The work of the maritime and coastguard agency

House of Commons
Transport Committee

The Work of the
Maritime and
Coastguard Agency
Fourteenth Report of Session
2003–04

Report, together with formal minutes, oral and
written evidence
Ordered by The House of Commons
to be printed 30 June 2004

HC 500
Published on 18 July 2004
by authority of the House of Commons
London: The Stationery Office Limited
£14.50


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Mrs Gwyneth Dunwoody MP (Labour, Crewe) (Chairman)
Mr Jeffrey M Donaldson MP (Democratic Unionist, Lagan Valley)
Mr Brian H. Donohoe MP (Labour, Cunninghame South)
Clive Efford MP (Labour, Eltham)
Mrs Louise Ellman MP (Labour/Co-operative, Liverpool Riverside)

Mr Ian Lucas MP (Labour, Wrexham)
Miss Anne McIntosh MP (Conservative, Vale of York)
Mr Paul Marsden MP (Liberal Democrat, Shrewsbury and Atcham)
Mr John Randall MP (Conservative, Uxbridge)
Mr George Stevenson MP (Labour, Stoke-on-Trent South)
Mr Graham Stringer MP (Labour, Manchester Blackley)
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The Work of the Maritime Coastguard Agency

1

Contents
Report

Page

Summary

3

1

Introduction

5

2

The Maritime and Coastguard Agency

6

Role of the MCA
6
Scrutiny of the MCA in the previous Parliament
6
Safety
7
Incidents, accidents and deaths
7

Closure of rescue co-ordination centres
8
Time taken to respond to incidents
9
Watch Staffing Levels
10
Incidents, Accidents and Deaths: Conclusions
14
Implementation of Integrated Coastguard Communication System and Incident
Management System
15
Staff issues
16
Qualifications and competencies
16
Administration
17
Tackling pollution
18
Policy formulation
18
Justification for policy
20

3

Future of the Agency

23

Rescue co-ordination centres
Agency’s Remit

23
23

Conclusions and recommendations

25

Formal minutes

28

List of witnesses

29

List of written evidence

29

Reports from the Transport Committee 2002

30



The Work of the Maritime Coastguard Agency

3

Summary
The Maritime and Coastal Agency has a vital role in preserving life. It does this through its
work on ship safety, and through its Coastguard work. Forerunners to this Committee
have examined the Agency in the past, and expressed grave concerns about its
management of Coastguard operations. We are concerned the problems still continue.
Since 1998, the number of incidents, accidents and deaths in the United Kingdom search
and rescue region has risen. The Agency has no clear analysis of the reasons for this. The
number of rescue coordination centres has been cut; the Agency has no clear analysis of the
effect that this has had on response times. We are so concerned at the apparent absence of
any strategic analysis that we believe an independent review is necessary to establish
whether the Agency’s actions have contributed to the increase in fatalities around our
coast.
Individual coastguard officers may perform heroically, but individual effort will not
compensate for insufficient staff on duty, or for staff expected to undertake tasks for which
they are not qualified. Our inquiry revealed a routine acceptance that coastguard stations
will frequently be staffed at, or even below, the minimum complement. The Agency has
defined staff competences, but has no system for ensuring that underqualified staff are not
called on to provide cover for long periods.
Moreover, the Agency is failing in its duty to give a clear lead when Government policy
may have implications for safety at sea. Far too often, it is left responding to developments,
rather than taking the initiative. We believe there are still serious problems within the
Agency, which its new Chief Executive will have to address.



The Work of the Maritime Coastguard Agency

5

1 Introduction
1. As part of our ongoing inquiry into Department for Transport-related Executive
Agencies and Non-Departmental Bodies, we took oral evidence from Captain Stephen
Bligh, Chief Executive, and Mr Neil Goodall, Finance Director, of the Maritime and
Coastguard Agency (MCA) on 31 March 2004.
2. Our predecessor Committee reported on the MCA in 1999 and again, as part of a
broader inquiry into a number of Executive Agencies, in 2001.1 Those Reports identified a
number of concerns we wished to revisit; we also wished to hear Captain Bligh’s views—as
the relatively recently appointed Chief Executive of the Agency 2—on the priorities for, and
challenges facing, the MCA. On the basis of a single evidence session, this Report does not
cover every aspect of the MCA’s activities, but focuses on the areas about which we are
concerned and where we seek improvements.
3. We are grateful to the MCA for their oral evidence and follow-up written memoranda.
We are also grateful to the following organisations for their written evidence: the Royal
Society for the Protection of Birds; the Royal Yachting Association; the Public and
Commercial Services Union (PCS); the Inland Waterways Association; and the National
Union of Rail, Maritime and Transport Workers (RMT). We have also been greatly
assisted in this inquiry by our Specialist Adviser, Professor James McConville.

