Written evidence submitted by the National Union of Rail, Maritime and Transport Workers (MAR0013)


I am writing in response to your Committee’s request for evidence as part of the inquiry into the Government’s Maritime 2050 strategy.


RMT welcome TRANSCOM’s inquiry into the Government’s Maritime 2050 strategy, published in January 2019 and which informs the DfT’s Recovery Route Map for the industry post-pandemic.


RMT organise over 4,000 dock workers and UK seafarers, predominantly deck, engine, catering and on-board service Ratings working in the short sea passenger ferry and offshore energy sectors, and the Royal Fleet Auxiliary. Seafarer Ratings are specialist maritime staff, working to support officers across all departments on all types of ship, from passenger ferries and offshore supply to cargo and container vessels. In the early 1980s, there were around 30,000 Ratings working at sea in the UK merchant navy out of a total workforce of nearly 60,000 UK seafarers.  By June 2021, there were under 10,000 Ratings resident in the UK, accounting for 11.5% of all Ratings jobs in the UK shipping industry.[1]


All of our members in the maritime industry are affected by the themes in the Maritime 2050 Strategy as they have evolved since January 2019. Prior to the P&O crisis, these themes were people, competitiveness, regional growth, environment, innovation and security and resilience.


I should state at the outset that P&O Ferries scandalous and illegal assault on UK seafarers’ jobs and trade union rights has thrown the Maritime 2050 strategy up in the air. In our view, the scope and ambition of the Maritime 2050 strategy for British Ratings was inadequate and has been proven to lack the regulatory bite required to reverse the steady erosion of merchant seafarer jobs, training and skills in our advanced island economy over the past thirty years.


Whilst the development of the Maritime Skills Commission proposed by the Maritime 2050 strategy is welcome, RMT strongly believe that more has to be done to assess the yawning skills gap that exists in Ratings employment in the UK shipping industry. That skills gap and the lack of employment opportunities is a direct result of the growth in the low-cost crewing model which P&O illegally and aggressively imposed on UK Ratings and Officers on 17th March this year.


RMT was invited to make a presentation to Maritime Skills Commissioners on 10th March. We are awaiting a further update and place on record our support for the work and role of the Maritime Skills Commission.


More immediately, the P&O Ferries scandal has dragged the exploitative employment practices that are driving down employment and living standards in our key maritime communities into plain sight for the public and politicians of all parties to see.


The Government’s response to P&O Ferries actions through the nine-point package announced to Parliament by the Secretary of State for Transport on 30th March is careful to echo elements of Maritime 2050. For example, the recommendation under the People route map to develop a ‘social framework’ for seafarers


….under the social framework apply to the National Minimum Wage, harmonisation of certification standards, harmonisation of employment standards for those at sea, mental health support, better representation at the international level via the International Maritime Organization (IMO) and International Labour Organization (ILO), addressing issues such as seafarer fatigue, seafarer welfare and modern day slavery.”[2]


The ’social framework’ is a short term aim for Maritime 2050, to be achieved by 2024. This is clearly now an imperative for the industry and that timeline should be brought forward.


RMT would point to the progress the trade unions have made with some employers in the ferry industry since the P&O crisis engulfed our members and the maritime industry. The Fair Ferries National Framework Agreement (Fair Ferries Agreement) sketched out to Government by the Unions and employers must be adopted as a priority within a re-booted Maritime 2050 strategy.


Not only is this necessary to reverse the impact of P&O’s actions, it would prevent contagion spreading to major employers of UK seafarers in the ferry industry. We also believe that it serves as a template for seafarers across the UK and international shipping industry, where employment practices also fall well short of what would be acceptable for land-based workers.


The principles underpinning the Fair Ferries Agreement are:


  1. Urgent legislatives steps to ensure the complete reversal of P&O Ferries dismissals and legislation to ensure that it can never happen again.


  1. The 2018 Statutory Instruments transposing the EU Seafarers Directive said its purpose was to place those employed at sea on an equal footing with land-based employees. This language and ambition should underpin the reform package to level up seafarers’ employment and other conditions.


  1. At present, employers are incentivized to remove UK ratings and officers not just because seafarers are excluded from minimum wage legislation but also because they are excluded from other protections that apply to land-based workers. So, this reform package should level up all seafarers’ employment rights with land-based workers. DfT/BEIS should work with the unions and industry identify where there are detrimental differences and if possible seek agreement on removing them.


