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The UK Ship Register – revisiting some old debates

The thing that hath been, it is that which shall be; and that which is done is that which shall be done: and there is no new thing under the sun.

Ecclesiastes 1:9 KJV

In December last year, KPMG delivered to the Department for Transport the report the ministry had commissioned on the future of the UK Ship Register. In brief KPMG recommended a “part-privatisation” of the Register by spinning it out into a “Govco”, i.e. a privately held state-owned company which though subject to government oversight would have greater commercial freedom including over the employment terms of its staff.

In response, the PCS civil service union expressed concern, fearing a fall in regulatory and safety standards and a model more like the Panama, Liberian or Bahamas flags, notwithstanding the latter three being more important flags to the maritime industry than the UK and all being white list flags. The RMT union raised similar concerns as to the “cheapening” of the Register. By contrast the UK Chamber of Shipping considered that greater commercialisation of the UK Ship Register had become a priority in consequence of the Brexit vote.

Without wishing to take sides on matters administrative and political, it seems to WQW that what matters is not the ownership model so much as the willingness to make some small changes that could make the UK Ship Register more user-friendly, for example:

- Raising the registry’s fees (e.g. on a ship sale or mortgage transaction) so as to enable the registry to afford to provide a service level equivalent to other Red Ensign flags like the Isle of Man or the Cayman Islands. There is room to do this without losing competitiveness. It may seem odd to be suggesting that shipowners should pay more fees in a market where every additional cost is painful but the cost in wasted management or advisor time is considerably higher if the service level from the Ship Register is not in accordance with best industry standards. There would need to be safeguards for owners of smaller vessels, workboats, fishing vessels etc where the service level issue is less pressing – but a type of graded fee structure already exists, namely the “Premium Service” and this could be built on;

- Opening a counter in London (it would not need to be permanently staffed) so that original documents, especially Bills of Sale and Mortgages, can be deemed delivered to the MCA as soon as they deposited with that counter. Given a very large number of shipping completions occur in London and will no doubt continue do so, this simple facility would make everyone’s life easier (apart perhaps from the courier companies!). The foregoing proposal should be no threat to jobs in Cardiff and is not intended as some kind of Trojan horse to drag the Register to London; and

- For an additional fee and travel expenses, making provision for a registrar to attend completion meetings.

Perhaps we just have to get away from the public/private sector dichotomy and ideological viewpoints. Privatisation is no guarantee in itself of good service delivery and one would have thought that lesson should have been learnt over the last generation in the UK.

The Department for Transport devotes far more time and resource to the rail transport mode than to shipping. That needs to change and hopefully KPMG’s report, whether its recommendation is in the end the right one or not, will help concentrate minds.

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