consultations and workstreams coming from all directions at fishers. iVMS, the Catch App and multiple Fisheries Management Plans are just some of the others that have been running in parallel, making it difficult to keep up, let alone take part in them all.”
The survey can be found here.
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