1

Environment, Transport and Regional Affairs Committee, Sixth Report of Session 1998-99, The Maritime and Coastguard
Agency, HC 31; and Seventh Report of Session 2000-01, The Transport-Related Executive Agencies of the
Department of the Environment, Transport and the Regions, HC 1224

2

Appointed 1 September 2003

6

The Work of the Maritime and Coastguard Agency

2 The Maritime and Coastguard Agency
Role of the MCA
4. The Maritime Safety Agency (MSA) and the Coastguard Agency merged on 1 April 1998
to form the Maritime and Coastguard Agency (MCA). The Agency “is responsible
throughout the UK for implementing the Government’s maritime safety policy. That
includes co-ordinating search and rescue at sea through Her Majesty’s Coastguard, and
checking that ships meet UK and international safety rules…. [The Agency] works to
prevent the loss of lives at the coast and at sea, to ensure that ships are safe, and to prevent
coastal pollution…. [It is] putting increasing effort into prevention work and a measure of
[its] success is when accidents do not happen, or where [it] intervenes to minimise their
impact.”3 The Agency’s slogan is Safer Lives, Safer Ships, Cleaner Seas.
5. The Agency, which in 2002-03 employed 1,100 staff and had a net operating cost of
£105, 095, 000,4 seeks to achieve four outcomes:
x

A reduced rate of accidents, and accident related deaths, involving UK Registered
merchant ships and fishing vessels.

x

A reduced number of accidents, and deaths resulting from accidents, within the
UK Search and Rescue Region and Coastline.

x

A reduced number of incidents of pollution from shipping activities in the UK
pollution control zone.

x

An enhanced safety record for the Red Ensign Fleet.5

Scrutiny of the MCA in the previous Parliament
6. Our predecessor Committee’s Report into the MCA in February 1999 expressed concern
that the Agency was planning to close four (out of 21) maritime rescue co-ordination
centres (Oban, Pentland, Tyne Tees and Liverpool) and that Portland and Solent centres
were to be co-located. The Committee recommended that all 21 stations remain open.
Subsequently, the decision to close the Liverpool station and co-locate Portland and Solent
was rescinded. When it looked at the Agency again in 2001 as part of its inquiry into the
Department’s Executive Agencies, the Committee: urged the Agency to modernise
management structures; noted the need for adequate numbers of suitably qualified staff to
be on duty at Coastguard stations; re-iterated the Committee’s opposition to the closure
programme; and expressed concern about the introduction and operation of the new
digital Integrated Coastguard Communications System (ICCS). We revisit these issues in
this Report.

3

www.mcga.gov.uk

4

Maritime and Coastguard Agency, Annual Report and Accounts 2002-03, HC 863, pp 50 and 63

5

Ibid., p 8


The Work of the Maritime Coastguard Agency

7

Safety
Incidents, accidents and deaths
7. As noted above, one of the principal outcomes the MCA strives to achieve is “a reduced
number of accidents, and deaths resulting from accidents in the UK search and rescue
region”. However, the number of incidents, accidents and deaths increased significantly
between 1998 and 2002:
Table1: Incidents, Accidents and Deaths, 1998-2002
1998

1999

2000

2001

2002

% increase
1998 - 2002

Incidents

11, 553

12, 220

12, 016

12, 514

13, 395

15.9%

Accidents

6, 480

6, 581

6, 703

7, 242

7, 604

17.3%

249

251

236

284

319

28.1%

Deaths

Data Source: MCA Annual Report 2002-03, p. 91; percentages inserted by Transport Committee

8. It is particularly alarming that the numbers of deaths has risen more sharply than those
of incidents and accidents. The MCA’s Annual Report states that “this is a worrying trend
and supports our strategic objective to redirect our coastguard expertise into a more
coherent and sustained accident prevention strategy based on education, information and
advice. It is accidents to people swimming, and walking on beaches and cliffs that has
increased, whilst accidents involving vessels has decreased. We are planning to undertake a
series of quarterly sample surveys of potential customers, to gain a better understanding of
their safety awareness and how best to promote our safety messages.”6
9. We pressed Captain Bligh to explain why the number of incidents, accidents and deaths
has been increasing. He said that greater analysis was needed but noted that: there might be
some double-reporting of incidents and accidents;7 not all the deaths were related to
maritime incidents;8 and that statistics on the exposure of the public to coastal areas were
not available.9 These responses were not wholly convincing: double-counting of incidents
and accidents would not account for the increase in deaths, as Captain Bligh conceded; and
the fact that not all the deaths were related to marine incidents was presumably also the
case in 1998, and so does not explain the increase. Finally, the MCA does not know if more
people are engaging in activities on or near the coast: such an increase – if it has occurred –
might be a factor in the increased numbers of incidents and accidents, but would not

explain why deaths had increased at an even greater rate. There was a clear increase in the
number of incidents in 1999; by 2000, the increase in the number of accidents was marked;
although the significant increase in deaths in 2001 might have been considered a statistical
quirk, by 2002 it should have given cause for concern. We are shocked that when we took
evidence in 2004 the Agency was unable to demonstrate that it had already analysed the
reasons for the increases in incidents, accidents and deaths since 1998. This displays a
6

Maritime and Coastguard Agency, Annual Report and Accounts 2002-03, HC 863, p 8.

7

Q 29

8

Q 32

9

Q 43


8

The Work of the Maritime and Coastguard Agency

worrying inability to note trends, and to take the necessary action to make sure the
Agency understands them.
10. Given that the MCA were unable to provide a convincing explanation, we asked

