The recent inspection conducted by the European Maritime Safety Agency (EMSA) has highlighted numerous deficiencies in the Montenegrin education and training system for seafarers, particularly in the operations of the state maritime administration. It appears that the relevant ministry, which has undergone multiple name and structural changes in recent years, has either neglected or remains unaware of the persistent issues affecting this system.

“Vijesti” has obtained a copy of this report.

Due to the failure of certain educational institutions and seafarer training centers in Montenegro to adequately implement or partially apply specific regulations from the international STCW Convention, along with ineffective oversight by state maritime administration bodies, seafarers holding Montenegrin documentation could face significant challenges.

Risks

The issues identified in the latest EMSA report have been ongoing for years, culminating in a substantial risk that Montenegrin seafarers, whose certificates of professional competence are met with skepticism by the international community, could find themselves on the International Maritime Organization’s (IMO) so-called black list. Such a development would be catastrophic for approximately 6,500 Montenegrin seafarers and around 2,000 foreign nationals sailing with Montenegrin credentials, severely hampering their job prospects. This situation would also jeopardize the livelihoods of tens of thousands of families in Montenegro dependent on these seafarers, while depriving the state of around 300 million euros in annual income generated by these seafarers abroad and subsequently funneled into the national economy.

As of now, the Ministry of Maritime Affairs, led by Filip Radulović (PES), has not communicated the specifics of the EMSA report, which was compiled by inspectors Monika Malinska and Janis Dobris between May 24 and June 2, 2023. Their evaluation focused on Montenegro’s maritime education, training, and certification system, particularly its compliance with the International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers (STCW)—one of the three cornerstone conventions underpinning the global maritime industry.

Countries with certificates already recognized at the EU level are required to undergo a periodic re-evaluation at least once every ten years since their last evaluation. This recent inspection was carried out to facilitate the European Commission’s re-assessment of the Montenegrin system, involving site visits by EMSA inspectors to the Ministry of Capital Investments (MKI), the Port Authority of Bar, the University of the Adriatic – Faculty of Maritime Affairs and Tourism Bar (FPT Bar), and the BMV Shipping Services Seafarer Training Centre in Bar (BMV SSB).

In the past few days, Minister Radulović has held discussions with representatives from the Seafarers’ Union of Montenegro and the Captains’ Association from Kotor, assuring them that the government will take immediate corrective measures.

Remarks

EMSA inspectors identified numerous deficiencies, particularly regarding some educational institutions and seafarer training centers, where “certain rules from the international STCW Convention are inadequately implemented.” They emphasized substantial concerns regarding the functioning of state examination commissions at the port authorities in Kotor and Bar, specifically regarding record-keeping practices and the credibility of candidates applying for maritime titles after completing training at these centers. The inspectors pointed out ongoing conflicts of interest involving some Ministry of Maritime Affairs officials, who simultaneously serve as state representatives overseeing the training centers and as instructors at those very centers for compensation.

“The EMSA inspectors found three main deficiencies within Montenegrin legislation concerning the qualifications and training of assessors, instructors, and supervisors, as well as on-board training. Additionally, there are inadequate requirements for the certification of officers in charge of navigational watches and engine departments (OEW) and electrical engineering officers (ETO), failing to mandate ‘combined workshop skills training and approved seagoing service’. Furthermore, the training programs offered by the Montenegrin educational institutions (MET institutions) did not encompass practical skills training or possess sufficient facilities and equipment to deliver necessary training in accordance with the STCW Convention,” states the report summary.

Montenegro has purportedly established a system for approving education and training programs based on agreements with recognized organizations (ROs), which have been tasked with auditing and certifying MET institution programs to ensure compliance with the STCW Convention.

“Yet, the Ministry of Capital Investments has failed to monitor whether these ROs fulfill their responsibilities as per the agreements, with the EMSA inspection revealing shortcomings in program quality and a lack of the requisite equipment and training facilities necessary to adhere to STCW standards,” the report summary highlights.

