Audible response

Consultation response to revised notices on crew requirements for smaller vessels

Danske Havne would like to thank you for the opportunity to comment on the renewed consultation on the executive orders on crew requirements for smaller vessels.

Danske Havne acknowledges the intention to strengthen safety and the working environment for persons working on board small commercial vessels, including pilot boats. It is important that the regulation supports a high level of safety for the benefit of crews, pilots, and other users of the ports.

However, it is our opinion that safety in relation to pilotage is already high, and we are not aware of any serious incidents in this area that would indicate a need for further regulation. Experience shows that cooperation between pilots, skippers, and ports works well within the existing framework.

Danske Havne therefore considers it important that changes to manning requirements do not entail unnecessary costs for pilotage companies and thus shipping companies that use pilots, which could ultimately make pilotage unnecessarily expensive and thus weaken the competitiveness of Danish shipping.