whether three important aspects of the Agency’s performance – the reduced number of
rescue co-ordination centres, the time taken to respond to incidents, and staffing levels –
were factors in the increasing numbers of incidents, accidents and deaths. We now turn to
each of those factors.
Closure of rescue co-ordination centres
11. Asked about the consequences of the closure of Oban, Pentland and Tyne Tees
Centres, Captain Bligh said “I am not aware of any consequences of the closure of those
three stations.”10 However, this is perhaps not surprising - or confidence-inspiring - given
that he was also unaware of any assessment of the impact of the closures having been
carried out by the MCA.11
12. In its subsequent written evidence to the Committee, the MCA stated that
Since the closure of Oban, Pentland and Tyne Tees, regular exercises have been
carried out to ensure the operation integrity of the areas taken over by other coordination centres. Moreover, the search and rescue (SAR) resources and response
are discussed at the local SAR committees and marine safety groups for the areas in
question. In addition, the SAR levels of activity are frequently and regularly risk
appraised. In short, the operational integrity of all Agency areas of responsibility is
kept under review. There has been no reduction of Coastguard Rescue Teams on the
ground locally, and there has been absolutely no evidence of safety being
jeopardised.12
We note the MCA’s assertion that the closure of three rescue co-ordination centres has
not resulted in safety being jeopardised. We would have greater confidence in such an
assertion if it were based on a full assessment of the impact of the closures. The risk
appraisals already undertaken do not constitute such an assessment; otherwise the
Agency’s Chief Executive would have referred to them in his oral evidence.
13. The MCA should carry out a full assessment of the impact of the closures of Oban,
Pentland and Tyne Tees rescue co-ordination centres. This assessment should cover, as a
minimum, any impact of the closures on:
x

Time taken to decide on appropriate search and rescue responses and to initiate action;

x

Time taken for Coastguard Response Units to arrive at the scene of an incident; and

x

The prevalence of incidents, accidents and deaths.

10

Q 60

11

Qq 70-71

12

Ev 27


The Work of the Maritime Coastguard Agency

9

Until such an assessment has been undertaken the MCA’s claims that safety has not
been jeopardised will be impossible to verify.

Time taken to respond to incidents

14. One of the MCA’s Ministerial Key Targets for 2003-04 was:
In at least 96% of incidents, take a decision on the appropriate search and rescue
(SAR) response to accidents and life threatening situations and initiate action if
necessary within five minutes of being alerted.13
This applies to action in the rescue coordination centres. The MCA met the Target
comfortably in 2002-03, with decisions taken within 5 minutes in 99% of cases.
15. In addition, there are targets for the coastguard response units themselves. The relevant
Agency “Service Standard” is
For the Coastguard to arrive on the scene of an incident within 30 minutes of a
response unit being activated.14
The Agency met the Service Standard on 97.6% of occasions, but even so there were 206
incidents which Coastguard Rescue Teams failed to reach within 30 minutes of being
activated.
16. Impressive performance against both the Target and the Service Standard reflects the
hard work and dedication exhibited by staff on the ground. Nevertheless, our investigation
suggested that even here the Agency did not take a sufficiently strategic view. We asked
Captain Bligh why Coastguard Response Teams failed to meet the Service Standard on 206
occasions and what the impact of this had been. Captain Bligh “did not have the
information with him”15 and said he had not undertaken a study of the 206 incidents.16
However, in written evidence provided subsequently, the MCA said that
the Agency does not hold records of how much outside our exacting Standard time
of 30 minutes these occurrences were, however in every case the Teams arrived at the
scene and carried out their duties, and safety was not affected in any of the 206
incidents. Also, there were no instances of complaints or investigations resulting
from any of them. Delays in arrival were primarily due to traffic congestion.17
17. We are extremely surprised to hear that these figures are not kept, particularly since the
PCS told us that “every Coastguard Operations room has … a logging system that indicates
when the first call came into the operations room, when a rescue asset was alerted,
despatched, on scene …”18 (our emphasis). Be that as it may, we do not understand how the
13

HC Deb, 10 April 2003, col 32WS

14

Ev 26

15

Q 62

16

Q 68

17

Ev 27

18

Ev 41


10

The Work of the Maritime and Coastguard Agency

Agency can state that safety was not affected in any of the 206 cases in which teams arrived
late, if it does not know how much outside the 30 minute Standard they arrived. Given the

time-sensitive nature of the rescues undertaken (for example, involving mud rescue teams
or cliff rescue teams), it stretches credulity to believe that there was not a single incident in
which safety was not compromised.
18. The MCA should monitor the time taken for Coastguard response teams to arrive at
incidents so that:
x

the exact time of response is recorded in each case where the 30 minute Standard is
not met and an assessment made of the impact of the failure to reach the Standard;

x

the national situation can be assessed to see whether the Standard is breached in
certain areas more frequently than others and what the implications are of any such
variation.

Watch Staffing Levels
19. The PCS made a number of claims about staffing levels, including the following:
…it has become commonplace… to operate on minimum staffing levels rather than
the recommended level…. The minimum staffing level can be defined as the level
that is capable of supporting the normal level of incident activity without the margin
of safety.19
20. Giving oral evidence, Captain Bligh said that 90% of watches were run at
recommended levels.20 When we probed further, he also said that up to 10% of watches
each month are staffed below minimum levels.21 Table 2, based on data provided by the
MCA, shows the number of watches operated at minimum, and below minimum, levels for
March 2003 to February 2004.