Control of these arrangements should be underpinned by legislation requiring a Fair Ferries National Framework CBA based on industry support from the ferry operators and the maritime unions.


We have also called for the Government to implement a certification approval process to operate through the MCA with regards to ferry services operating to or from a UK port on international routes. The Government has heeded this call in the package of measures announced on 30 March and the resulting correspondence between the Secretary of State, the Maritime and Coastguard Agency and the ports sector.[3]


Vessels and Scope


  1. Regular Scheduled Ferry Services to and from the UK and within the UK i.e. RoRo, Ropax, LoLo. This includes time or bareboat charter vessels.


  1. Exemption for temporary vessels brought in to cover dry-docks and any force majeure situations and subject to confirmation with the maritime trade unions.




  1. Safe roster patterns – maximum of two-weeks on and two-weeks off; or less (only extension in force majeure situations and agreed with the maritime unions e.g. Covid-19 global pandemic). In order to ensure safety and well-being of all crew, commitment to a safe roster pattern of no more than 14 days followed by an equal amount of rest – this must be a rostering principle; exceptions covered by Collective Bargaining Agreements between employers and RMT and Nautilus.


  1. Adherence to rest hours directive for seafarers set out in the ILO Maritime Labour Convention, 2006 as amended and a commitment to go beyond this minimum international standard, where possible in the UK ferry sector.


  1. One-week minimum familiarisation for newly employed seafarers or those seafarers joining via a crewing agency for the first time.


  1. Adherence to IMO Standards in Training, Certification and Watchkeeping (STCW) 1995, as amended, in relation to basic safety training requirements for all crew which includes Personal Survival Techniques, Personal Social Safety Responsibility, Crowd Management (Ro-Pax only), Elementary First Aid and Basic Fire Fighting.


  1. Mandatory training for safety officer and safety representative roles.




Minimum wage and other employment conditions proposed are flag blind, to be implemented, where possible by route through a mechanism agreed between Government, trade unions and ferry operators:


  1. The UK Ferry sector must be covered with legislation that references UK NMW being applicable but minimum rates of pay should be set through a Fair Ferries National Framework CBA with the union(s) in the Flag state or country at either end of the route.


  1. An agreement between trade unions and employers to establish agreed core crewing levels with consideration given that all core crew must be permanently employed.


  1. NMW as a minimum applies to all seafarers for the entire route and establishes the wage floor. This provides the base from which industry norm differentials are calculated. No offsets permissible for food and/or accommodation, death/disability, communications, welfare and training.


  1. Voyage only contracts should be avoided with preference to permanent employment for passenger delivery positions that are based on increased passenger demand or other short-term requirements.


  1. Agreed minimum content level of UK/local/flag state ratings and officers across the regular assigned vessels.


  1. A review of financial incentives for seafarers and employers; Employer/Employee National Insurance and Seafarers Earning Deductions.


  1. Minimum of DC pension at auto enrolment rate (UK) or equivalent scheme.


  1. Nationality based pay discrimination to be eradicated. The Government stated in June 2020 that a review of pay discrimination on international ferry routes would be held ‘by the end of the year’[4] but this has yet to happen. In that time, Irish Ferries has expanded its low cost operation onto the Dover-Calais route.


  1. Employers of seafarers in the UK ferry sector must demonstrate they are working with recognised trade unions and encouraging good industrial relations. This should also be a condition of licences granted to operators by port authorities. Such as a procedural/recognition agreement as well as CBA’s.


Flag and Training – UK flagged vessels


  1. If a vessel carries UK flag a reduction in light dues by a percentage is applicable as agreed by the government and shipowners if the company is meeting its UK seafarer training commitment.


  1. Increased funding through Support for Maritime Training (SMarT) for Ratings and Cadets.


  1. If ferry operators are training greater numbers of Ratings and Cadets than can be employed by that operator, then increased SMarT funding should be provided to cover the full cost of those additional persons being trained.


