Letter: DPSN

BUENOS AIRES, 18 September 2002

Considering the information provided by the Safety of Navigation Police Direction about increasing the number of pilots in the compulsory Pilotage Area in the River Plate, and


That due to the extension of the Punta Indio Channel in the River Plate from Km 205.3 to the current Recalada Station in the proximity of Km. 239.0, there is a substantial increase in the time used for navigation from the beginning to the end of the route, thus causing that ships of 8.84 m (29’ 00”) or upwards in length need more than 10 hours to navigate such route.

That when considering the time incurred by ships in the above-mentioned route, it should be taken into account that most ships must remain anchored in the vicinity of km 99 waiting for the proper tide to navigate the Punta Indio Channel under safety conditions, which leads to an additional 10-hour period.

That this Maritime Authority has designated only an area between pair of buoys No. 3 and 7 in the Punta Indio Channel where crossings of ships of 8.84 m (29’ 00”) or upwards in length are allowed. This preventive measure has increased safety of navigation parameters as regards collision and/or grounding avoidance but led to an increase in pilotage duration.

That conclusive results have been obtained from the analysis made on the navigation time used for pilotage as from the above-mentioned action taken to date, as out of all ships above 29’ 00” in length which have navigated with only one pilot, 96.8 % did it in more than eight (8) hours; 74.2 % in more than (9) hours and 29.0 % in more than 10 hours.

That this increase in the duration of pilotage -even though the navigation route is less than 220 kilometres long- can cause fatigue in marine pilots with the resulting incidence of accidents this problem may have. For this reason, it is necessary to take preventive measures, both for safeguarding human lives and for preventing property and environmental damages.

That in accordance with studies and investigation reports, human error is the primary cause of the majority of accidents related to water transportation. Consequently, preventive actions to be taken must effectively reduce the incidence of human error.

That considering the issue of fatigue in professionals and its incidence in human factors which contributes to marine casualties, the International Maritime Organisation (IMO) has concluded that great part of the accidents are the result of the fatigue of maritime crew members and of the professionals who fulfil route advisory functions, as is the case of the pilots where navigation takes a long time, or is performed in restricted waters.

That the International Maritime Organisation (IMO), through the Maritime Safety Committee (MSC) established a Working Group intended to study the role of fatigue in maritime safety, following a review of an analysis conducted jointly by the said MSC and the Marine Environment Protection Committee (MEPC) Working Group on the Human Element (HE), which highlighted the acceptance made by IMO with regard to the definition of fatigue as the reduction of physical and/or mental capability as the result of physical, mental or emotional exertion which might impair nearly all physical abilities including strength, speed, reaction time, co-ordination, decision making, or balance.

That article 12 (Pilotage Regime) of the Rules on Pilotage Services in Rivers, Passages and Channels of the Argentine Republic, para. c) empowers this Maritime Authority to provide an increase in the number of pilots for navigation routes which require uninterrupted navigation for more than eight (8) hours.

That, in addition, article 7 of the Rules on Pilotage Services in Rivers, Passages and Channels of the Argentine Republic empowers this Maritime Authority to introduce temporary changes in the limits of the zones, as well as to incorporate new areas where necessary or in the interest of safety of navigation.

That considering the navigation zone – Río de la Plata (River Plate) - and for purposes of increasing Safety of Navigation and Environmental Protection, Permanent Provision DPRA No.: 2/92 (“Statutory Standards on the Pilot rest and Use of only one Pilot in any navigation longer than 220 Km.”) must not be applied to ships of 8,84 m. (29’ 00”) and upwards in length.

That the Navigation Centre, through Circular No: 11240, has suggested its members consider the need – rather than the convenience – of discouraging the practice of only one (1) professional on board when the duration of the journey exceeds eight (8) hours, considering that any incidental commercial benefit it may provide results valueless against the potential harm that may be caused by a navigation incident attributable to the excess of stress or lack of rest of the pilot conducting the ship.

That for the purposes of navigation safety, this Maritime Authority must regulate ships' navigation in National Jurisdiction waters, as well as ships' entering, berthing and exiting, in line with articles 89 and 34 of Navigation Act No. 20094, pursuant to article 5 para.. a) item. 2 of Act No. 18.398.-




ARTICLE 1.- To establish a minimum number of two pilots on board to conduct navigation on ships of 8.84 m (29’ 00”) or upwards in length through the channels of the River Plate Pilotage Area, even when the navigation route is shorter than 220 km.-

ARTICLE 2.- That the provisions of DPRA No.: 2/92 (“Statutory Standards on Pilot's Rest and Services of Only One Pilot in Navigation longer than 220 Km.”) shall not apply to ships of 8.84 metros (29´00´´) or upwards in length in the River Plate Pilotage Area.

ARTICLE 3.- This provision shall take effect thirty (30) days after being published in the Merchant Marine Bulletin (BIMM) and shall remain effective for one hundred and eighty (180) calendar days on a temporary basis. Prior to the end of this timeframe, the Safety of Navigation Police Direction shall inform the outcome of the measures established, so as to include them in the Rules on Pilotage Services for Rivers, Ports, Passages and Channels of the Argentine Republic on a permanent basis.-

ARTICLE 4.- That this resolution be made known, and informed to the relevant Chambers, Associations and Companies through the Safety of Navigation Police Direction (Pilotage and Navigation Personnel Department). Let it be published in the Merchant Marine Bulletin through the Navigation Regulations Department.. That so done, let it be filed with the above-mentioned Direction as background information.

Provision PRAC L5 1 No: 08/01.-