19

Ev 22

20

Q 47

21

Qq 48-56


The Work of the Maritime Coastguard Agency

11

Table 2: Watch operation levels
Total
watches

Total at
or above
recom’d
Level

Total at
minimum
level

% of
total

Total
below
minimum
level

% of total

March 2003

1,116

805

173

15.5%

138

12.4%

April 2003

1,080

805

207

19.2%

68

6.3%

May 2003

1,116

759

235

21%

122

10.9%

June 2003

1,080

727

291

26.9%

62

5.7%

July 2003

1,116

797

203

18.2%

116

10.4%

August 2003

1,116

702

342

30.6%

72

6.4%

September 2003

1,080

705

303

28%

72

6.7%

October 2003

1,116

698

318

28.5%

100

9.0%

November 2003

1,080

673

312

28.9%

95

8.8%

December 2003

1,116

713

271

24.3%

132

11.8%

January 2004

1,116

787

240

21.5%

89

8.0%

February 2004

1,044

741

240

23.0%

63

6.0%

Yearly average
(rounded)

1098

743

261

23.8%

94

8.6%

Data Source: Ev., p. 29; percentages and average inserted by Transport Committee

21. Far from having 90 per cent of watches being staffed at recommended levels, nearly a
third are run at or below minimum levels. When we asked about the implications of
operating regularly at minimum levels, Captain Bligh said “I do not believe there are any
safety implications in running at the minimum level.”22 He also claimed that at times when
watches operated below minimum level other staff were undertaking training in new
technology on the premises.23
22. In contrast, the PCS drew our attention to the MAIB report on the fatality at Loch
Ryan. As the PCS pointed out, the report found
the watch manning level at Belfast MRSC did not meet the minimum requirement of
four, as defined by Coastguard guidelines. In addition, the three members of staff on
duty were all probationary and acting above their substantive ranks in the positions
they held during that watch… although Clyde did meet the minimum on the
evening watch… it failed to meet the recommended requirement of five staff…24
During the incident the MAIB found
22

Q 55

23

Q 53

24

Ev 22


12

The Work of the Maritime and Coastguard Agency

The Clyde Coastguard watch assistant dealing with VHF channel 16 monitored the
yacht’s “Pan Pan” call to Belfast Coastguard and made a typing error in omitting the
decimal point in the minutes of latitude. His attempt to correct the error resulted in
an anomalous entry (009 .9). Typographical errors are to be expected in the normal
course of events, particularly when complex messages are being précised in real time.
The watch assistant’s failure to make an unambiguous correction might have been,
in part, because of inexperience….25
23. As a result of this error, the search and rescue helicopter was initially directed to the
wrong place. We do not wish to castigate those involved in this incident; we are concerned
with the underlying problems. As the MAIB says
the procedures used in managing an incident do not seem to provide a robust
defence against transmission of simple typing errors. In part this is probably because
of the workload involved in the early stages of an incident…26
The MAIB concluded:
The Belfast Coastguard team was undermanned (below minimum level) and Clyde
Coastguard team was manned at below the recommended level. The three people on

duty in Belfast were all acting above their substantive ranks. Under-resourcing
possibly contributed to high workload which, in turn, contributed to the errors
made.27
We would add that in a larger team someone might have spotted the mistake in time to
send the helicopter to the correct location.
24. We note the MAIB report made no reference to the presence of other qualified people
on site able to assist the Belfast team. This evidence seems to undermine Captain Bligh’s
assertion that running watches at minimum levels has no safety implications.
25. Captain Bligh suggested that the staffing levels set out in Operational Advice Note/122,
which were set in 2001, had been superseded by new technology.28 In written evidence we
were told that that an interim operational advice note allowed the relaxation of existing
arrangements.29 We note that a review of staffing levels is underway, and in the interim, the
levels set out in the existing Operational Advice Note would be used as guidance, and
watch levels would be set on the basis of risk assessment by district operations managers
and watch managers trained for the task.30
26. For the year March 2003-February 2004, monthly figures showed that between 5.7%
and 12.4% of all watches were staffed below the minimum level. Over the year as a
25

Marine Accident Investigation Branch, Report on the investigation of the swamping and foundering of a 4.6m grp
open sports boat with the loss of three lives on Loch Ryan south-west Scotland 12 July 2003, Report No 5/2004 April
2004, 2.10.2.1

26

Ibid, 2.10.2.4

27

Ibid, 2.10.3

28

Q 53

29

Ev 34. It is unclear whether this is a general relaxation, or applies to Aberdeen and Forth Coastguard stations.

30

Ev 34


The Work of the Maritime Coastguard Agency

13

whole 8.6% of watches were staffed below minimum levels. It is unacceptable that,
month after month, nearly a third of all watches are operating at or below minimum
levels. We expect to receive a full briefing on the results of the staffing review when it
has reported. Given the seemingly inexorable rise in the number of incidents, accidents
and deaths, we would need to hear very convincing arguments before condoning any
diminution of recommended or minimum staffing levels.
27. The interim relaxation of arrangements would be acceptable only if we could be certain
that managers were given the staff they considered necessary. The PCS claimed that “watch
managers who complete risk assessments and request extra staff are being told that the
vacancy will not be filled and they are to run with the staff they have got”.31 In contrast,
MCA told us that “there have been no requests from Watch Managers to HR or Regional
Management for additional staff in the last 12 months”.32 The PCS maintained that the

appropriate route for such requests was through District Management.33 We asked the
MCA for clarification of this point. They told us:
There have been no recorded requests through District Operations Managers for
additions to the complement of Rescue Centres during the last 12 months. Records
of such requests would have been kept – in the case of written requests copies of
these would have been retained, and in the case of verbal requests these would have
been recorded at management meetings.34
We cannot decide between these competing claims, but it is clear from the PCS’s comment
that Coastguards themselves have little faith that watches have the staff they need with the
skills they need. We understand the interim arrangements until the staffing review is
completed will be that existing recommended and minimum watch levels are to be
treated as guidance and watch levels will be set on the basis of risk assessment. This will
only be acceptable if it is guaranteed that managers will receive the staff that the risk
assessments show they need.
Accident prevention
28. Captain Bligh has stressed his commitment to accident prevention which, he told us,
“has to go right across the Agency as a whole”.35 A new accident prevention branch has
been set up and a research programme is underway. As part of the increased emphasis
being placed on prevention, which we welcome, the Agency has developed a new Target. In
2003-04, the Target was:
Ensure that at least 5% of available Coastguard time is spent on prevention activity36
This has been superseded by the following Target for 2004-05:

31

Ev 22

32

Ev 29

33

Ev 42

34

Ev 40

35

Q 85

36

HC Deb, 10 April 2003, col 32WS


14

The Work of the Maritime and Coastguard Agency

Develop a robust statistical base and design a system which will allow the Agency to
measure accurately the impact of its incident prevention activity.37
29. In written evidence, Captain Bligh said
The Agency has always been involved in actively preventing shipping accidents…
Until recently, we have been less proactive in coastal incident prevention, having
considered that to be an operational search and rescue function. However, I see this
as requiring a similar approach to that already taken in relation to shipping:
identifying the root causes of an accident, determining what can be done to address

the cause, balancing the risks and the costs, and taking appropriate action on the
basis of that analysis. We have therefore brought our risk analysis and prevention coordination functions together. This will allow us to make the best use of the available
skills, by enabling us to take a more strategic approach to incident prevention, rather
than requiring shipping standards and operational activities to be considered
separately as in the past.38
30. We welcome the Agency’s commitment to accident prevention, and appreciate the
need for a Target which allows the Agency to assess more accurately which methods of
accident prevention are effective. We assume that the new Target is a transitional one
and that, once a system is in place by which types of preventative work can be assessed,
it will be superseded by a Target which challenges the Agency to implement a range of
effective prevention programmes.
Incidents, Accidents and Deaths: Conclusions
31. The rising numbers of incidents, accidents and deaths are very worrying. We are
concerned that the Agency has a tendency to explain these by referring to factors outside
its control while maintaining that actions for which it has responsibility—the closure of
rescue co-ordination centres, the time taken to respond to incidents, and staffing levels—
have no safety implications. The Agency’s Chief Executive cannot confidently maintain
that these factors have no safety implications while conceding that he did “not have a
straightforward answer” as to why deaths have increased39 and that he did not have
“detailed enough knowledge of each of those individual deaths to be able to identify what
was the primary cause”.40
32. The Maritime and Coastguard Agency has failed to review sufficiently swiftly its
actions in the light of the increasing numbers of incidents, accidents and deaths. The
Department for Transport should therefore commission an external independent
review. As well as considering factors such as suicides and use of coastal areas by the
public, that review should include the MCA’s responsibilities, and in particular should
examine the effect of closing rescue co-ordination centres; the time taken to respond to
incidents; and staffing levels.

37

HC Deb, 1 April 2004, col 99WS

38

Ev 31

39

Q 35

40

Q 42


The Work of the Maritime Coastguard Agency

15

Implementation of Integrated Coastguard Communication System
and Incident Management System
33. MCA’s 2002-03 Annual Report states that “the installation and implementation of the
Integrated Coastguard Communication System (ICCS) at all of our Coastguard Coordination Centres and our Training Centre was completed in February 2003. This has
been a most successful project and was delivered on time and within budget. We have also
similarly implemented the first two phases of the Incident Management System (IMS).
Development of the third phase is ongoing, and represents a major leap forward in
incident, message and report handling and most significantly, management information
collection and reporting. We hope to have this completed in August 2004.”41
34. PCS’s written evidence stated that “the radio communications part of this new

technology is working well and has been well received by our members. However…the
command and control side called ‘Vision’ is cause for concern and its installation has been
suspended.”42
35. In oral evidence, Captain Bligh said “the ICCS system is working well”,43 although he
noted that there had been “isolated incidents”, “a couple of problems with the
infrastructure” and one “major failure” caused by a lightning strike at a centre in
Falmouth.44 In supplementary written evidence, the MCA gave more details of this major
incident; and also of nine further incidents as a result of which, it stated, there was no loss
of distress and safety service. However, the “initial comments” relating to these incidents
makes it clear that these problems were, at the least, disruptive:
x

“ICCS – unable to change radio channels – error message on monitor (a serious error
has occurred while writing to drive C) system locked & unable to change over servers”
(of an incident in London);

x

“Both 999 & one ex directory telephone line lost” (Humber);

x

“Thames Barrier Navigational Centre – loss of sound all VHF and phones” (London –
Woolwich);

x

“ICCS screens continually faulting – hampering use” (Aberdeen).45

36. Given the evidence that the radio communications part of the new technology seemed

to be working well, but that there were reported problems with Vision – the command and
control part of the system – the Committee asked whether the latter had been suspended.
Captain Bligh said that it had not been suspended,46 but that there was a “temporary stop”

41

Maritime and Coastguard Agency, Annual Report and Accounts 2002-03, HC 863, p 21

42

Ev 23

43

Q 222

44

Qq 223-234

45

Ev 38-39

46

Q 234


16

The Work of the Maritime and Coastguard Agency

before “rolling the system out.”47 However, Captain Bligh was confident that the entire
system would be in place by November 2004.48
37. New technology frequently takes longer to refine than originally envisaged, and the
implementation date for IMS has already slipped from August to November 2004. The
MCA must ensure that the Incident Management System is not implemented until all
the problems so far encountered have been fully resolved, even if that requires a further
delay.