Maritime 2050 trumpets the action the Government planned, with trade union agreement to introduce NMW for seafarers on domestic routes. That change was introduced via Secondary Legislation in October 2020.[5] In the Delegated Legislation Committee, the then Shipping Minister, Kelly Tolhurst MP at the time stated quite clearly that this change would only apply to


“…those who operate domestically, from port to port, and does not cover ferry routes such as that from Dover to Calais.” [6]


Irish Ferries set up operations on the Dover-Calais route in June 2021, and the RMT warned the Government then that this low cost contagion could spread to other ferry operators on the Dover-Calais short sea routes if action was not taken against low cost crewing on this and other international ferry routes.[7]


P&O’s actions have exposed this modest NMW reform as an inadequate response that does nothing to address the chronic exploitation of foreign seafarers on international ferry and other regular shipping routes servicing passengers and the UK economy. RMT and cross-party MPs have consistently asked for the seafarers NMW review to be extended to cover seafarers on international routes. We strongly believe that the Maritime 2050 strategy has to be updated to reflect this renewed ambition to protect and develop UK Ratings jobs and skills.


Until the P&O scandal, the Government and the Maritime 2050 strategy had claimed that this would not be possible. We welcome the actions in the nine-point package which overlap with some of the Maritime 2050 ambitions, including at international level for seafarers welfare but, I repeat that it is clear for all to see that the Maritime 2050 Strategy itself needs to be amended.


One of the architects of Maritime 2050 and other reforms to seafarer employment protections, the former Shipping Minister and current Transcom member Nusrat Ghani MP stated at the joint select committee session with the relevant Ministers:


“….the actions of P&O Ferries have trashed some of the ambitions that are in Maritime 2050, and they have been hugely damaging for the sector and the reputation of the UK, whether it is for the flag or whether it is for the MCA or for all the work that we are trying to do to encourage firms to come on board and fly our flag, or even to hire our seafarers.” [8]


We have a number of concerns around Maritime 2050’s other themes in addition to ‘People.’ For example, the 2050 strategy does not take any action against flags of convenience such as Cyprus and the Bahamas which have driven the rise of low cost crewing at the expense of employment and training for UK seafarers. The P&O scandal has clearly exposed this and a response to the role of low regulation, low tax ship registers must be clear and robust.


We strongly believe that the UK Ship Register must not seek to compete with Flags of Convenience for international tonnage but grow the fleet and lead the international maritime industry through promoting higher employment and safety standards for seafarers. P&O Ferries actions must be a line in the sand over the exploitation and abuse of international crews, and a wake-up call for Government to tackle crewing agents that act with impunity when an employer breaks the law.


The Maritime 2050 plan also recommended that the Government pursue Freeports across the UK. The tensions between Freeports and employment law, trade union rights, taxation, freedom of information, environmental and safety regulations are well documented and RMT share concerns in all of those areas.


We would point out the role of P&O’s owner DP World in the development and operation of Freeports, and the wider UK maritime supply chain through their ownership of P&O Ferries. This raises further and serious concerns over the suitability of a multi-national that breaks UK law in a premeditated fashion in order to dismiss hundreds of dedicated maritime workers to replace them with low cost crews just to avoid consulting trade unions. It is absolutely essential for the Maritime 2050 strategy to be re-balanced in favour of the collective bargaining rights of seafarers, port staff and all maritime workers.


We must never forget that good industrial relations were also a victim of P&O’s purge of UK seafarers with an average of twenty years experience working on a fleet which had suffered chronic under investment since the Dubai state purchased P&O in 2006.


RMT would welcome the opportunity to provide your committee with further evidence as part of the inquiry into Maritime 2050.



April 2022



[1] Table SFR0303 https://www.gov.uk/government/statistics/seafarers-in-the-uk-shipping-industry-2021

[2] Para 2.21, Pg 11 Maritime 2050 – People Route Map January 2019.

[3] https://www.gov.uk/government/publications/new-powers-to-protect-maritime-workers

[4] Hansard Col 431 25 June 2020, House of Lords.

[5] https://www.legislation.gov.uk/ukdsi/2020/9780111195895/contents

[6] Hansard Col.8 Delegated Legislation Committee 22 June 2020.

[7] https://www.bbc.co.uk/news/business-60876918

[8] Q267 Transport Select Committee Transport Committee & BEIS Committee Oral evidence: P&O Ferries, HC 1231 24 March 2022.