This inspection was conducted in line with EU Directive 2022/993 regarding the minimum training standards for seafarers. EMSA is mandated to conduct inspections in third countries to gather pertinent information on the STCW Convention’s implementation. Such inspections occur following a Member State’s notification to the European Commission regarding its intention to recognize third-country certificates. If a country has been recognized by the EU before, inspections are performed regularly or ad-hoc in response to complaints. Findings are categorized as deficiencies or observations, with “deficiency” denoting non-compliance with STCW rules and “observation” reflecting potential issues that could escalate into deficiencies if unresolved.

21 Deficiencies

The report outlines a total of 21 deficiencies and one observation. Inspectors found discrepancies in Montenegrin regulations concerning simulator training and practical experiences for instructors and examiners assessing candidates utilizing simulators. Additional concerns included the absence of regulations defining a “Ship Training Logbook” that young maritime trainees—deck cadets and engineer assistants—must maintain. It was indicated that candidates for engineer officers and electronics officers do not receive “combined training for acquiring skills through workshops and approved maritime service,” primarily due to inadequate training institution capacity. Notably, the lack of equipment and facilities adversely affects training programs on essential survival techniques, cargo management, and firefighting protocols as outlined by FPT Bar and BMV SSB.

Moreover, Montenegro has failed to meet the obligation of reporting to the IMO, every five years at minimum, regarding independent evaluations of the quality systems in its maritime training bodies, with the most recent report filed on November 2, 2005. For years, the Ministry of Capital Investments has also not supervised the audit and certification activities assigned to educational institutions for maritime training. Such audits are meant to ensure compliance with IMO course models, typically conducted by recognized organizations (mostly foreign classification societies like Bureau Veritas or RINA).

“The contracts established between MKI and ROs contained provisions for monitoring the activities assigned to them, intended to confirm adherence to agreed standards. However, in the years leading up to the EMSA inspection, MKI did not adequately oversee the audit and certification duties performed on its behalf by MET institutions,” the EMSA audit report asserts.

The European inspectors noted that “the established facts in the maritime education and training institutions indicated that the approval system in Montenegro does not fully guarantee conformity with the required STCW standards.”

EMSA concluded that the relevant ministry did not effectively monitor the educational institutions and centers or the authorized organizations meant to oversee them.

Persistence of Fraud

The report also revealed that the Port Authority of Bar has failed to implement processes for addressing reported instances of incompetence, fraud, or illegal activities concerning maritime certificates.

“Consequently, the Port Authority of Bar lacked a foundation for verifying documents submitted by seafarers for certificate issuance, despite some checks being conducted in practice, such as scrutinizing maritime service certificates and responding to fraud cases by rejecting seafarers’ applications. Instances of fraud and unlawful actions pertaining to certificates were detected, particularly regarding information on certificate statuses requested by third parties. A recent fraudulent case examined by the EMSA team involved a Montenegrin seafarer attempting to acquire a certificate of recognition from an EU Member State due to a lack of established procedures,” the report elaborates.

Questions of Accountability

An experienced seafarer shared unofficially with “Vijesti” that EMSA has reaffirmed that the entire system in Montenegro is flawed, but it refrains from investigating the root causes of these persistent issues.

“It is essential for the responsible authorities in our nation, including the prosecutor’s office, to ascertain whether the findings from EMSA stem from ignorance and incompetence within the leadership of the Ministry of Maritime Affairs or if they indicate organized criminal activity profiting at the expense of seafarers. All this inadequate training, exams, and certificate issuance, for which seafarers pay significant fees, is troubling,” the source added.

According to this individual, it has been demonstrated that the Ministry of Maritime Affairs is closely linked to these training centers and institutions, as many officials serve as paid lecturers there.

“These same individuals, as state officials tasked with oversight, have vested interests in certifying and inadequately supervising training centers lacking the required equipment for their registered training offerings. Once again, these officials, for additional fees, function as examiners for the state in commissions that evaluate candidates trained at the same centers where they are employed. The implications of this situation are concerning,” an outraged and seasoned Montenegrin seafarer expressed to “Vijesti”.