Staff issues
Qualifications and competencies
38. Captain Bligh told us that it was his belief that “over a period of time, we will find
ourselves in a position where those traditional pools of recruitment from which we are able
to draw will become less and less. So we need to find a way of possibly developing our own
people for the future, through training.”49 The “traditional pools” to which Captain Bligh
referred included entrants with formal qualifications. The potential diminution of
candidates with suitable qualifications, often coupled with some form of maritime
experience and expertise, has been one of the factors in the drawing up of a “competencebased recruitment system”, whereby the competencies required for each post are identified
and candidates assessed against them (on a system of levels from 0 – “no knowledge
required” – to 4 – “Specialist”– for technical and non-technical competencies; and at
“standard”, “higher” and “advanced” levels for behavioural competencies). Some, but not
all, of the competencies are equivalent to formal qualifications.50
39. The MCA’s subsequent written evidence stated that
posts for certain categories of professionally qualified marine surveyor are already
difficult to fill with suitably qualified personnel. Within the last month we have
needed to re-trawl three posts because, despite many applications, no suitable
candidates were found. The decade or so leading up to the mid-nineties had seen a
decline in the UK shipping industry and fewer graduates choosing seafaring as a

career. Consequently, the pool of potential marine surveyors shrunk. In the future
we will need to replace existing marine surveyors with home-grown professionals.
We are already recruiting marine technicians who can acquire specialist skills in a
surveyor development programme and over several years become fully competent as
marine surveyors.51
40. The written evidence also stated that
for surveyor posts and all Coastguard posts excluding Coastguard Watch Assistants
(Operations) (CWA(O)) there is a requirement to have some externally assessed
47

Q 240

48

Qq 244-245

49

Q 15

50

Qq 10-14

51

Ev 33


The Work of the Maritime Coastguard Agency

17

qualification(s), that demonstrates and confirms technical competence….The CWA
(O) post requires a specific level of numeracy and literacy at the recruitment stage, all
Coastguard technical competencies are developed by attending formal in-house
training courses… All Coastguard Watch Assistants and Watch Officers must pass
internally assessed examinations. It is the intention to have these internal
examinations externally accredited.”52
41. We wanted to know the degree to which postholders without externally or
examination-based competencies were able to fill posts normally requiring them on a
temporary basis. The MCA’s written response acknowledged the value of externally
assessed qualifications but also said that “if, for operational reasons, it is necessary for a
person without formal qualifications to carry out some aspects of a post for a short time, it
would be on the basis that they would have very strong and effective support and guidance
from a formally qualified colleague”. Asked what systems were in place to ensure that those
without relevant validated competencies filling posts on a temporary basis could gain such
validation, the MCA said that “there is no specific system or process in place” although it
did outline more generally the means by which training requirements were identified and
met.53
42. Given the likelihood of a future shortage of suitably qualified candidates for some
posts, it is only sensible that the MCA should seek ways to ensure its staff are up to the
job. However, in order to ensure that standards are not diluted, the Agency needs to
ensure that its internally identified competencies are at least as stretching as
comparable externally awarded qualifications. The Agency needs to move quickly to
ensure that its competency framework is externally assessed to ensure it is sufficiently
rigorous.
43. The Agency’s responses about the circumstances in which unqualified staff might
temporarily take on posts requiring qualifications suggested that its approach was entirely
ad hoc. The MCA needs to draw up proper formal guidance – and stick to it –

stipulating: the circumstances in which unqualified staff may temporarily fill posts
requiring specific qualifications or competencies; the regime in place to ensure such
staff are sufficiently supported and monitored; and the steps to be taken to ensure that
they receive the extra validations and/or qualifications required to fill the posts in
question substantively.
Administration
44. In our study of the Department for Transport’s Annual Report we noted “the Spring
Supplementary Estimate reclassified over £40 million of staff costs from administration
costs to “other current” costs in February 2003” and that “frontline delivery staff in
Departments and Departmental agencies are now charged to programme rather than to
administration costs.”54 In the course of our hearing on the MCA it became clear that the
reclassification had caused difficulties to the Agency, since its budget for 2002-2003 was
52

Ev 32

53

Ev 33

54

Transport Committee, Second Report of Session 2003-2004, The Departmental Annual Report, para 25


18

The Work of the Maritime and Coastguard Agency

only finalised in February 2003, and the Agency “ended up losing £700,000”55 “10 or 11

months into the financial year”.56 It is entirely unsatisfactory that because of Treasury
adjustments the Maritime and Coastguard Agency did not have its 2003-03 budget
settled until the financial year was almost over. In these circumstances, no blame can
attach to the Agency for the overspend. While we support attempts to improve the
accuracy of Government accounts, those making the improvements should be aware of
the potential operational impact of their actions.

Tackling pollution
45. The MCA is responsible for minimising the risk of pollution from ships and, where
pollution occurs, minimising its impact on UK waters, coastline and economic interests.
The Committee of Public Accounts (PAC) produced a Report on Dealing with Pollution
from Ships in January 2003. 57 The Report concluded, inter alia, that “the Agency should
exploit new technology to detect pollution offences and to identify and trace offenders.” 58
46. We were disappointed to discover that the Agency’s Chief Executive did not seem to be
aware of the PAC’s Report when giving evidence to us. Asked what had been done to
exploit new technology, Captain Bligh said “I do not have an answer.”59 Captain Bligh then
recalled that “we are apparently working with the EU on a satellite monitoring project on
detection of oil spills.”60
47. More generally, Captain Bligh did not seem to be championing innovative approaches
to tackling pollution. When invited to do so, he could not offer any technological,
regulatory or legislative changes he would like to see implemented in order to combat
pollution.61 He was confident that the Agency had sufficient resources in this area.62
48. The MCA summarises its objectives as Safer Lives, Safer Ships, Cleaner Seas.
However, the Agency’s Chief Executive appeared not to be briefed on a key Report
about pollution from ships, was apparently unaware of the one example the Agency
could muster as evidence of its exploitation of new technology, and could not suggest a
single desirable legislative, regulatory or technological change. The Department should
review with the MCA the strategic approach provided by the Agency on pollution
matters.

Policy formulation
49. The Department for Transport’s 2003 Annual Report stated that “the Department’s six
executive agencies are central to delivering the Government’s transport policies and
55

Q 214

56

Q 216

57

Committee of Public Accounts, Second Report of Session 2002-03, HC 119

58

Ibid., para 2

59

Q 96

60

Q 98. The Agency subsequently provided the Committee with updates on the Public Accounts Committee conclusions
on Survey and Inspection and Dealing with Pollution from Ships (not printed)

61

Qq 91-92

62

Q 94


The Work of the Maritime Coastguard Agency

19

services. In developing a new structure for the Department, an important priority has been
to strengthen the role and position of the agencies, ensuring they are fully engaged in
shaping as well as delivering policy”; and that “In its policy development function, the
MCA works closely in partnership with the Department’s Shipping Policy division.”63
50. In oral evidence, Captain Bligh said that the MCA had influenced policy on maritime
security and had been involved in discussions on “a number of Directives and statutory
instruments.”64 However, he also said “I am not aware of any major shipping policy issues
that I have been directly involved with since I took office”65 and could not point to any
specific outcomes achieved as a result of the MCA’s involvement in a policy debate.66
51. In subsequent written evidence, the Agency outlined the “regular formal and informal
contact with DfT at all levels”, but, responding to a question about the policies it had
influenced or changed, said that “our relationship with the Department works on a
different basis…. The Agency works collaboratively and collectively with its parent
Department and respects the principle of a two-way ‘no surprises’ rule.”67
52. The RMT’s written evidence noted that
The MCA needs to be more aware of the wider DfT Government objectives for
shipping and information needs to be effectively shared between the two
organisations so that policy objectives can be pursued effectively.68
We are not convinced that the MCA is intervening effectively in the policy debate. For

example, it was clear from our evidence that the MCA did not consider itself to be an active
participant in the policy debate on the siting of offshore windfarms. When we first asked
about this, we were told that the MCA’s role was to circulate guidance, after initial
decisions had been taken. Further questioning produced a response that the policy was the
responsibility of “another department” (that is, the Department of Trade and Industry,
rather than the Department for Transport). Finally we elicited the following exchange:
Captain Bligh: There have been a number of meetings between the Department of
Transport and the DTI.
Chairman: At which we can take it you suggested it was not a good idea to build
wind turbines in a navigable shipping lane, or am I misinterpreting what you say?
Captain Bligh: I am sure that advice was given.69
Captain Bligh made it clear that he had some “personal concerns” about development of
policy on offshore wind farms. It is astounding that he could not tell us clearly what he had
done to convey those concerns to others within government. It is alarming that the
63

Department for Transport, Annual Report 2003, CM 5907, paras 2.12, 2.13 and 7.33

64

Qq 198 and 200

65

Q 197

66

Q 202

67

Ev 31

68

Ev 25

69

Qq 152-3


20

The Work of the Maritime and Coastguard Agency

Agency’s Chief Executive could not give us specific examples of the MCA's influence on
policy debates. It is clear from the evidence we took on offshore wind farms that the
MCA is not engaging properly with the policy development process. The Department
needs to ensure that the Agency’s views are fully taken into account at an early stage in
the formulation of relevant policy. But the principal onus is on the Agency itself to
identify areas of emerging or deficient policy and to make coherent and pragmatic
proposals to the Department. The head of the government’s maritime safety agency has
not only the right but the duty to make his views about matters which could affect the
safety of navigation known to those formulating policy.
Justification for policy
53. We also asked Captain Bligh to answer complaints from the Inland Waterways
Association and the Royal Yachting Association that the Agency may be overregulating
some activities. He told us that he did not believe that the measures were disproportionate,

but maintained that “I am not aware of a measurement technique to decide whether it was
proportionate.”70 We asked for copies of the Agency’s regulatory impact assessments
(RIAs). We note that they are brief in the extreme, and one, on the Introduction of
Commercial Inland Waterways Boatmasters’ Licences, lacked any figures for costs. The
written evidence explained
The RIA on International Standards for Commercial Inland Waterway Vessels is
only partial because there was a fundamental lack of national vessel information on
which to base a complete one. It was hoped that feed back from the consultation
would provide some further information on vessels and likely costs.71
54. Cabinet Office guidance makes clear “the initial RIA provides a rough and ready
assessment based on what is known. This helps to identify gaps in knowledge and aids the
collection of fuller, more accurate information, for example through external consultation.
This is then developed into a partial RIA which contains more detailed policy options and
refined estimates of the costs and benefits.”72
55. As far as benefits are concerned, the RIA notes “This is an area for which accident
statistics have never, up to now, been compiled. Therefore it is difficult to quantify the
positive effects on safety resulting from the proposal”.73 The RIA’s analysis of costs boils
down to a guess at the cost of licences, a recognition that any increased costs will be
difficult for the many small businesses in the sector to bear, and two blanks for the total
costs in the first and subsequent years. This is hardly a “refined estimate of the costs and
benefits”.
56. Not only does the MCA’s RIA contain no real figures for costs and benefits, it misstates
the case for its policy. The RIA claims that a national Boatmasters’ license, which is to
apply to all commercial and passenger vessels, is made necessary by European Council
70

Q 181

71

Ev 29

72

Cabinet Office, A Quick Guide to Regulatory Impact Assessment

73

National Inland Waterways Boatmasters’ Licence, Regulatory Impact Assessment, section 3


The Work of the Maritime Coastguard Agency

21

Directive 96/50/EC.74 The Consultation Document claims that “as a member of the EC, the
UK is obliged to implement this directive.”75 In fact, Article 3 of the directive itself makes it
clear that the directive does not apply to
x

boatmasters of vessels intended for goods transport which are under 20 metres in
length,

x

boatmasters of vessels intended for passenger transport, which carry no more than 12
people in addition to the crew.

57. In addition, it provides that:
A Member State may, after consulting the Commission, exempt from the application

of this Directive boatmasters operating exclusively on national waterways not linked
to the navigable network of another Member State and issue them with national
boatmasters’ certificates, the conditions for obtaining which may differ from those
defined in this Directive. The validity of those national certificates shall in that case
be limited to those waterways.
58. The MCA recognises that since the mainland United Kingdom has no national
waterways linked to the navigable network of another Member State it would be possible to
exempt national waterways, but claims an obligation to introduce “national measures that
attain equivalent standards to those required by the Directive”.76 It is not clear to what
extent the MCA has consulted the Commission as the Directive envisages, and whether
this is a condition of exempting the UK from the Directive imposed by the Commission.
This is something the consultation or the RIA should make explicit. The MCA also prays
in aid a commitment to revise the present Directive given in the EC Transport White
Paper, even though “the EC has made little progress with this to date, so we do not yet
know the details of the revisions”.77
59. Given that the Directive says that certificates for national waterways shall only be valid
on such waterways it is puzzling that the RIA claims that the UK National Boatmasters’
Licence should make it easier for any boatmaster who wished to work on inland waterways
within the EU.78
60. The MCA claims that its proposals for boatmasters’ licences will not impose any
requirements that are more onerous than those of the Directive on Harmonisation of
the conditions for obtaining national boatmasters’ certificates for the carriage of goods
and passengers by inland waterways in the community. In fact, they will apply
standards to vessels not covered by the Directive. This is gold plating at its worst. The
MCA’s statement is true only in the sense that it does not apply the detailed technical

74

Ibid, section 1

75

National Inland Waterways Boatmasters’ Licence, Base Consultation Document, para 12

76

National Inland Waterways Boatmasters’ Licence, Base Consultation Document, para 12

77

National Inland Waterways Boatmasters’ Licence, Base Consultation Document, para 13

78

National Inland Waterways Boatmasters’ Licence, Regulatory Impact Assessment, section 3


22

The Work of the Maritime and Coastguard Agency

requirements needed for navigation on major continental waterways to the entirely distinct
United Kingdom system.
61. The justification and cost and benefit analysis given for the proposals for an Inland
Waterways Boatmasters’ Licence is entirely inadequate. If the MCA does not have the
information it needs to make sensible policy, it should do the necessary research before
it makes proposals.


The Work of the Maritime Coastguard Agency

23

3 Future of the Agency
Rescue co-ordination centres
62. We have already noted that no full assessment of the closure of Oban, Pentland and
Tyne Tees centres has been carried out. In their written evidence, PCS claim that
The MCA had… made a commitment that there would be no station closures during
the ten year life of the integrated communications and control rescue centres (ICCS).
Despite the fact that the ICCS is still being installed… the Chief Executive has given
Ministers a list of rescue centres that could be closed if there is the political will to do
so.79
63. Captain Bligh denied this claim when giving oral evidence and said “I have not given a
list of rescue centres. I have discussed the situation informally internally that, if I was
required to do something, what would be some of the options that we would have to take if
we were asked to cut our costs. I made a statement that we should be looking at these
things. I believe that it is my duty as Chief Executive at least to put these debates in the
round…”80
64. We have criticised the Agency for not taking the initiative in forming policy. It is
ironic that the only case of initiative we have found—a discussion of which rescue
centres might be closed should the Agency be asked to make cuts—is entirely
undesirable and destabilising. It is unacceptable to contemplate further closures when
there has been no full assessment of the closures already made, and the numbers of
incidents, accidents and deaths are increasing.

Agency’s Remit
65. PCS’s written evidence stated that Captain Bligh told a management seminar “he would
like to see one organisation covering all marine issues.”81 In oral evidence, Captain Bligh
said he had been talking “in general terms” and that he needed “to understand more about
the organisation themselves”. Pressed by our Chairman, he conceded that he was not

resiling from the statement, but saying “not yet”.82
66. The Agency’s existing remit is extensive. With a very high degree of dedication and
professionalism, its staff do the important work of responding to incidents on the coast
and at sea, dealing with pollution incidents, managing the shipping register, inspecting
foreign registered ships visiting UK ports, and ensuring seafarers are qualified and
competent. The comments made in this Report reflect on the need for those at the top
of the Agency give its staff the leadership they deserve. On the evidence we have taken,
the MCA has failed to intervene effectively in the policy debate. Its own policy
proposals are made without proper analysis. Most damningly, when accidents and
79

Ev 22

80

Q 75

81

Ev 22

82

Qq 18-20